[Fwd: Re: [CPEO-BIF] Ironsides Battery. Fond du Lac County, Wisconsin]

[Lenny Siegel <lennysiegel@gmail.com>]

From: 	Peter B. Meyer <pbmeye02@louisville.edu>


Lenny raises an interesting point, but there's little question in my
mind about the basis for deciding whether or not the reuse of a factory
by another industrial user constitutes a brownfield redevelopment. There
are two factors that probably constitute the minimum requirements in the
federal and state brownfield programs, as far as I can tell:

(1) is the site in any way mitigated or made less environmentally hazardous?

(2) is there a new beneficial use of the site (whether as open or
natural space or serving humans more directly)?

The answer to both questions has to be "YES" for it to be a brownfield
redevelopment.

The Oshkosh site in question qualifies on that standard: (1) the final
sentence of the article notes that a county executive is, "... happy the
site is cleaned up ..." and we have no evidence to suggest it has not
been mitigated to the modern industrial use standard under a RBCA
logic, and (2) the site is back in use and on the tax rolls for the
first time since 1991.

Whether this is a sustainable or environmentally beneficial re-use of a
brownfield is not the question Lenny raised, nor one my reading answers.
Moreover, the minimum criteria currently applied in federal and state
programs generally do not address the long term management of a still
polluted site, the major problem facing all RBCA redevelopments.

Peter

--


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
<lsiegel@cpeo.org>
http://www.cpeo.org

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