Re: [CPEO-BIF] Brownfields Digest, Vol 61, Issue 24

["Schnapf, Lawrence" <Lawrence.Schnapf@srz.com>]

an NPL site can include the source area of the release as well as
wherever the hazardous substances have come to rest. If the source is a
property on the riverbank that has released hazardous substances that
have settled into the sediments of the river, the site can include the
land along the river as well as the river. Likely the source area and
the river would be identified as separate operable units for
administative purposes......

Larry  

-----Original Message-----
From: brownfields-bounces@lists.cpeo.org
[mailto:brownfields-bounces@lists.cpeo.org] On Behalf Of Charles Rich
Sent: Wednesday, September 16, 2009 4:51 PM
To: brownfields@lists.cpeo.org
Subject: Re: [CPEO-BIF] Brownfields Digest, Vol 61, Issue 24

We are not talking about a river in Cleveland catching on fire.  How can
a
natural waterway be classified as a Federal NPL Superfund Site?  In
reality,
it is subject to varying QW over the years.  What cleanup objectives
would
apply.  It is not an "inactive hazardous waste site.."  and surely one
could
not have it qualify by any sort of rating system - as originally
utilized to
qualify the initial sites listed on the NPL back in the 80s.  It
obviously
also would not qualify as a 'brownfield' by definition.   I think,
constructively, and quite effectively,  we would need to simply enforce
the
Clean Water Act at Gowanus, since enforcement of it nationwide has been
so
lax for many, many years.  

-----Original Message-----
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Sent: Wednesday, September 16, 2009 3:59 PM
To: brownfields@lists.cpeo.org
Subject: Brownfields Digest, Vol 61, Issue 24

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Today's Topics:

   1. Re: Dunedin and Tarpon Springs, Florida (Schnapf, Lawrence)


----------------------------------------------------------------------

Message: 1
Date: Wed, 16 Sep 2009 15:47:42 -0400
From: "Schnapf, Lawrence" <Lawrence.Schnapf@srz.com>
To: "Peter Strauss" <petestrauss1@comcast.net>,	"Henry, Clark"
	<ClarkH@BES.CI.PORTLAND.OR.US>
Cc: "Chisholm, Deb" <ChisholmD@nashuanh.gov>,
	brownfields@lists.cpeo.org
Subject: Re: [CPEO-BIF] Dunedin and Tarpon Springs, Florida
Message-ID: <ABB79193261A514FBDF8547B67F610A8063E418B@nyexch4.srz.com>
Content-Type: text/plain; charset="us-ascii"

i dont think Gawanus is unique. there are lots of urban rivers with the
same issues..........

________________________________

From: brownfields-bounces@lists.cpeo.org
[mailto:brownfields-bounces@lists.cpeo.org] On Behalf Of Peter Strauss
Sent: Wednesday, September 16, 2009 3:42 PM
To: Henry, Clark
Cc: Chisholm, Deb; brownfields@lists.cpeo.org
Subject: Re: [CPEO-BIF] Dunedin and Tarpon Springs, Florida


Clark: 
Let's look at a different scenario, one where I have some experience.
The site was designated a brownfield site, and the relatively small
footprint of the new building was cleaned up.  However, during the
remediation they discovered that groundwater flowing beneath the
property was contaminated with a variety of chemicals, requiring them to
build barrier that would prevent recontamination.  The "upstream"
sources have not been cleaned up, or face any enforcement actions,
although the state regulators have promised to attempt identify
responsible parties, (and only after the community's consultant pointed
it out).  I am skeptical that they have the resources to follow through
on this commitment.  Isn't this the same situation as you cite below.
Isn't the "stigma" the same?

Gowanus is a unique situation.  It is located in a highly urbanized
area. It is not a "natural" canal.   After years of pouring all sorts of
industrial contaminants into it, the surrounding area lost most of its
industrial sources.  As a result, and a project that allowed some clean
water to flow into the canal, it supported, for a time, a fish
population.  This became the driver for health and ecological risks to
exceed the EPA criteria for listing on the NPL.  Ironically, if it were
just a stagnant, highly polluted canal that supported no life (except
for bacteria), it wouldn't qualify.

Peter
On Sep 16, 2009, at 8:40 AM, Henry, Clark wrote:


	Without taking a Superfund or Brownfield only position, I do
recognize a difference from the stigma attached to each, especially when
the Superfund site is a waterway and the stigma rides with the upland
properties as Evans points out below.  Since the rivers did not pollute
themselves the liability rides on the upland sites even if they
themselves are not designated superfund sites.  Portland, Oregon is
experiencing the issue Evans describes below.   Those upland sites are
considered to be in what we are calling the Superfund cloud, or the
study area in which EPA sees liable parties located.  Sites within that
cloud are not eligible for brownfield funding.  Tacoma Washington is
experiencing the same thing.   This nuance creates confusion which never
makes a purchaser comfortable.
	 
	Without EPA confirming that a purchaser has successfully
achieved protections afforded through All Appropriate Inquiry, they
avoid the purchase of a property within that 'cloud' for fear of being
dragged into unquantified Superfund and NRDC claims.  Most (if not all)
states have some form of Prospective Purchaser Agreements establishing
protection from State agencies for brownfields but they don't have
authority over Superfund. The result locally is hundreds of acres of
unused employment land in a state with 12.3% unemployment.
	 
	Clark

	Clark Henry 
	City of Portland 
	Portland Brownfield Program
	(503) 823-5863 - office 
	(503) 823-5565 - fax 
	clarkh@bes.ci.portland.or.us 
	www.brownfield.org 
	  


________________________________

		From: brownfields-bounces@lists.cpeo.org
[mailto:brownfields-bounces@lists.cpeo.org] On Behalf Of Evans Paull
		Sent: Wednesday, September 16, 2009 6:38 AM
		To: lsiegel@cpeo.org; Chisholm, Deb
		Cc: brownfields@lists.cpeo.org
		Subject: Re: [CPEO-BIF] Dunedin and Tarpon Springs,
Florida
		
		
		I don't know the specifics of the Gowanus Canal, but EPA
often designates a larger landside area as contributing to the Superfund
site.  I'm familiar with several west coast cities, where current or
proposed sediment cleanup superfund/NPL sites also include a large land
area as contributing to the Superfund site.  This has generated much
concern in the locality and for business investment related to
stigmatizing large areas of the cities.  These contributing areas seem
to have murky legal ramifications, but concerns were elevated in one
city when EPA turned down a brownfields application because the site was
deemed ineligible due to its location within a Superfund site.  
		 
		These issues of Superfund/NPL vs. other mechanisms are
often debated in the Great Lakes region, where there is federal funding
under the Great Lakes Legacy Program for sediment cleanup, but only at
sites where the NPL enforcement mechanisms have failed or there are
well-documented orphan shares.  The two sources can also be mixed under
an interesting formula (see:
http://www.epa.gov/glnpo/sediment/legacy/rule/rfp.html#8._Evaluation_Pro
cess_)
		 
		For Gowanus, I assume there is no similar alternative
source for federal funding of orphan shares.
		 
		We produced a report on ways to tie sediment cleanup to
landside development, available at:
http://www.nemw.org/images/stories/documents/Innov_Financing_GL_Dec08.pd
f
		 
		
		Evans Paull, Senior Policy Analyst
		Northeast Midwest Institute
		50 F Street, NW
		Washington, DC 20001
		202-329-4282 (cell)
		fax 202-544-0043
		epaull@nemw.org <mailto:epaull@nemw.org> 
		www.nemw.org <http://www.nemw.org/>  
		NEMW Brownfields Website
<http://www.nemw.org/index.php?option=com_content&view=category&id=18:br
ownfields&layout=blog&Itemid=214&layout=default> 

________________________________

		From: brownfields-bounces@lists.cpeo.org on behalf of
Lenny Siegel
		Sent: Tue 9/15/2009 8:26 PM
		To: Chisholm, Deb
		Cc: brownfields@lists.cpeo.org
		Subject: Re: [CPEO-BIF] Dunedin and Tarpon Springs,
Florida
		
		

		Deb,
		
		In Brooklyn, only the Gowanus Canal - the waterway
itself - is proposed
		for the "Superfund" National Priorities List. The
adjacent properties
		that are proposed for redevelopment would not be hurt by
policies
		denying brownfields funding to Superfund sites.
		
		People who have smelled the canal are skeptical that
Listing would
		create a greater stigma.
		
		Lenny
		
		
		Chisholm, Deb wrote:
		> The Brooklyn Gowanus Canal site is proposed to the
NPL.  This is a very important point not to be overlooked.  It may
escape the stigma attached to a Superfund designation, but it does not
get funding typically associated with Brownfield sites.  Sites on or
proposed to the NPL are ineligible for Brownfield funding from EPA and
from HUD's BEDI program.  The only way to remove the proposed status is
to clean it up - with regulatory oversight just like a real Superfund
site.  We have a site in NH also in this Superfund purgatory.  So when
looking to escape the stigma of Superfund, people should be careful
about what concessions they're really making.    
		> 
		> Deb Chisholm
		> Brownfields Coordinator
		> Nashua Community Development Division
		> City Hall, 229 Main Street, PO Box 2019
		> Nashua, NH 03061-2019
		> Phone: (603) 589-3074
		> Cell Phone: (603) 491-7763
		> Fax: (603) 589-3119
		>
		> ________________________________
		>
		> From: brownfields-bounces@lists.cpeo.org on behalf of
Trilling, Barry
		> Sent: Tue 9/15/2009 3:25 PM
		> To: 'lsiegel@cpeo.org'
		> Cc: 'brownfields@lists.cpeo.org'
		> Subject: Re: [CPEO-BIF] Dunedin and Tarpon Springs,
Florida
		>
		>
		>
		> Lenny:  I believe you make my point for me with yoir
examples:  the reality on and under the ground may have less to do with
stigma than the title we attribute to the property.  Some properties
that are considered "mere" brownfields have significant contamination
but may escape deserved stigma until the seriousness of their condition
becomes publicly known.  Any property that carries a "Superfund" label
automaticallly has an indelible mark, notwithstanding its level of
contamination or success in cleanup.  Once the label attaches it is
almost always irreversible.  Non-Superfund brownfield sites may have
hope for development and reuse that the Superfund label would not
permit.  Hence the reluctance to make the Brooklyn Gowanas Canal a
Superfund site.
		>
		> ----- Original Message -----
		> From: Lenny Siegel <lsiegel@cpeo.org>
		> To: Trilling, Barry
		> Cc: brownfields@lists.cpeo.org
<brownfields@lists.cpeo.org>
		> Sent: Tue Sep 15 14:57:33 2009
		> Subject: Re: [CPEO-BIF] Dunedin and Tarpon Springs,
Florida
		>
		> Barry,
		>
		> Brownfields sites include many uncontaminated parties.
(In fact, in
		> Michigan the only requirement appears to be that the
property was once a
		> field.)
		>
		> And Superfund sites include lands that should never be
redeveloped for
		> continuing human occupancy.
		>
		> But there are many sites, such as factories where
releases impact
		> groundwater in the neighborhood, that could go either
way.
		>
		> There are about 20 Superfund listings within ten miles
of my house, and
		> many have undergone redevelopment. There are many more
non-Superfund
		> sites with documented contamination.
		>
		> My point is that whatever stigma exists - at least
here - is a function
		> of the contamination and has little to do with whether
the sites are
		> listed under Superfund or any other regulatory
program.
		>
		> Lenny
		>
		> Trilling, Barry wrote:
		>
		>>Lenny:  There's a world of semantic and legally
significant difference between a "Superfund" site and a "brownfield."
Superfund sites are thought of as the worst kind of environmental
disaster zones, such as the Love Canal or Times Beach.  The Operating
Industries SIte, for example, long rated #1 on the EPA National
Contingency List, started its life as a 400 foot pit and over time was
filled with industrial waste until to towered as a hill 1/4 mile up into
the horizon, with literally thousands of potentially responsible
parties.  This is a far cry from a typical brownfield, for instance a
former metal finishing shop located in a strip mall.  Most voluntary
remediation programs do not extend eligibility to Superfund sites.  A
brownfield, on the other hand, may not even be contaminated, but merely
carry the stigma of potential contamination by virtue of its prior
industrial use.  It is easy to understand how the stigma of the word
Superfund will stick, while a brownfield si
		
		>
		> te may lose that stigma after undergoing cleanup.
		>
		>>Barry J. Trilling
		>> W I G G I N  A N D  D A N A
		>>
		>>
		>>-----Original Message-----
		>>From: brownfields-bounces@lists.cpeo.org
[mailto:brownfields-bounces@lists.cpeo.org] On Behalf Of Lenny Siegel
		>>Sent: Wednesday, September 09, 2009 7:39 PM
		>>To: Michael.Goldstein@akerman.com
		>>Cc: brownfields@lists.cpeo.org
		>>Subject: Re: [CPEO-BIF] Dunedin and Tarpon Springs,
Florida
		>>
		>>Michael,
		>>
		>>Thanks for the background. I find it ironic that in
some locales, such
		>>as New York City, developers and the city prefer
"Brownfield" over
		>>"Superfund" because it supposedly does NOT carry the
stigma.
		>>
		>>My experience in Silicon Valley suggests that whatever
stigma is
		>>associated with contaminated property doesn't come
from a government
		>>label. Instead, it derives from the contaminated or
blighted condition
		>>of the property. To the degree that labeling helps
repair that
		>>condition, it overcomes the stigma.
		>>
		>>Lenny
		>>
		>>Michael.Goldstein@akerman.com wrote:
		>>
		>>
		>>>First a clarification is in order.   The columnist
refers to the EPA
		>>>Brownfields Program as "offering tax incentives,
grant funds,
		>>>low-interest loans and employee training for
developers willing to build
		>>>in areas designated a brownfield."  This particular
laundry list of
		>>>incentives for sites located in a designated
Brownfield Area is correct;
		>>>however, the government entity offering them is the
State of Florida,
		>>>not EPA.
		>>>
		>>>That said, the larger point the columnist makes is
spot on and
		>>>underscores what has historically been a steep
learning curve - and
		>>>persistent source of resistance - in Florida for both
private sector and
		>>>public sector actors thinking about putting a toe in
the Brownfields
		>>>arena. More specifically, although environmental
professionals here have
		>>>long been promoting the Florida Brownfields Program
as an effective way
		>>>to, in the words of the columnist, "spark a new wave
of economic
		>>>redevelopment" and "eliminat[e] urban blight in
commercial and
		>>>industrial areas," inexperienced local governments
and developers cite
		>>>the fear that a "Brownfields label" would lead to
further market
		>>>dysfunction as a principal basis for staying on the
sidelines.
		>>>
		>>>While there has been no empirical study of whether
and, if so, precisely
		>>>how and to what extent properties that have been
formally designated a
		>>>Brownfield in Florida (i) suffer some measure of
diminution in value,
		>>>(ii) have a more difficult time obtaining financing
(or financing at
		>>>market rates), or (iii) are marginalized or rejected
by end-users, the
		>>>weight of experience among Brownfield practitioners
throughout the state
		>>>strongly suggests exactly the opposite.  What the
marketplace has
		>>>actually taught us since enactment of Florida's
Brownfields Program in
		>>>1997 is this: The Brownfields designation accelerates
the recycling of
		>>>contaminated property and turbocharges a project's
ability to attract
		>>>any combination of equity, debit, investors,
residents, and tenants. The
		>>>designation and the processes that follow provide a
level of comfort and
		>>>assurance that state and local environmental
regulators will be
		>>>institutionally invested in the project, that local
government officials
		>>>will utilize all of the planning and economic tools
and resources at
		>>>their disposal, that credentialed and serious legal
and engineering
		>>>professionals will be engaged, that the cleanup will
proceed on a smart
		>>>and predictable schedule, that development and
construction will be
		>>>subject to innovative and cutting-edge design
methodologies, and that
		>>>the risk of exposure to be liability will be managed
in a sophisticated
		>>>and effective manner.
		>>>
		>>>The line in the column that resonates most deeply -
"A bit of stigma
		>>>over a designation no one will remember should not
deter these cities
		>>
		>>>from getting hundreds of thousands of dollars in
redevelopment funds" -
		>>
		>>>also rings extraordinarily true, notwithstanding the
issue that some
		>>>observers take with the notion that the designation
creates even "a bit
		>>>of stigma."  If there is stigma, it's in the
underlying contamination or
		>>>perception of contamination (among other criteria)
that triggers the
		>>>eligibility for designation in the first instance.
The designation, on
		>>>the other hand, is the delivery vehicle for the
financial and regulatory
		>>>incentives, the private capital, and the expedited
permitting (among
		>>>other benefits) that create the initial catalyzing
effect and launch a
		>>>project towards rehabilitation and reuse.  In short,
the designation is
		>>>neither manifestation nor exacerbation of market
dysfunction; rather,
		>>>it's a swift first step towards prompt environmental
cleanup and
		>>>successful economic revitalization.
		>>>
		>>>Finally, yes, local governments should, as the
columnist concludes, "act
		>>>quickly" to get their fair share of federal and state
grant programs and
		>>>other economic incentives because the marketplace in
Florida has also
		>>>taught this lesson: Private capital chases the flow
of public funds, and
		>>>the powerful leveraging effect created by the
combination of public and
		>>>private money is the single greatest factor in
establishing the
		>>>feasibility of a Brownfields redevelopment project.
		>>>
		>>>-M
		>>>
		>>>Michael R. Goldstein, Esq.
		>>>Akerman Senterfitt
		>>>One Southeast Third Avenue, 28th Floor
		>>>Miami, FL 33131
		>>>Direct Line: 305.982.5570
		>>>Direct Facsimile: 305.349.4787
		>>>Mobile Phone: 305.962.7669
		>>>michael.goldstein@akerman.com
		>>>
		>>>"Recycle, Reuse, and Restore Environmentally Impacted
Properties:
		>>>Rebuild Your Community One Brownfield at a Time"
		>>>
		>>>
		>>>Michael R. Goldstein, Esq.
		>>>Akerman Senterfitt
		>>>One Southeast Third Avenue, 28th Floor
		>>>Miami, FL 33131
		>>>Direct Line: 305.982.5570
		>>>Direct Facsimile: 305.349.4787
		>>>Mobile Phone: 305.962.7669
		>>>michael.goldstein@akerman.com
		>>>
		>>>"Recycle, Reuse, and Restore Environmentally Impacted
Properties:
		>>>Rebuild Your Community One Brownfield at a Time"
		>>>
		>>>
		>>>
		>>>
		>>>
		>>>
		>>>
		>>>
		>>>
		>>>
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		>>>
		>>>
		>>><http://www.akerman.com/>
		>>>www.akerman.com <http://www.akerman.com/> | Bio
	
>>><http://www.akerman.com/public/attorneys/aBiography.asp?id=619> | V
Card
	
>>><http://www.akerman.com/public/attorneys/vcard.asp?id=619>
		>>>
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		>>>
		>>>
		>>>-----Original Message-----
		>>>
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		>>>From: brownfields-bounces@lists.cpeo.org
		>>>[mailto:brownfields-bounces@lists.cpeo.org] On Behalf
Of Lenny Siegel
		>>>Sent: Tuesday, September 08, 2009 5:13 PM
		>>>To: Brownfields Internet Forum
		>>>Subject: [CPEO-BIF] Dunedin and Tarpon Springs,
Florida
		>>>
		>>>What's a little contamination among friends?
		>>>
		>>>COLUMN BY MARK SCHANTZ
		>>>SUNCOAST NEWS (FL)
		>>>September 5, 2009
		>>>
		>>>What's a little contamination among friends,
especially when it means
		>>>millions of federal tax stimulus dollars being
available to local
		>>>governments and area developers?
		>>>
		>>>Cities like Largo and Clearwater have already
utilized the Environmental
		>>>Protection Agency's Brownfields Redevelopment Grant
Program to
		>>>revitalize their depressed areas, by providing
economic incentives to
		>>>developers and business owners. These grant funds can
spark a new wave
		>>>of economic redevelopment eliminating urban blight in
commercial and
		>>>industrial areas. It can help property owners repair
and redevelop
		>>>buildings.
		>>>
		>>>The Dunedin City Commission is considering declaring
its downtown
		>>>community redevelopment district and other parts of
its city a
		>>>brownfield. The designation would be a great fit in
Tarpon Springs,
		>>>which badly needs to attract developers and spark
economic redevelopment
		>>>downtown, at the Sponge Docks and along the Pinellas
Avenue corridor.
		>>>
		>>>...
		>>>
		>>>For the entire column, see
	
>>>http://suncoastpinellas.tbo.com/content/2009/sep/05/pi-whats-a-little
-contamination-among-friends/
		>>>
		>>>--
		>>>
		>>>
		>>>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 <http://www.cpeo.org/>
<http://www.cpeo.org/>
		>>>
		>>>
		>>>
		>>>_______________________________________________
		>>>Brownfields mailing list
		>>>Brownfields@lists.cpeo.org
	
>>>http://lists.cpeo.org/listinfo.cgi/brownfields-cpeo.org
		>>>
		>>
		>>
		>>
		>>
		>>
		>>--
		>>
		>>
		>>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 <http://www.cpeo.org/>
<http://www.cpeo.org/>
		>>
		>>
		>>
		>>
		>>_______________________________________________
		>>Brownfields mailing list
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>>http://lists.cpeo.org/listinfo.cgi/brownfields-cpeo.org
	
>>**********************************************************************
		>>This transmittal is intended for a particular
addressee(s). It
		>>may constitute a confidential attorney-client
communication.
		>>If it is not clear that you are the intended
recipient, you are
		>>hereby notified that you have received this
transmittal in error;
		>>any review, copying or distribution or dissemination
is strictly
		>>prohibited. If you suspect that you have received this
		>>transmittal in error, please notify Wiggin and Dana
		>>immediately at 203-498-4400, or by email, reply to the
sender
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>>**********************************************************************
		>>
		>>
		>>
		>>
		>
		>
		>
		>
		> --
		>
		>
		> 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 <http://www.cpeo.org/>
<http://www.cpeo.org/>
		>
		>
		>
		>
		>
		>
**********************************************************************
		> This transmittal is intended for a particular
addressee(s). It
		> may constitute a confidential attorney-client
communication.
		> If it is not clear that you are the intended
recipient, you are
		> hereby notified that you have received this
transmittal in error;
		> any review, copying or distribution or dissemination
is strictly
		> prohibited. If you suspect that you have received this
		> transmittal in error, please notify Wiggin and Dana
		> immediately at 203-498-4400, or by email, reply to the
sender
		> and delete the transmittal and any attachments.
		>
		> Neither this message nor the documents attached to
this
		> message are encrypted.
		>
**********************************************************************
		>
		>
		>
		> _______________________________________________
		> Brownfields mailing list
		> Brownfields@lists.cpeo.org
		>
http://lists.cpeo.org/listinfo.cgi/brownfields-cpeo.org
		>
		>
		>
		
		
		--
		
		
		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 <http://www.cpeo.org/> 
		
		
		
		_______________________________________________
		Brownfields mailing list
		Brownfields@lists.cpeo.org
		http://lists.cpeo.org/listinfo.cgi/brownfields-cpeo.org
		

	_______________________________________________
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************************************************************************
****
*
U.S. Treasury Circular 230 Notice: Any U.S. federal tax advice included
in
this 
communication was not intended or written to be used, and cannot be
used,
for the 
purpose of avoiding U.S. federal tax penalties.
************************************************************************
****
* 



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End of Brownfields Digest, Vol 61, Issue 24
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*****************************************************************************
U.S. Treasury Circular 230 Notice: Any U.S. federal tax advice included in this 
communication was not intended or written to be used, and cannot be used, for the 
purpose of avoiding U.S. federal tax penalties.
***************************************************************************** 



NOTICE

This e-mail message is intended only for the named recipient(s) above. It may 
contain confidential information that is privileged or that constitutes attorney 
work product.  If you are not the intended recipient, you are hereby notified that 
any dissemination, distribution or copying of this e-mail and any attachment(s) is 
strictly prohibited.  If you have received this e-mail in error, please immediately 
notify the sender by replying to this e-mail and delete the message and any 
attachment(s) from your system.  Thank you.
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