Breath of Clarity

Discussion Post: Superfund List

The overwhelming 1,336 locations on the National Priorities List (NPL) are 88% private sites while only 12% are federal facilities. Theoretically, the report does well at declaring the EPA as a leader to provide certainty to American families by efficiently generating and facilitating private investment. Designating the agency lead definitely does address the lack of clarity in the case of multiple government agencies working on a single site which we saw as a reason for delay in the RCRA Corrective Action profiles. While the report does include a general plan to “reduce oversight cost for PRPs that perform timely, high quality work,” the key missing element is creating specific incentives for the outside parties to join and take action quickly. Delegating responsibility to groups who are not pressured to shorten the general NPL, but rather instead are motivated to remediate one single site, ensures prompt action and quality is not going to be compromised. A private company can be motivated to cleanup a site in order to bring independent financial gain or improve its public image.

At the birth of residential solar panel system installation, the only way for homeowners to buy the equipment was to dish out thousands of cash dollars and wait 10 years to see a return on investment. Even with financing programs now out there, many industry professionals still advise homeowners to pay for it outright to dodge interest rates. It brings into question the equivalent of interest rates we see in the loss a company endures from opting to do the minimal environmental cleanup instead of focusing on potential reuse gains in the long run. The return on investment potential of reusing these lands is astounding and it’s great to see the report recognizes the benefit.

It’s inefficient to focus on 20 sites that have the most reuse potential if PRPs are not motivated to cleanup a site to a standard sufficient for redevelopment. The report needs to focus on how to show a company the site’s redevelopment value and integrate the reuse needs into cleanup activities. The Glen is a perfect example of fulfilling a major report pillar in that its “land that was returned back to the local community so they can enjoy it”. Investors gathered together to understand the town needed more housing, as well as restaurants and artistic entertainment. Now that the services are in place, people are proud to hear about its history and frequently attend the site. Creating portfolios of these success stories and making them visible to every environmental cleanup’s key financial players is crucial. I foresee taking the extra step to formally identify reuse needs saves time in the long run because it provides companies with a larger vision that propels diligence in their cleanup completion. The report mentions a version of this in its goal of “entering into site-specific agreements that define the responsibilities and liabilities of a third party investor”. Rather than seeing it as responsibilities and liabilities that entail some sort of sacrifice, it needs to be seen as a pristine opportunity to build a business. This collaboration on the project is a way to build positive relationships with key stakeholders, government agencies and corporations. The need for maintaining these partnerships is going to be a reoccurring challenge unless motivation for the annual cleanups is clear.

Question for the group: How else besides publicizing site specific fact sheets can we engage communities in identifying cleanup and reuse opportunities?

I do commend the EPA for creating the 30-day deadline for the task force to complete its mission, and the already outlined actions are all planned to be completed within the year. Since the recommendations can be started without any legislative action, it doesn’t face the delay in being debated between the house and senate committees. Speeding up the dispute resolution process is even a major goal the report lists even at the actual Federal Facilities and private sites. I was surprised the report also mentions utilizing enforcement authorities to move the processes along. While its difficult to spell out specific disciplinary measures for not fulfilling the report’s plan when there are so many agencies involved, some consequences need to be in place so American families can be certain the values are actually going to be carried into action.