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E-M:/ The Brownfields' Achilles Heal??



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Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>
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Some students on the list recently asked about environmental issues
in Michigan....

.....I've always been of the opinion that student environmentalists
ought to "think big".....don't just do a term paper....do something
that will change something...cause a big reaction....set forth
crucial issue and policy research that others can use and act
upon.....TAKE ISSUE LEADERSHIP!!

That is the way we did it in the good old days back
in the 70's.......

.....So here is a suggestion.....

I don't know much about the specific MDEQ particulars
of this current issue but I'd suggest it is a
sleeper and potentially a very important public health and
environmental issue......it is the matter of indoor air pollution
in residential and commercial buildings built upon so-called
"remediated brownfields"

Under the Engler/Harding cabal, what was once the toughest
law requiring responsibility for cleaning up contaminated lands
has been largely gelded at the behest of banks,  insurance companies,
land developers, potentially responsible parties
and urban mayors (mostly Democrats).    At the same time, there
have been moves to relax some of the previously more stringent
soil contamination and remediation guidelines.   There have even
been some rumblings about the state relaxing such guidelines for
some very toxic materials.

In any event, apparently the MDEQ Environmental Response Division
has drafted some kind of policy concerning indoor air contamination
problems that result, or are likely to result, when constructing buildings
on certain brownfield and cleanup sites.   I've not read this document,
but it probably addresses such matters as the potential for gasoline
and other solvent vapors to invade indoor building spaces.

Concern about indoor air pollution....as the potential "achilles heal" of
brownfield policies that allow substantial contamination to remain onsite
and writing off groundwater supplies when no use is made of them....
might lead an agency to restrict such construction or to require more
cleanup and remediation.

Now comes John Engler who has apparently convened a panel of
the Michigan Environmental Sciences Board to evaluate the MDEQ
indoor air policy and consider "alternatives."    Here is some information 
about their next meeting
from the current issue of the MDEQ calendar:

FEBRUARY 2, 2000
  8:30 a.m. - 12:00 p.m.
MEETING OF THE MICHIGAN ENVIRONMENTAL SCIENCE BOARD, INDOOR
AIR INHALATION PANEL at the Courtyard by Marriott, 7799
Conference Center Drive, Brighton, Michigan 48114. Information
Contact: Keith G. Harrison, Michigan Environmental Science Board,
517-373-4960, or E-mail at mesb@state.mi.us

How much would you like to bet that this is happening because some
large Detroit, Lansing or Grand Rapids law firm and their clients got
stung by something MDEQ did with this policy???   It is simply beyond
belief that Engler would do something like this as a result of citizen
and environmental concerns.

The petroleum and gasoline marketing industry (one of Engler's favorites),
the liquid hazardous waste recyclers, the specialty chemical and petrochemical
industries and selected others (along with their $250/hour lawyers) would have
the greatest stake in weakening requirements for comprehensive groundwater
contamination cleanup.

Engler has been mouthing off to the National Governors Association
about his brownfield policies being such unqualified successes so my
guess (and this is all strictly speculation) is that this is the method by
which "alternatives" will be considered that will allow more risk for
indoor air dwellers in brownfields than present policies will allow by
allowing less cleanup to happen and still have it be "acceptable" under
remediation rules.

Note that indoor air quality is still  largely an  unregulated area.....current
occupational health regulations do not effectively protect indoor dwellers 
and are not intended to
address these kinds of problems.

Consider that exposure of structures to intrusions of gasoline vapors
(which contain benzene) in soil contamination may have the potential
to cause elevated cancer risk in those exposed to indoor air.  Other
carcinogenic and toxic solvents will also be issues.    Extended exposure
to these kind of materials is also a known cause of neurotoxicity in
exposed individuals.

In any event, lets have some of those students learn about what has
gone on and what is being considered and to revisit the "how clean
is clean" debates before decisions get made that "dirty" is "clean"....
Write a briefing memo for the Sierra Club, the Lung Association and the 
Michigan
Environmental Council......make a difference!!    Develop some
position papers.   Outline the remediation and cleanup issues.   Find out
who is behind the move to consider "alternatives".... Engler/Harding
"speak" for figuring out how to deregulate business while exposing you,
the public, to more toxic pollution......this is the real agenda of
"compassionate conservatism" like they practice in petroleum-industry-
influenced-saturated places like Lansing and George Bush's Texas.

And so it goes....


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Alex J. Sagady & Associates        Email:  ajs@sagady.com

Environmental Enforcement, Permits/Technical Review, Public Policy and
Communications on Air, Water and Waste Issues
and Community Environmental Protection

PO Box 39  East Lansing, MI  48826-0039
(517) 332-6971 (voice); (517) 332-8987 (fax)
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