2010 CPEO Brownfields List Archive

From: michael.goldstein@akerman.com
Date: Thu, 11 Nov 2010 07:10:27 -0800 (PST)
Reply: cpeo-brownfields
Subject: Re: [CPEO-BIF] US Mayors Brownfield Report
 
Larry, keep stirring the pot!  I happen to disagree with you on this one - strongly - and think this would create a huge chilling effect on redevelopment activity, killing an important percentage of it in the starting gate.  In fact, I can think of a number of valid public policy reasons why federal resources should not be allocated for this type of activity.  Not even for a minute. 
 
That said, I would like to switch gears and raise another issue implicated by the huge federal investment in assessment and cleanup grants, which investment is channeling hundreds of millions of dollars into the coffers of environmental engineering and consulting firms.  
 
The issue is this: Given the windfall that these firms are enjoying, how many have turned around and made a point to hire graduates from EPA's Brownfield Job Training Grant Program?  I've been participating in a BJTG Program here in South Florida, and we are having a heck of a time getting firms to even attend our job fairs, much less hire our graduates. 
 
I'm wondering what others are seeing across the country. 
 
For the EPA folks on this listserv, is the Agency collecting this type of data (and, if so, is an attempt being made to correlate the firms that are receiving EPA assessment/cleanup grant funded work with the number of hires these same firms make out of the BJTG Program)? 
 
It would be illuminating to know which firms are getting the most grant funded assessment and cleanup work and what their BJGT Program hiring record is.  
 
In our part of the world - and I'm confident this is true all over the country - we are graduating bright, eager, enthusiastic students who emerge from the program with high expectations and great need.  We need to get them gainfully employed, and the firms that are the beneficiaries of EPA's assessment and cleanup grants should be lining up to do the hiring. This may, in fact, be happening elsewhere; unfortunately, we're seeing very little of it in South Florida.  Again, what are others seeing?
 
Best regards,
Michael
 
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
 
"Recycle, Reuse, and Restore Environmentally Impacted Properties: Rebuild Your Community One Brownfield at a Time"
 
 
 


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From: brownfields-bounces@lists.cpeo.org [mailto:brownfields-bounces@lists.cpeo.org] On Behalf Of larry@schnapflaw.com
Sent: Wednesday, November 10, 2010 3:32 PM
To: brownfields@lists.cpeo.org
Subject: [CPEO-BIF] US Mayors Brownfield Report

I think an unaddressed question is how much of brownfield assessment or cleanup grant funds have been used at former corporate facilities for which there are still viable PRPs?  I think the federal government should seriously consider seeking cost recovery from viable PRPs for brownfield sites where EPA has awarded brownfield assessment or cleanup grants. In a time of diminishing federal  resources, this could help assure there will be sufficient funds in the future for more brownfield funding as well as help replenish the superfund account.

I am not suggesting using cost recovery up front since this would delay redevelopment. Nor am I suggesting that EPA pursue small businesses or disqualify an application/grantee because a viable PRP is around. However, when brownfield grants are used to assess former corporate facilities-especially those abandoned in the past 20 years (i.e, after the passage of CERCLA)- it seems to be we are creating yet another moral hazard to those that have occurred in the past decade since cmpanies can export jobs to Asia and abandoned their facilities figuring that the local government will apply for brownfield funds to clean up the mess they left behind.

It would be interesting to see if EPA even tracks how many sites that received brownfield funding have viable PRPs associated with them. If I was a betting man, I'd wager that EPA does not compile such info.

Yet another example of the erosion of the "polluter should  pay" framework.  

Schnapf Law Offices 
55 East 87th Street, Ste. 8B
New York, NY 10128
212-756-2205 (p) 
646-468-8483 (c)
Larry@SchnapfLaw.com
http://www.SchnapfLaw.com/
 
 

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