2007 CPEO Brownfields List Archive

From: "Joe Schilling" <jms33@vt.edu>
Date: 2 Jul 2007 18:58:23 -0000
Reply: cpeo-brownfields
Subject: RE: [CPEO-BIF] Re: Brownfields Digest, Vol 34, Issue 25
 
Peter of course makes a very compelling case for keeping BFs incentives
"pure." He also offers many good points about making sure that BFs
incentives should go towards properties that really need them in order to
return these properties back into commerce.

My perspective is probably a bit more futuristic.  I start from the
perspective that BFs redevelopment, somewhat by accident, perhaps by design,
has probably become this country's e most successful community
revitalization policy in the last forty years. And it is somewhat ironic
that it happened at EPA as opposed to HUD or the typical revitalization
policy silo.  Given that it is unlikely anytime soon for the federal
government to create a holistic and comprehensive community revitalization
initiative is there a way we can build on the success of BFs redevelopment
and tweak a few BFs policies here and there so that it can accomplish more
area-wide revitalization.  

So, yes, I'm advocating a policy direction that would create "spill" over
benefits from these BFs policies/projects so that a community could, if it
wants, leverage, apply, use certain BFs incentives to redevelop true BFs AND
adjacent/nearby vacant and abandoned properties (not functionally
obsolescent) and thereby accomplish significant community revitalization
goals instead of an isolated BFs project here and there.  Such an area wide
approach could also address the properties where the redevelopment market is
non existent, perhaps transforming the properties into green infrastructure?

However, I recognize there are certain dangers of such a direction.  Some
may contend that it's politically risky to extend BFs programs beyond their
intended scope--obviously, I'm not advocating doing so without proper
legislative reforms--that a backlash like eminent domain could arise.  As
Michigan illustrates, even if you make the legislative changes to encompass
a broader definition of BFs you need to back that up with the funding and
capacity to implement. 

My point is we should consider how to leverage the benefits of existing BFs
incentives and policies to serve as the catalyst for community-scale
revitalization.

JMS



 

-----Original Message-----
From: brownfields-bounces@list.cpeo.org
[mailto:brownfields-bounces@list.cpeo.org] On Behalf Of Peter B Meyer
Sent: Monday, July 02, 2007 7:40 AM
To: brownfields@list.cpeo.org
Subject: [CPEO-BIF] Re: Brownfields Digest, Vol 34, Issue 25

I'm going to jump in on the Michigan issue since it relates to the whole
issue of targeting subsidies, a topic of a great deal of interest to me.

There are a lot of economic and social issues facing depressed cities and
communities in addition to contamination, including abandonment and
underutilization. Such settings generally need outside help if they are to
regenerate. This is a fact that I doubt is controversial.

There also are brownfields in real estate markets that are so hot that there
is little, if any, need to provide any public support (other than regulatory
clarity and consistency) to get them remediated and reused. The New York
state brownfields program has been criticized for wasting money on such
settings, and is undergoing some revisions, for that and other reasons (as
has been evidenced in earlier postings to this liostserv).

It is not clear to me whether or not the Michigan program has similar
failings, though I suspect it is comparably flawed.  What IS clear from
earlier listserv postings is that (a) the state fund is virtually depleted,
(b) it was spent in part (wasted) on grants that probably should have been
loans (Evans Paull's last comment) -- and might even have been wasted in
settings in which no support was needed to overcome non-contamination
barriers to incentives, and (c) the case that started this discussion
involved "functionally obsolete" student housing -- for which there was
demand, since the students are still ther and it is just being replaced, and
which was not clearly abandoned nor in a depressed real estate market.

The specific student housing case in Mount Pleasant, in fact, does not
appear to qualify for support on either Evans' or Joe Schilling's criteria
for aid; it also was not a site with contamination problems, at least not as
described.

But the key question is whether BROWNFIELD funds should be used for
abandoned or underutilized properties that do not have a contamination
problem.  Given the legal constraints under which EPA operates, federal
funds should not be used for such projects -- and there is a risk to any
state that wastes its brownfield monies on such projects that the funds
involved include some federally-funded state records keeping or other
program management support under the 2002 Act's funding to states, if not
direct transfers of federal subsidy dollars. (I do not discount the
possibility that, despite the language of the 2002 Brownfields Act, many of
the applications for grants are actually for projects of the type that Joe
and Evans would approve ... and I suspect that some have been so well
pitched as brownfields in need that they have gotten funds when the key site
problems were not environmental, despite the best proposal review efforts of
the Office of Brownfields Cleanup and Redevelopment.)

Like it or not, the funds for what I would characterize as neighborhood or
urban regeneration are stovepiped legislatively to different functions.
Monies appropriated in a stovepipe designated for any one function (such as
dealing with brownfields) that get spent on other problems (such as
functional obsolescence of buildings, infrastructure or the like) deplete
the dollars available for the function for which they were appropriated. 

Larry Schnapf's desciption of the Petoskey Pointe project in Michigan
underscores this argument. The developer will, apparently, end up with $4.5
million in tax credits, plus $450,000 for remediation cost reimbursement.
The project will produce 115 jobs, it is true, but the subsidy for each of
those jobs will be in excess of $43,000.  The subsidy may or may not be
needed to "create" those jobs -- and, of course, the claimed "new" jobs may
simply be relocating from elsewhere. However, the real issue is what
cleanups of dangerous sites with heavy contamination problems the $4.5
million in tax credits could have supported and will not continue to expose
people and ecosystems until job creation funds are diverted to brownfields.

I would advise anyone hoping for such an unlikely event not to hold his or
her breath -- especially since the brownfield tax credits in Michigan, as is
the case with brownfield funds in many other states,  are allocated to
projects by the Michigan Economic Development Corporation.  That's Economic,
not Environmental development ...

The "novel definition" in Michigan thus tends to deprive true brownfield
properties with real or perceived contamination of what we all know to be
very limited funding.

Given this conclusion, I wonder if Joe and Evans might want to reconsider
their support for it. I know I do not want to see brownfield funds diverted
in this manner.

Peter 

Peter B. Meyer
Professor Emeritus of Urban Policy and Economics
Director, Center for Environmental Policy & Management
University of Louisville
WEB:  <http://cepm.louisville.edu>
- - - - -
Director of Applied Research
Center for Public Leadership and Public  Affairs
Northern Kentucky University
- - - - - - 
3205 Huntersridge Lane
Taylor Mill, KY 41015
502-45-3240 (cell)

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