2003 CPEO Brownfields List Archive

From: LSchnapf@aol.com
Date: 30 Oct 2003 18:25:36 -0000
Reply: cpeo-brownfields
Subject: Re: [CPEO-BIF] Report from the All Appropriate Inquiry October meeting
 
While I agree with Peter's comments about the record reviews, I think there needs to be more experienced persons than just a "stamp" by a consultant engineer. In many cases, it is just a rubber stamp by someone who is not really familar with the nuances of the site.

There's lots of judgement calls that need to be made as to whether an upgradient hit poses a risk to a site, whether sufficient info on historical uses had been achieved, etc. There ate just too many of the "commodity-style" firms just do the absolute minimum and may users of these reports including non-environmental lawyers just do not have the sophistication to recognize a bad report from a good report. 

If the AAI will be deferring to professional judgement in many cases, then I feel strongly that there must be a high competency threshold for those individuals who are making those decisions. 

Larry Schnapf
55 E.87th Street #8B/8C
New York, NY 10128
212-996-5395 phone
212-593-5955 fax
www.environmental-law.net website

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