| From: | Lenny Siegel <lsiegel@cpeo.org> |
| Date: | Wed, 29 Jul 2009 17:32:17 -0700 (PDT) |
| Reply: | cpeo-brownfields |
| Subject: | Re: [CPEO-BIF] Solar Brownfields |
I still believe that cleanup decisions should be based upon "reasonably
anticipated future land use," not current or next land use. And I still
prefer permanent remedies over those which require activity and use
limitations. Public health and the environment benefit in the long-run
from more complete cleanups. I consider cleanups un-reassuring when they
are based upon calculations that remove one straw from the risk camel's
back and call it safe. Such "risk-based" strategies are indeed less
protective.
I support the Brownfield concept because it takes the added value from reuse and applies it towards the cost of cleanup, often at sites where there is insufficient funding available from responsible parties or government agencies. I am willing to support solar installations directly on landfill caps where for other reasons - technical or economic - it has been determined that capping is the best remedy. I also recognize that groundwater cleanup is largely independent of the surface land use. I am concerned, in particular, about planning to place photovoltaic arrays directly upon the surface of the land, and then tailoring a risk-based soil cleanup (or lack thereof) to the minimal exposure pathways associated with that use. Not only does the residual contamination requiring long-term management, but it limits the land use. Remember, one can easily install solar panels on roofs and canopies, generating as much or more (if above the shade) energy while providing opportunities for housing, jobs, and/or parking and generating the value added to pay more for cleanup. Lenny Markus Niebanck wrote: Just a suggestion on the vernacular - it isn't that standards would be "lowered" as much as a cleanup goal would be established as a function of proposed site use. As Ed observes, a goal that reflects the evaluation of contaminant exposure to human and ecologic health in a solar array deployment scenario. Were the land to be cleared for unrestricted re-use it would have one cleanup goal; under a solar energy use strategy a different one. Not a lower/higher comparison - both endpoints are identical (protective of the user and the environment). Reutilizing impaired land, where practicable, for solar or wind power generation is, to me, a good thing. Markus -- 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 _______________________________________________ Brownfields mailing list Brownfields@lists.cpeo.org http://lists.cpeo.org/listinfo.cgi/brownfields-cpeo.org | |
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