Re: [CPEO-BIF] Gowanus Canal, Brooklyn, New York listing

[Lenny Siegel <lennysiegel@gmail.com>]

I believe the Times article about the proposed Superfund listing of the 
Gowanus Canal raises a key issue about the future of environmental 
cleanup, and I would urge members of this list to respond to my comments.

In my "Brownfields 101" presentations, I describe the two basic models 
of cleanup: Superfund, in which remediation is funded by responsible 
parties or the government, and Brownfields, in which cleanup is funded 
from the income generated by the future use. Both have their place.

I - and most of the community activists with which I work - have been 
discouraged by the trend, over the last decade, to address 
Superfund-caliber sites as Brownfields. When sites that pose the 
greatest threat to public health and the environment are treated as 
Brownfields, there is a tendency to leave contamination in place. While 
usually this provides short-term protection, it may lead to unacceptable 
risks in the long run.

I assume, based upon the findings of both the New York Department of 
Conservation and U.S. EPA Region 2, that the Gowanus Canal is indeed a 
Superfund-caliber site. The city of New York and the developers it is 
working with claim that placing the site on the Superfund National 
Priorities List (NPL) will make it difficult to develop property because 
of the stigma associated with Superfund.

I believe the opposite. The stigma exists because of the contamination. 
Unless knowledge of that site is hidden improperly, the act of listing 
and the associated additional environmental responses may actually 
reduce the stigma of building on and occupying the property. Sweeping 
environmental problems under the rug, foundation, or building is likely 
to create future exposure risks and/or litigation from inadequately 
protected site occupants.

No doubt adding a site to the NPL creates a hiccough in the process, as 
new rules and regulators are brought to bear on the site. But if indeed 
a site, because of the level of contamination, likelihood of pathways, 
and presence of receptors qualifies for Superfund listing, then the 
public deserves the protection that Superfund oversight provides.

Lenny

--


Lenny Siegel
Executive Director, Center for Public Environmental Oversight
a project of the Pacific Studies Center
278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
<lsiegel@cpeo.org>
http://www.cpeo.org



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