|From:||Emery Graham <"egraham"@ci.wilmington.de.us>|
|Date:||Mon, 8 Mar 1999 15:31:57 -0800 (PST)|
|Subject:||Definition of Brownfields Question on HUD Chat|
A hazardous wastesite by any other name is a hazardous wastesite. When does a Brownfield become a hazardous wastesite; after a Phase II assessment determines that the site contains substances defined in Federal, state, or local laws as a danger to life, health, and safety? One of the emerging problems with municipalites engaging in the brownfields programs seems to be their confoundment re defining a hazardous wastesite and a brownfield. What's the difference? Regardless of which level of government's definition is used to characterize the contaminants, the presence of hazardous waste defines the location as a "hazardous wastesite." Once we get to a location being defined as a "hazardous wastesite," or for 29 CFR 1910.120 purposes a "uncontrolled hazardous wastesite," we've arrived at a juncture where the city solicitors need to get very busy. Unfortunately the Federal effort to introduce municipalities into the clean up equation seemed to not emphasize the "systems" aspects of the involvement, e.g., OSHA requirements, liability implications, local training needs of municipal employees, public health impacts, forecasting stakeholder interests based on race, class, and gender etc. All of these questions and issues, and others I'm sure, arise as a result of taking a systemic orientation toward brownfields defined as hazardous wastesites. Otherwise there's no discursive example of a brownfield; only hazardous wastesites, environmentally contaminated sites, or polluted sites. Once we do our "assessments" we arrive at the historically defined essence of a brownfield.
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