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Industry Watch

Starbucks a Catalyst?:
Just wanted to tell you I really enjoyed your “Golden Icon Turns Green” publisher’s letter this morning. Sitting down to a cup of coffee (unfortunately not Starbucks), I read the opening article of the December issue with a smile and a note to myself on how well you hit the nail.An operation like Starbucks says something positive about the community/neighborhood where it is found and is a catalyst that attracts other businesses. Good job.

As a catalyst for brownfield redevelopment Starbucks isn’t much help. They are not looking to go onto brownfield properties primarily because brownfield properties are not generally in high foot-traffic areas.
But, if there is a Starbucks in the neighborhood it does imply a neighborhood in transition and moving in a positive direction, which may then attract other developers who will look to the brownfield property as a place to put offices or townhouses.
By the way, we do have Starbucks in Michigan.
Bruce Moore, Michigan Department of Environmental Quality, Lansing, Mich.

You Can Get Coffee in Ohio
A Starbucks outlet has been located across the street from our environmental consulting company since Spring 2004. We have the demographics. We fit the siting model.
You are right, ”they are creative in building locations and don’t use a cookie-cutter approach.” The Starbucks took over an old gasoline station that had been closed for a few years. The vacant gas station had been unused while undergoing environmental remediation. They retrofitted the old gas station building to their requirements.
Henry Fahnenbruck, KU Resources, Inc., Akron, Ohio

Starbucks Concept Solid
I really liked the article on Starbucks as a leading economic indicator. At first I thought, “cute idea,” but then I realized that it’s very solid from an economic perspective.
I think that franchises and multi-location retailers like Starbucks are over-rated in terms of their ability to predict success, but they’re quite often successful.
Carl Friesen, Global Reach Communications, Mississauga, Ont.

RESPONSE TO STATE PROGRAMS THAT WORK

Michigan Left Out
I took great pleasure in reading your December 2004 issue, but I have to admit something was missing. In reading my friend Charlie Bartsch’s article, “State Brownfield Programs That Work,” I was quite surprised that Michigan was left out.
Hey, Charlie, what gives? Since 1995, when Michigan’s legislature revamped our liability structure, over 7,876 contaminated properties have changed hands. This has resulted in the reuse and redevelopment of all of these properties.
In addition, Michigan has an unmatched, very successful brownfield grant and loan program, funding dozens of substantial projects every year. On top of that, our brownfield redevelopment financing act has provided significant tax incentives since 1996.
Tax increment financing pays for eligible environmental costs while the Michigan Economic Development Corporation provides single business tax credits to qualified developers. Michigan’s progressive brownfield redevelopment atmosphere is second to none and our programs work.
Thanks, Charlie, for allowing me to put my two cents worth in. Next time please don’t forget us.
Brian D. Eggers, AKT Peerless Environmental Services, Saginaw, Mich.

MRESPONSE TO SOIL VAPOR INTRUSTION: A VOLITILE ISSUE
Vapor Intrusion an Important Issue
In response to your article, “Soil Vapor Intrusion: A Volatile Issue” (December 2004), communities impacted by vapor intrusion want regulatory and health agencies to err on the side of protection — particularly for young children —when setting health-based exposure standards for volatile compounds, such as trichloroethylene (TCE), because it’s not practical to obtain an alternate air supply in our homes and neighborhoods.
However, it’s still possible to minimize response costs by thoughtfully applying those standards.
It’s important to develop a comprehensive conceptual site model that considers all sources, pathways and receptors. On the one hand, it should consider how to eliminate releases of volatile products from local industries, groundwater treatment systems and even household products.
On the other hand, it should address the low-level toxic cloud that often surrounds vapor intrusion sites. Calling that cloud “background” doesn’t wash, since TCE and other vapor pollutants don't occur naturally. Subsurface contamination finds a way to the surface, exposing large numbers of people outdoors as well as indoors.
Though venting systems may still be necessary where indoor air pollutant readings are high, the solution to vapor intrusion is accelerated cleanup.
Fortunately, many innovative technologies that destroy contamination in situ have become cost-competitive with the long, slow process of pump and treat.
Lenny Siegel, Center for Public Environmental Oversight, Mountain View, Calif.

RESPONSE TO POINT/COUNTERPOINT: ALL APPROPRIATE INQUIRY
AAI Needs more Clarification
The U.S. EPA should find the comments made by attorneys Lee Hoffman and Michael Carvalho in the December 2004 issue of Brownfield News about EPA’s proposed “All Appropriate Inquiry” (AAI) regulations very useful. I hope that EPA will respond with clarity that the concerns stated by Messrs. Hoffman and Carvalho should not materialize into the problems about which they have speculated.
I represented the National Association of Industrial and Office Properties (NAIOP) as a participant on the 25-member stakeholder group convened by EPA under the Federal Advisory Committee Act (FACA) to negotiate the proposed regulation. I also participated in the panel discussion at EPA’s Brownfields 2004 Conference referred to by Mr. Hoffman and have a somewhat different view of that discussion.
The panel members differed not in their understanding of the meaning of the proposed regulation, as suggested by Mr. Hoffman, but in the practical effect the regulation would have on contaminated property transactions. In short, a regulation that changes the status quo — especially one based in part on arguably superfluous and anachronistic statutory dictates — will never meet everyone’s satisfaction. In the long run, however, the proposed regulation deserves the support of the regulated community.
Nonetheless, many of the concerns expressed by Messrs. Hoffman and Carvalho, and others who have voiced criticism, reflect, to a greater or lesser degree, arguments NAIOP and our real estate colleagues made in eight months of deliberations. Although the current preamble does address and alleviate many of these concerns, I would welcome further clarification from EPA in its final publication of the regulation to dispel these concerns.
Barry J. Trilling, Esq., Wiggin and Dana LLP, Stamford, Conn.
Barry Trilling has more to say on AAI. A lot more. Read his full-length original letter to the editor.

GENERAL FEEDBACK

Magazine Looking Good
Just a quick note to tell you the December, 2004 issue of Brownfield News looked great! The changes you made were very recognizable and the publication really looked nice.
Kristi Grigsby, Neighborhood America, Naples, Fla.

Editor’s Response:
I’m glad you noticed the changes we have been making. I hope you like the new look of Brownfield News even better. Please keep your letters coming, everyone — we love to get the feedback and will share as many letters as we can fit in each issue with our readers.

rachels@brownfieldnews.com

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