2010 CPEO Brownfields List Archive

From: Lenny Siegel <lennysiegel@gmail.com>
Date: Mon, 1 Mar 2010 08:13:14 -0800 (PST)
Reply: cpeo-brownfields
Subject: Re: [CPEO-BIF] Proposals for EPA's March 17 listening session
 
FROM A STATE REGULATOR ...

Lenny,

I'd like to see a little more "meat on the bone" regarding "Section 312.29 - The relationship between purchase price vs. value of property, if not contaminated", namely a little more research into the "value of the property, if not contaminated." It seems to me that this should be a requirement of the Environmental Professional. At a minimum, the value listed on the Tax Rolls should be required. We're not talking rocket science here.

As far as the "disclosure" issue is concerned, it is very simple. As long as it is up to the "Environmental Professional" (and I use that term loosely) to decide whether a REC poses a threat to public health and the environment (i.e., his/her own judgment of the STATE's rules),... ain't nothin' gonna happen.

While there are exceptions out there, "Doin' The Right Thing" is, for the most part, just a movie.


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