From: | Lenny Siegel <lsiegel@cpeo.org> |
Date: | Thu, 17 Sep 2009 11:27:10 -0700 (PDT) |
Reply: | cpeo-brownfields |
Subject: | Re: [CPEO-BIF] The Stigma Issue |
Barry, Mike, et al,I tend to believe that the policies that we collectively have developed over the past 15 years have to a large degree removed unnecessary impediments from property development. Of course, I consider requirements to protect public health and the environment from serious contamination to be necessary. To be sure, there are some states and localities where irrationalities persist, but the tools exist to do things right. The big question today is how better to let the public know about existing or potential toxic exposures (that they haven't been told about) without creating new, irrational obstacles to property reuse. Assuming that currently depressed property values rebound somewhat, I think that added awareness and the consequent pressure for protective action on actual development properties will not increase development costs prohibitively, but there are two other obstacles that we have to think through: 1) First, we have to reduce the amount of unproductive paperwork and the delays caused by backlogs at regulatory agencies. Long ago I observed that certain types of cleanup agreements rely entirely upon paperwork milestones, not actual cleanup milestones. Thus, cleanup projects tend to produce voluminous documents. (Shrinking them onto CDs doesn't solve the problem.) We need real-world milestones to streamline the cleanup process. 2) Often the biggest threat to public health, and the largest cleanup challenge, is addressing off-site migration. That is, it may be easy to prepare a property for reuse but protecting the neighbors may be a long, drawn-out process. It may be necessary to create hybrid cleanup models that follow the brownfields model, in which development pays for the cleanup, on the source property, but which for downgradient properties follow the enforcement model, in which the polluter or government funds pay for at least some of the cleanup. Lenny Trilling, Barry wrote: MIke: My experience and yours differ significantly. I too have seen significant increases in awareness by the general market of the opportunities provided by brownfield incentive programs, but they have far from reached the point of overcoming the general market's resistance to impaired properties. The playing field is far from level, with lenders reluctant to provide necessary financing, many state agencies still pursuing shot-gun style "polluter pays" policies in which innocent owners and purchasers are compelled to atone for the sins of past owners and operators, and suspicious community and environmental activists dogging any form of development that does not restore pristine pre-human habitation standards. Owners of such properties are reluctant to part with them because of the fear of lingering liabilities and purchasers, save for the benighted few described in your earlier posting, have not rushed in to purchase these sites, despite your own experience. In some states, such as Pennsylvania, state voluntary remediation programs have worked effectively to bring these properties back on the general mainstream market. In Connecticut, however, despite the existence of voluntary cleanup programs that provide some measure of protection to prospective purchasers, our Transfer Act provides a scheme of never-ending liability and extends to cleanup of contamination that migrated off property boundaries-- liabilities which, with very limited exception, can extend to subsequent owners. While New York and New Jersey both have sophisticated cleanup programs, they are burdened with bureaucratic impediments that discourage the development of all but the most economically promising properties (although NJ's adoption of a licensed environmental professional program is a step in the right direction away from bureaucracy). I suspect that only when most state programs are more like PA and less like those with burdens reflecting the very stigmatization we're discussing will most of us brownfield practitioners be able to share your rosier outlook.Further, a note to my friend Larry Schnapf in response to his message: If states and the federal government adopt your suggestion about even more compelled disclosure than we already have I suspect the problems I've noted above will only be compounded and we'll see even more sites boarded up, un-remediated, and undeveloped.Barry J. Trilling W I G G I N A N D D A N ABarry J. Trilling W I G G I N A N D D A N AFrom: Michael.Goldstein@akerman.com [mailto:Michael.Goldstein@akerman.com] Sent: Thursday, September 17, 2009 1:05 PM To: Trilling, Barry; ClarkH@BES.CI.PORTLAND.OR.US; petestrauss1@comcast.net Cc: ChisholmD@nashuanh.gov; brownfields@lists.cpeo.org Subject: RE: The Stigma IssueTo the contrary, my friend! Today's contaminated property reuse community is hardly the exclusive province of opportunistic specialty developers. In fact, I would argue that the OSDs are rapidly losing market share to the more conventional and mainstream developers and end users who strategically and programmatically pursue and build retail, residential, industrial, and mixed projects on these types of properties. (I don't know that I was "lauding" anyone in my prior post, but to the extent that I was, I laud the conventional and mainstreams too.) That said, the greater point that I was trying to make is directly counter to your assertion that specialty investors will have the "edge in sophistication and understanding of risk." Because I believe the opposite is true - i.e, that there is such widespread access to good information, regulatory and economic agency assistance, and qualified and experienced environmental and redevelopment professionals, that the playing field has been leveled (or near leveled) - the scary folklore associated with the Brownfields or NPL status of a contaminated site, historically communicated and understood as "stigma," is now increasingly being heard and interpreted (and acted upon) as "opportunity." A caveat: I'm fully aware that stigma as classically and commonly understood hasn't gone away and won't - and can't - anytime soon. Still, there is something afoot that is worthy of note and discussion (and that, in my opinion, reaffirms the health of the transactional and reuse marketplace for contaminated properties of all stripes). To sum up, the thesis that I'm proposing here and in my last post is that neither the Brownfield label nor the Superfund label in and of itself creates the same dysfunction in the marketplace as it might have ten years ago and perhaps even as recently as five years ago. Again, I see the label more as dinner bell than alarm bell and more likely to attract rather than repel an increasing universe of (both specialty and mainstream) buyers, redevelopers, and end users.------------------------------------------------------------------------ From: Trilling, Barry [mailto:BTrilling@wiggin.com] Sent: Thursday, September 17, 2009 12:17 PMTo: Goldstein, Michael (Sh-Mia); ClarkH@BES.CI.PORTLAND.OR.US; petestrauss1@comcast.netCc: ChisholmD@nashuanh.gov; brownfields@lists.cpeo.org Subject: RE: The Stigma IssueTalk about feeling compelled to re-enter the dialogue!! Mike's comment goes to the crux of the problem: the existence of stigma is a major contributing factor to the reluctance of the main-stream real estate development, investment, and financing community to deal with brownfield properties. As long as this under-served realm of impaired properties remains the exclusive domain of the opportunistic special investors described, and impliedly lauded, by Mike, we will not have moved far enough in having these properties cleaned up and developed. The rational objective of public policy should be to make these properties as attractive as possible to the mainstream market in order to get them cleaned up and redeveloped. Yes, the specialty investors will always have the edge in sophistication and understanding of risk, but we should not abandon the field to them.Barry J. Trilling W I G G I N A N D D A N AFrom: brownfields-bounces@lists.cpeo.org [mailto:brownfields-bounces@lists.cpeo.org] On Behalf Of Michael.Goldstein@akerman.comSent: Thursday, September 17, 2009 11:02 AM To: ClarkH@BES.CI.PORTLAND.OR.US; petestrauss1@comcast.net Cc: ChisholmD@nashuanh.gov; brownfields@lists.cpeo.org Subject: [CPEO-BIF] The Stigma IssueI feel compelled to re-enter the dialogue to offer this observation: In many communities (and many markets) across the country, there appears to be a subtle yet very real counter-dynamic at work that reflects a willingness of private investors and their capital to move towards stigma as opposed to away from it. We have clients - and I'm sure that many others on this listserve do as well - that use the Brownfields designation or the Superfund status of a site, property assemblage, corridor, or region as initial screening criteria to identify potential deal opportunities that they may want to pursue and acquire. So . . . if one party's stigma is another party's potential value proposition, is there really any stigma at all? And in terms of trying to empirically quantify the actual monetary discount purportedly related to stigma, if there are parties - in fact if there is a whole industry - willing (eager) to close, cleanup, and redevelop a given site, again, is there really any stigma at all? Perhaps stigma, in this light, doesn't really mean what we think it means. Perhaps it should be redefined to simply refer to those parties who lack the knowledge, ability, and risk tolerance to properly underwrite cleanup and construction premiums related to contamination and then identify, structure, and manage risk and liability properly. In this sense, maybe stigma is not a "thing" to be quantified, but a "state of mind" to be understood and put in context. I don't know the answers to any of these questions, but I do know this: There are plenty of folks out there who, when they hear a site is a Brownfield or on the NPL, not only do they not run the other way, their response is, "fantastic, tell me where it's located, what I can do with it, and what the asking price is."Put another way, for an increasing number of parties the Brownfields or Superfund status of a site isn't an alarm bell, it's the dinner bell.-MMichael 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 <mailto:michael.goldstein@akerman.com>"Recycle, Reuse, and Restore Environmentally Impacted Properties: Rebuild Your Community One Brownfield at a Time"<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>CONFIDENTIALITY NOTE: The information contained in this transmission may be privileged and confidential information, and is intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this transmission in error, please immediately reply to the sender that you have received this communication in error and then delete it. Thank you.CIRCULAR 230 NOTICE: To comply with U.S. Treasury Department and IRS regulations, we are required to advise you that, unless expressly stated otherwise, any U.S. federal tax advice contained in this transmittal, is not intended or written to be used, and cannot be used, by any person for the purpose of (i) avoiding penalties under the U.S. Internal Revenue Code, or (ii) promoting, marketing or recommending to another party any transaction or matter addressed in this e-mail or attachment.------------------------------------------------------------------------From: brownfields-bounces@lists.cpeo.org [mailto:brownfields-bounces@lists.cpeo.org] On Behalf Of Henry, ClarkSent: Wednesday, September 16, 2009 4:14 PM To: Peter Strauss Cc: Chisholm, Deb; brownfields@lists.cpeo.org Subject: Re: [CPEO-BIF] Dunedin and Tarpon Springs, FloridaI'm not trying to say that brownfields don't have a stigma, it's just that it is different than superfund because an innocent future owner's liability, or protection against it, is different. Not knowing the details of the case you reference below it is difficult to make any calls on this but initially I would say that yes, it is different. If the barrier was constructed to prevent recontamination, it seems to me like it is not related to the groundwater contamination and is an engineering control for ongoing operation of the brownfield site. Very common. If the barrier is intended to prevent vapor intrusion whose source is the groundwater, it is still different because the regulators recognize that the brownfield isn't the source of the contamination and the cost of the barrier can be recovered from the polluter (ideally). There is also a difference in cost (and final closure), which is what stigma and liability really boil down to. In the case of the Willamette river, the unquantified liabilities are in the hundreds of millions. A vapor barrier on a small footprint doesn't even compare. I do not know what the potential costs of the Gowanus cleanup are but that's the quintissential problem, not knowing. There is no question that the Gowanus should be cleaned up. The question is, how does it get paid for? Yes, in a sense, it's unique but I wonder just how unique. It's a waterway whose sources of pollution are the properties around it. When designated as a Superfund site, its cleanup will be paid for by the owners, after many years of public involvement and legal haggling. As stated below, I'm not taking a position on brownifeld vs. superfund but it's important to recognize that superfund designation of a waterway most definitley casts a stigma on the surrounding properties because that's who created and will pay for the pollution.Clark------------------------------------------------------------------------ From: Peter Strauss [petestrauss1@comcast.net] Sent: Wednesday, September 16, 2009 12:42 PM To: Henry, ClarkCc: 'Evans Paull'; lsiegel@cpeo.org; Chisholm, Deb; brownfields@lists.cpeo.orgSubject: 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 <mailto:clarkh@bes.ci.portland.or.us> www.brownfield.org <http://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 <mailto:lsiegel@cpeo.org>; Chisholm, Deb Cc: brownfields@lists.cpeo.org <mailto: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 aSuperfund 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_Process_)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.pdfEvans 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:brownfields&layout=blog&Itemid=214&layout=default>------------------------------------------------------------------------ From: brownfields-bounces@lists.cpeo.org <mailto: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 <mailto: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 avery 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 reallymaking.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<mailto:brownfields-bounces@lists.cpeo.org> on behalf of Trilling, BarrySent: Tue 9/15/2009 3:25 PM To: 'lsiegel@cpeo.org <mailto:'lsiegel@cpeo.org>' Cc: 'brownfields@lists.cpeo.org <mailto:'brownfields@lists.cpeo.org>' Subject: Re: [CPEO-BIF] Dunedin and Tarpon Springs, FloridaLenny: 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 <mailto:lsiegel@cpeo.org>> To: Trilling, Barry Cc: brownfields@lists.cpeo.org <mailto:brownfields@lists.cpeo.org><brownfields@lists.cpeo.org <mailto: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 wasonce afield.) 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 myhouse, andmany have undergone redevelopment. There are many more non-Superfund sites with documented contamination. My point is that whatever stigma exists - at least here - is afunctionof 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 significantdifference 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 toSuperfund 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 site 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> [mailto:brownfields-bounces@lists.cpeo.org] On Behalf Of Lenny Siegel>Sent: Wednesday, September 09, 2009 7:39 PM >To: Michael.Goldstein@akerman.com<mailto:Michael.Goldstein@akerman.com>>Cc: brownfields@lists.cpeo.org <mailto: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<mailto: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 willingto build>>in areas designated a brownfield." This particular laundry list of >>incentives for sites located in a designated Brownfield Area iscorrect;>>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 privatesector and>>public sector actors thinking about putting a toe in the Brownfields >>arena. More specifically, although environmental professionalshere have>>long been promoting the Florida Brownfields Program as aneffective 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 developerscite>>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 formallydesignated 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 byend-users, the>>weight of experience among Brownfield practitioners throughoutthe state>>strongly suggests exactly the opposite. What the marketplace has >>actually taught us since enactment of Florida's BrownfieldsProgram in>>1997 is this: The Brownfields designation accelerates therecycling of>>contaminated property and turbocharges a project's ability to attract >>any combination of equity, debit, investors, residents, andtenants. The>>designation and the processes that follow provide a level ofcomfort and>>assurance that state and local environmental regulators will be >>institutionally invested in the project, that local governmentofficials>>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 asmart>>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 asophisticated>>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 redevelopmentfunds" -> >>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 underlyingcontamination or>>perception of contamination (among other criteria) that triggers the >>eligibility for designation in the first instance. Thedesignation, on>>the other hand, is the delivery vehicle for the financial andregulatory>>incentives, the private capital, and the expedited permitting (among >>other benefits) that create the initial catalyzing effect andlaunch a>>project towards rehabilitation and reuse. In short, thedesignation 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 columnistconcludes, "act>>quickly" to get their fair share of federal and state grantprograms and>>other economic incentives because the marketplace in Florida has also >>taught this lesson: Private capital chases the flow of publicfunds, and>>the powerful leveraging effect created by the combination ofpublic 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 <mailto: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 <mailto:michael.goldstein@akerman.com> >> >>"Recycle, Reuse, and Restore Environmentally Impacted Properties: >>Rebuild Your Community One Brownfield at a Time" >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >><http://www.akerman.com/> >>www.akerman.com <http://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> >> >> >>CONFIDENTIALITY NOTE: The information contained in thistransmission may>>be privileged and confidential information, and is intended onlyfor the>>use of the individual or entity named above. If the reader of this >>message is not the intended recipient, you are hereby notifiedthat any>>dissemination, distribution or copying of this communication isstrictly>>prohibited. If you have received this transmission in error, please >>immediately reply to the sender that you have received this >>communication in error and then delete it. Thank you. >> >>CIRCULAR 230 NOTICE: To comply with U.S. Treasury Department and IRS >>regulations, we are required to advise you that, unless expresslystated>>otherwise, any U.S. federal tax advice contained in thistransmittal, is>>not intended or written to be used, and cannot be used, by any person >>for the purpose of (i) avoiding penalties under the U.S. Internal >>Revenue Code, or (ii) promoting, marketing or recommending to another >>party any transaction or matter addressed in this e-mail orattachment.>> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >>-----Original Message----- >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >> >>From: brownfields-bounces@lists.cpeo.org<mailto: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 theEnvironmental>>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 newwave>>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 economicredevelopment>>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 <mailto:lsiegel@cpeo.org>> >>http://www.cpeo.org <http://www.cpeo.org/> <http://www.cpeo.org/> >> >> >> >>_______________________________________________ >>Brownfields mailing list >>Brownfields@lists.cpeo.org <mailto: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 <mailto:lsiegel@cpeo.org>> >http://www.cpeo.org <http://www.cpeo.org/> <http://www.cpeo.org/> > > > > >_______________________________________________ >Brownfields mailing list >Brownfields@lists.cpeo.org <mailto:Brownfields@lists.cpeo.org> >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 >and delete the transmittal and any attachments. > >Neither this message nor the documents attached to this >message are encrypted. >********************************************************************** > > > > -- 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 <mailto: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 <mailto: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 <mailto:lsiegel@cpeo.org>> http://www.cpeo.org <http://www.cpeo.org/> _______________________________________________ Brownfields mailing list Brownfields@lists.cpeo.org <mailto:Brownfields@lists.cpeo.org> http://lists.cpeo.org/listinfo.cgi/brownfields-cpeo.org _______________________________________________ Brownfields mailing list Brownfields@lists.cpeo.org <mailto:Brownfields@lists.cpeo.org> 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 senderand delete the transmittal and any attachments.Neither this message nor the documents attached to thismessage are encrypted. ********************************************************************************************************************************************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 _______________________________________________ Brownfields mailing list Brownfields@lists.cpeo.org http://lists.cpeo.org/listinfo.cgi/brownfields-cpeo.org | |
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