Comments on: Cleanups at Former Auto Sector Sites

By: Marian Feinberg of For A Better Bronx

Marian Feinberg of For A Better Bronx — Fri, 05 Feb 2010 19:30:37 +0000

While retailers and manufacturers may be closing, it is very possible that there may be an increase of auto and auto body repair shops, as well as what we call “chop shops” as people try to hold on and keep cars running as long as possible and where dire economic situations may increase car theft. This kind of business contributes alot to community toxicity, with solvents, paints, heavy metals etc. In the South Bronx we have many such businesses already and would welcome EPA support to work with such local businesses to help them “green” as well as to do investigation into contamination, not only of air, but also soil and perhaps water from runoff, and how these small (but multiple) sources of contamination in concentrated areas can be cleaned up.

By: Ron Smedley of Dpt. of Natural Resources and Environment

Ron Smedley of Dpt. of Natural Resources and Environment — Thu, 04 Feb 2010 21:17:44 +0000

First, a list of the properties that have been shut down or that are planned to be shut down or abandoned, the list would include the major environmental concerns at these sites, and who is going to pay for the assessments and cleanups and provide a reasonable timeline for the sites to be assessed, cleaned up, and available for sale to new purchasers. The list should be on the EPA website, or the holding companies should develop their own web sites with this information. For all other automotive related sites, the EPA should refer to state environmental programs which likely will have information about USTs or LIW/SQ generators.

By: John W. Schweizer, P.E. of T3W Business Solutions, Inc.

John W. Schweizer, P.E. of T3W Business Solutions, Inc. — Wed, 03 Feb 2010 19:17:39 +0000

In my view, simple case histories of plant closures, decontamination, remediation and redevelopment or re-use would be helpful to inform the publid about the environmental impacts involved and the means to correct or mitigate them.
Similarly, many dealerships have closed over the years, and the sites have gone through environmental due diligence and been redeveloped. A few typical scenarios based on real-world examples for the reuse of dealership sites, with and without maintenance departments, would help inform the public.

By: Chris Harrell of City of Indianapolis Brownfield Redevelopment Program

Chris Harrell of City of Indianapolis Brownfield Redevelopment Program — Mon, 01 Feb 2010 21:12:17 +0000

AA Mathy Stanislaus & OSWER:

Thank you for creating this vehicle to provide comments. I plan to formalize my most pertinent comments and thoughts related at your listening session in Indianapolis, but this opportunity to provide input is appreciated.

A) Is it possible that EPA Administration Officials arrange a meeting with DOJ and Dept. of Treasury where I could join as a municipal voice to encourage DOJ / DOT to consider allocating 20% of GM ($1.2B fund they have from bankruptcy not sufficient) & Chrysler tax payer loan repayment funds directly toward assessment, demolition, remediation, site preparation, and carrying costs for jettisoned/abandoned GM & Chrysler sites. EPA could administer these funds for the unmet costs of GM site reuse prep, as well as Chrysler reuse prep. to remove a significant portion of the burden from municipalities witnessed by these market failures. I can outline this better in a formal letter, but if removing these sites from Chrysler and GM bankruptcy balance sheets was required for their rebirth, then allowing contamination of those sites to rest solely on shoulders of local communities rather than the companies that contributed is patently unfair. This option could help balance the equation.

B) In the context of both Auto Sector sites, as well as vacant / abandoned brownfield sites in general, can US EPA please work to create concrete liability protections for municipalities AND not for profit entities AS WELL AS new Low Profit social entrepreneurship entities (L3Cs) that acquire vacant and abandoned brownfield sites for redevelopment purposes. With the re authorization of the EPA Brownfields Program, the time is ripe for this action. This key policy question of full and firm protection for municipalities, not for profits, and now L3Cs needs to be addressed to assist in anti-sprawl and smart growth redevelopment practices nationwide.

C) Can EPA assist in communities gaining address and or Parcel # / inventory data of all dealerships with which Chrysler and GM previously had dealer arrangements? This would be especially helpful in terms of identifying maintenance facility brownfield sites that may be underutilized or now abandoned in urban core areas, and suburban communities alike.

Lastly, I want to ensure funds available for GM sites now being liquidated via bankruptcy by Motors Liquidation Corp. ($1.2B from bankruptcy) will provide some for ‘carrying costs’ for a reasonable amount of time for municipalities to get the sites back to market after assessment, demolition, remediation, and site prep is complete. Please do not forget this important activity for which municipalities also do not have funds.

Best regards,

Chris Harrell

charrell@indy.gov

By: Chris Cady of Missouri DNR Brownfields Program

Chris Cady of Missouri DNR Brownfields Program — Mon, 01 Feb 2010 20:36:11 +0000

One thing I can think of right off is to draw distinctions between issues addressed under RCRA vs. brownfields. This can get a little complicated with a plant that has been operating post-RCRA and just shut down, but was in operation for years or decades prior, and may have historical environmental issues that may or may not be fully identified, characterized or remediated prior to sale to a redeveloper. The public is not always knowledgeable about the regulatory subtleties, and this can lead to negative some reactions.

I like the idea of this forum, and will be watching!