|From:||Lenny Siegel <firstname.lastname@example.org>|
|Date:||Fri, 24 Apr 2009 06:48:57 -0700 (PDT)|
|Subject:||Re: [CPEO-BIF] Gowanus Canal, Brooklyn, New York listing|
I believe the Times article about the proposed Superfund listing of the
Gowanus Canal raises a key issue about the future of environmental
cleanup, and I would urge members of this list to respond to my comments.
In my "Brownfields 101" presentations, I describe the two basic models of cleanup: Superfund, in which remediation is funded by responsible parties or the government, and Brownfields, in which cleanup is funded from the income generated by the future use. Both have their place.
I - and most of the community activists with which I work - have been discouraged by the trend, over the last decade, to address Superfund-caliber sites as Brownfields. When sites that pose the greatest threat to public health and the environment are treated as Brownfields, there is a tendency to leave contamination in place. While usually this provides short-term protection, it may lead to unacceptable risks in the long run.
I assume, based upon the findings of both the New York Department of Conservation and U.S. EPA Region 2, that the Gowanus Canal is indeed a Superfund-caliber site. The city of New York and the developers it is working with claim that placing the site on the Superfund National Priorities List (NPL) will make it difficult to develop property because of the stigma associated with Superfund.
I believe the opposite. The stigma exists because of the contamination. Unless knowledge of that site is hidden improperly, the act of listing and the associated additional environmental responses may actually reduce the stigma of building on and occupying the property. Sweeping environmental problems under the rug, foundation, or building is likely to create future exposure risks and/or litigation from inadequately protected site occupants.
No doubt adding a site to the NPL creates a hiccough in the process, as new rules and regulators are brought to bear on the site. But if indeed a site, because of the level of contamination, likelihood of pathways, and presence of receptors qualifies for Superfund listing, then the public deserves the protection that Superfund oversight provides.
Lenny -- Lenny Siegel Executive Director, Center for Public Environmental Oversight a project of the Pacific Studies Center 278-A Hope St., Mountain View, CA 94041 Voice: 650/961-8918 or 650/969-1545 Fax: 650/961-8918 <email@example.com> http://www.cpeo.org _______________________________________________ Brownfields mailing list Brownfields@lists.cpeo.org http://lists.cpeo.org/listinfo.cgi/brownfields-cpeo.org
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