RE: [CPEO-BIF] Re: Re-Working the Thinking on Brownfields Subsidies

["Ignacio Dayrit" <idayrit@ci.emeryville.ca.us>]

As I have not seen anybody from the local government, to which most of the monitoring duties will fall upon, I need to chime in. 

This exchange is very erudite, scholarly, etc.  To put into perspective, one has to consider who is giving and monitoring the subsidy.  If, at the state or federal level, perhaps you can go into all these acrobatics y'all discuss. However, at the local level, for most municipalities, any type of monitoring, however appropriate, is unrealistic.  Heck, local governments (and most states) have not even figured out ICs yet.  Even as to the EPA BF grants, performance measures/reporting has been a challenge.  EPA has tried to simplify and many localities still find it hard to comply.  To imply that most locals will be able to collect sufficient evidence (data, info, etc.) to make a case for a refund (for nonperformance) is unrealistic.

Subsidies related to BF should certainly try to equalize the comparative disadvantage vis-à-vis a clean site, given the same circumstances.  Any additional incentives for job creation, smart growth, etc. should be accounted for separately.  

Also, the thread we've all been following seems to assume that the incentives come from one pot of money.  Often, they don't - cities cobble grants and incentives from various sources to make projects work.  How then do you separate the performance from the incentive?


Ignacio Dayrit
Emeryville, CA

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