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Friday, September 26, 2014
Turning Lemons into Lemonade: Resilience, Smart Growth and Equitable Development on Long Island
Check out EPA's Greening The Apple blog, which reported today on a collaboration between Touro Law Center's Land Use & Sustainable Development Institute and the Long Island Smart Growth and Resiliency Partnership (LISGRP): Turning Lemons into Lemonade: Resilience, Smart Growth and Equitable Development on Long Island | Greening The Apple. LISGRP is partnership of EPA, FEMA, New York State Department of State, Suffolk County, Nassau County and the Metropolitan Transit Authority (MTA) formed shortly after Super Storm Sandy to help Long Island rebuild in a smarter, stronger and more resilient fashion.
Among other projects that focus on the intersection of climate resiliency and smart growth, LISGRP is working with Touro Law Center to place law students with the City of Long Beach to support sustainable rebuilding. Consistent with priorities identified in the City's recently completed NY Rising Community Reconstruction Plan, the City is implementing recommendations from a Global Green Technical Assistance project (funded through a grant from EPA's Building Blocks for Sustainable Communities program) and a New York University study on green infrastructure and storm water management.
Thus, according EPA Greening the Apple bloggers Joe Siegel and Rabi Kieber, LISGRP and its collaborators are "turning lemons into lemonade" in the wake of the devestation of Super Storm Sandy.
...Long Island Smart Growth Resiliency Partnership has turned lemons into lemonade by incorporating not only climate change resilience but smart growth and equitable development into long term planning on Long Island. The groundbreaking work of the Partnership will no doubt serve as a model for other recovery efforts in Region 2 and beyond.
Posted by Professor Sarah J. Adams-Schoen, Director of Touro Law's Land Use & Sustainable Development Law Institute. You can follow the Institute's blog here, and contact Professor Adams-Schoen by email or phone (email@example.com, (631)761-7137).
September 26, 2014 in Beaches, Climate, Coastal Regulation, Community Economic Development, Federal Government, Green Building, Local Government, Planning, Smart Growth, State Government, Sustainability, Zoning | Permalink | Comments (0)
Saturday, September 6, 2014
"Big Box" Costco agrees to cut greenhouse gas refrigerant emissions nationwide
EPA describes this week's settlement between the United States and Costco as indicative of a more aggressive policy by the federal government to use the Clean Air Act to prosecute the largest GHG emitters, including grocery stores -- a continuing shift in federal priorities that will be of interest to state and local government law practitioners and scholars, as well as those of us who focus on the intersection of local land use law and climate change.
In a settlement announced on Wednesday by the DOJ and EPA, Costco agreed to cut its emissions of GHGs from refrigeration equipment at more than half of its stores nationwide. Costco will also pay $335,000 in penalties for CAA violations and improve refrigerant management at 274 stores at an estimated cost of $2 million over the next three years.
Sam Hirsch, acting assistant attorney general for the Justice Department's Environment and Natural Resources Division, responded to the settlement, saying
"Industry needs to lead the way in abandoning harmful chemicals in favor of using and developing greener, environmentally friendly alternatives to protect our health and our climate."
EPA and DOJ announced that the measures required by the settlement are expected to reduce Costco's GHG emissions by the equivalent of approximately 30,000 metric tons of carbon dioxide per year. The GHG at issue in the settlement is actually hydrochlorofluorocarbon (from leaks of the refrigerant R-22), which is a more potent GHG than carbon dioxide.
Some may question whether the settlement requires enough of Costco, the nation's second largest retailer, given annual revenues of over $100 billion (in 2013, as reported by EPA).
The proposed settlement is subject to a 30-day public comment period and final court approval.
Read the proposed settlement and related documents here.
By Professor Sarah J. Adams-Schoen, Director of Touro Law's Land Use & Sustainable Development Institute. You can follow the Institute's blog here, and contact Professor Adams-Schoen by email or phone (email@example.com, (631)761-7137).
September 6, 2014 in Climate, Environmental Law, Federal Government, Sustainability | Permalink | Comments (0)
Wednesday, August 20, 2014
Posting from New Orleans (No. 3) -- Forging Successful Non-Profit Partnerships Following Crisis and Disaster: O.C. Haley Boulevard's Story
This blog post follows-up a pair of August 5th and August 12th New Orleans posts. Although I'm home in Atlanta getting ready to begin the new school year, I'm continuing an observance of Katrina's 9th anniversary by 'walking' O.C. Haley Boulevard and looking at one of the city's emerging post-storm neighborhood revitalization stories.
At the outset of this post, it is important to note that there are many more neighborhood stories that deserved to be told, ranging from stretches of St. Claude, Carrollton, and Claiborne Avenues to Freret and lower Magazine Streets. There are also many neighborhood corridors still struggling to come back all over the city, but particularly neighborhoods lying generally east and a little north of the French Quarter, including the vast area of New Orleans East as well as the Upper Ninth Ward and the Lower Ninth Ward.
As the son of an architect, I'm always ready to begin discussion of any neighborhood transformation by flashing slides of the 'bricks and mortar' improvements. Those are also the improvements that we as lawyers are most directly involved in supporting: the land acquisitions, the tax credit financings, the bridge loans, the condo documents, the parking easements. But to get any neighborhood to the point where it can provide the social and economic buttressing to support significant private market transactions, there's often a foundation of community activism and advocacy. O.C. Haley Boulevard is no exception.
Very rarely is any one individual or organization the sole 'mover' behind a neighborhood's re-emergence. Long before the levees and flood walls breached, non-profit, business owner, and neighborhood advocacy groups were working to lay the groundwork for O.C. Haley Boulevard's resurgence. Carol Bebelle, co-founder of the Ashé Cultural Arts Center, moved the Center onto the Boulevard in 1998 in order to sustain and nurture the stories and traditions of New Orleans' African American community. The Cultural Arts Center's historic building, an adaptive use of a former department store, became a foothold for the Boulevard's resurgence, supporting non-profit office space, exhibit and meeting space, and 29 apartments.
About the same time, O.C. Haley Boulevard Merchants and Business Association gathered local businesses to spearhead creation of a strategic plan for the Boulevard's revitalization.
A couple of years later, in 2000, Café Reconcile opened across the street as an adaptive use of another large historic commercial building, housing a full-service restaurant dedicated to providing culinary training and life skills development to young men and women from the surrounding neighborhoods.
Along the way, the Boulevard attracted key regional community development partners, and led them to call the Boulevard 'home.' These partners included Hope Federal Credit Union (http://www.hopecu.org/) and Good Work Network (http://www.goodworknetwork.org/), both of which concentrate their resources on serving low and moderate income families and developing opportunities for minority and women-owned businesses.
In short, the Boulevard's momentum had already been triggered when Katrina's storm surge filled-up 80 percent of city, leaving the Boulevard and only a handful of other major corridors navigable by car as opposed to boat. (A relatively current map of the businesses that have grown-up on the Boulevard in the last fifteen years is found on the Merchants and Business Association's website, http://ochaleyblvd.org/?page_id=5).
Lawyers – often community development lawyers – figure critically in these first stages of a neighborhood's redevelopment, well before building projects begin 'going vertical.' Lawyers are counseling neighborhood groups and businesses on drafting their articles of incorporation and their bylaws or preparing their Form 1029 to seek IRS 501(c)(3) status. They are helping review applications seeking funding from foundations for planning and predevelopment award monies. They may be advising their clients to seek funds for a market study to help give current and future businesses a sense of where and how they might invest their capital and other resources. Or, they may be advocating at city hall for stricter enforcement of health and safety code violations affecting vacant or abandoned properties. Law students interested in pursuing urban and community development work should gain an appreciation in law school of these critical supporting and counseling roles that lawyers play for community groups.
Earlier this month, I visited with Kathy Laborde, President and CEO of the non-profit Gulf Coast Housing Partnership (GCHP). Laborde, who has worked on the Boulevard for almost two decades, described the factors that convinced her and the neighborhood's stakeholders that they could turn around the Boulevard's fortunes. GCHP has been a main driver of redevelopment on and around the corridor since Katrina. In sharing her thoughts and recollections concerning the Boulevard's rebirth, Laborde described not only the last nine years' key redevelopment projects, but at the same time she highlighted additional pieces of the urban redevelopment 'puzzle' that successful urban and community development lawyers need to appreciate to serve their clients well.
(Photo: Gulf Coast Housing Partnership offices (gray building) at 1610 O.C. Haley Blvd.)
Location is an essential consideration for any urban redevelopment project. Against the essential backdrop of an engaged group of neighborhood stakeholders, Laborde outlined the following factors as critical:
- The O.C. Haley corridor's historic status as the one of the chief commercial centers for the city's African American community;
- The corridor's proximity to New Orleans' Central Business District (separated only by the elevated U.S. 90, The Pontchartrain Expressway);
- The corridor's proximity to St. Charles Avenue, one of nation's great historic streets, which runs just 3 blocks to the corridor's southeast; and
- The presence of historic commercial buildings fronting O.C. Haley Boulevard and stakeholders' initial investment in rehabilitation of those structures.
These four areas of strength formed a sort of superstructure for the corridor's redevelopment; however, by themselves, these four factors were not sufficient to draw significant investment to the corridor. The challenge for GCHP and the corridor's stakeholders was how to connect O.C. Haley's assets to the city's surrounding areas of strength and investment while maintaining the corridor's character. It was at this juncture, nine years ago, Hurricane Katrina unleashed its destructive forces.
Katrina fundamentally altered the way those inside and outside New Orleans viewed the city. To those living in New Orleans, the telltale watermark stains left by the epic flooding clearly distinguished O.C. Haley Boulevard as 'high ground' that did not flood. To those outside New Orleans, particularly local and national foundations and philanthropies, O.C. Haley Boulevard bordered one of the city's toughest neighborhoods with one of its deepest pockets of poverty. Outsiders also appreciated that the Boulevard was surrounded by areas of significant strength, including the city's wealthier Uptown neighborhoods, the Central Business District, St. Charles Avenue, and the former C.J. Peete (Magnolia) development which was a 1930s-era public housing development then-slated to receive millions of dollars in HUD funds for complete redevelopment into the new mixed-income Harmony Oaks community.
Outside funders immediately saw the Boulevard in a new way. It stood out not only as a neighborhood where the private foundations and philanthropic funders saw they could achieve programmatic goals of creating more equitable, inclusive, and prosperous inner-city neighborhoods, but also these private funders were buoyed by the fact that high levels of investment were occurring all around the Boulevard. Further, just as foundations and philanthropies were looking to leverage their investments, so too was the New Orleans Redevelopment Authority (NORA), which was responsible for making decisions about deployment of a tranche of federal disaster block grant monies for commercial corridor investments. It was a 'no brainer' for NORA to join the catalytic investments of the Greater New Orleans Foundation, Kellogg, Rockefeller, Ford, Surdna, and the J.P. Morgan Chase Foundations.
Make no mistake – even with this level of interest, the Boulevard was hardly awash in cash. In a post-Lehman Brothers world, banks had a low temperature for risk, and in post-Katrina New Orleans where the levee and flood control system rebuilding was not yet complete, caution was the rule for commercial lenders. But what the philanthropic and government funding accomplished was to make the development 'math' work for deals dependent on tax credits and tax exempt bonds. A non-profit developer could run a development pro forma that now yielded at least a sliver of a development fee. The challenge for those developers and their clients was to complete successful residential and commercial development projects that would help New Orleanians and visitors alike see O.C. Haley Boulevard as a safe place to live and work. As Laborde explains, this was the "show me stage" of the corridor's redevelopment. Beginning in 2007, this is exactly what the Boulevard's stakeholders began to do.
Over the last seven years, GCHP and the Boulevard's other stakeholders have completed a steady stream of housing, restaurant, office and retail projects. The first pivotal project was GCHP's completion of The Muses, a 263-unit mixed-income apartment community, which opened in 2009. This project brought hundreds of new residents to the Boulevard and helped bridge the three-block real estate market 'canyon' between St. Charles Avenue and the Boulevard.
(The Muses is located a block off of O.C. Haley at 1720 Baronne Street).
The tipping point project may have been GCHP's redevelopment of almost an entire city block between Martin Luther King, Jr., Boulevard, Thalia Street, O.C. Haley, and Rampart Street. GCHP convinced the New Orleans Redevelopment Authority to move its 45 employees from its downtown rented office space to become the anchor tenant of an office building with ground floor commercial space. This office and retail building were funded with New Markets Tax Credits, NORA's investment of $2 Million in disaster Community Development Block Grant (dCDBG) funds, and private financing. The office building, in turn, helped secure financing for an adjacent 75-unit affordable senior housing development.
(Photo: New Orleans Redevelopment Authority office building, 1409 O.C. Haley Blvd.; 75-unit senior housing development can be seen to the right and to the rear of NORA's building.)
Another important project was Café Reconcile's expansion and rehabilitation of its existing restaurant and training space.
(Photo: Café Reconcile restaurant and training facility at 1631 O.C. Haley Blvd.; the recently completed expansion occupies the two-story light tan brick building.)
Café Reconcile's $6.5 Million expansion was funded by private donations, NORA dCDBG funds, and state and federal tax credits.
"Success in community development," Laborde stresses, "is about getting people to follow." And they are doing so on the Boulevard. More projects are just weeks and months from completion, including the adaptive use of an historic school as a grocery store and offices, the renovation of two large retail buildings into the Southern Food and Beverage Museum (SoFAB), including The Museum of the American Cocktail, as well as the first home of the New Orleans Jazz Orchestra (NOJO), including its 360-seat performance venue. The projects soon coming on-line include:
(Photo: the former Myrtle Banks School at 1307 O.C. Haley Blvd., which is being redeveloped by Jonathan Leit of Alembic Community Development.)
The school's $17 million renovation is financed by New Markets Tax Credits, historic tax credits, $1 Million from the City's dCDBG-funded Fresh Food Retailer Initiative, $900k from the New Orleans Redevelopment Authority, and $300k from the Foundation for Louisiana.
(Photo: Currently under construction are (left) New Orleans Jazz Orchestra (NOJO) Market at 1436 O.C. Haley Blvd. and (right) the Southern Food and Beverage Museum (SoFAB) at 1504 O.C. Haley Blvd.)
The NOJO Market and SoFAB redevelopment projects critically anchor two separate O.C. Haley Boulevard blocks where the Boulevard meets Martin Luther King, Jr., Boulevard. NOJO's development is financed by State of Louisiana historic tax credits, State of Louisiana theater, musical, and theatrical production tax credits, $10 Million from Goldman Sachs' Urban Investment Fund, an $800k loan from NORA's commercial revitalization gap loan fund, and a bridge loan from Prudential Insurance Company. NOJO will open in the spring of 2015. A ribbon cutting for the SoFAB redevelopment is set for September 29, 2014.
Next week we will wrap-up our discussion of O.C. Haley and Katrina's 9th anniversary with a discussion of what urban redevelopment professionals are looking for in the attorneys they hire.
John Travis Marshall, Georgia State University College of Law
August 20, 2014 in Affordable Housing, Architecture, Community Economic Development, Development, Downtown, Federal Government, Financial Crisis, Historic Preservation, Housing, HUD, Redevelopment, Teaching | Permalink | Comments (0)
Monday, August 4, 2014
Snapshots from New Orleans' Long-Term Recovery -- Katrina at 9
This August marks the ninth anniversary of Hurricane Katrina's devastating collision with the Gulf Coast. New Orleans, of course, did not suffer the direct hit that submerged and leveled the Mississippi Gulf Coast, but the hurricane's historic tidal surge overwhelmed a poorly maintained and engineered Orleans Parish flood protection system. Lake Pontchartrain's brackish muddy waters poured through gaping holes in flood walls and levees and submerged 80 percent of the city.
The disaster's immediate aftermath has been described in thousands of blogs, maps, documentaries, songs, books, articles, and deeply disturbing pictures that are seared into the collective American consciousness. The shockingly poor government agency response at every level has earned "Katrina" a place not only in the American political lexicon, but also in international discourse, alongside "Waterloo", "Watergate", and "9.11." For the past nine years, however, an equally compelling but far less "photogenic" story of long-term recovery has unfolded – glacially at first, then haltingly, and over the past four years at a steadier pace. The flood waters inundated the city in just hours, but the long-term recovery has proceeded as a kind of community development 'trench warfare', advancing one street and one block at a time.
Nine years later there are still neighborhoods that show only a faint pulse of life amid boarded houses, car-eating potholes, and jungle-like yards. These are particularly the lower income neighborhoods with pre-storm populations that were predominantly African American. These include neighborhoods such as the Upper Ninth Ward and the Lower Ninth Ward. At the same time, the redevelopment slog that has characterized the long-term recovery has been the catalyst for instances of remarkable investment in, and revitalization of, moribund neighborhood commercial corridors.
Many of the law teachers and development practitioners reading this entry have one or more former students or protégés who have sought out opportunities over the past twenty years in New Orleans or Gulfport, Cedar Rapids or Grand Forks, Tuscaloosa or Galveston, or most recently New York City, New Jersey and Detroit to work with federal, state, and local government agencies and, perhaps even more important, with non-profit and philanthropic organizations who often spearhead long-term recovery and revitalization efforts. The next couple of New Orleans dispatches are intended to serve less as a land use travel log than as a discussion of what
happens during a community's long-term recovery as well as the key skills and proficiencies that our students must have in order to contribute to rebuilding cities. It is no coincidence that non-profit and local government executives point to legal capacity and sophistication as critical and also troublesome components of New Orleans' long-term recovery. The refrain not infrequently heard is that 'we lost thousands of dollars' or 'weeks of time' because a developer did not challenge an informal government interpretation of a federal regulation that turned out to be incomplete or based solely on anecdotal experience from a disaster in another jurisdiction. There is no substitute for learning how to read and carefully analyze agreements, local code provisions, or federal regulations.
Over the next few weeks, there will be at least two more dispatches from New Orleans. The first dispatch will be from the Oretha Castle Haley Boulevard ("O.C. Haley"), which begins just a football field's length from the edge of the New Orleans' Central Business District (CBD) and travels southwest towards the Central City neighborhood, which prior to Katrina reported some of the city's highest poverty and crime rates. You can follow along by entering the intersection of Martin Luther King, Jr., Boulevard and O.C. Haley Boulevard into your favorite mapping application.
August 4, 2014 in Community Economic Development, Development, Downtown, Federal Government, Local Government, Redevelopment, State Government | Permalink | Comments (0)
Thursday, June 26, 2014
Whitehouse v. CIR. 5th Circuit Upholds Major Deduction in Conservation Easement Valuation
No one is more surprised than I with how much time I spend reading about tax law these days, but I wanted to alert folks to another case regarding the valuation of historic conservation easements. This time, we are talking about Maison Blanche - a fancy former department store now an even fancier Ritz Carlton on Canal Street in New Orleans.
In 1997, the Whitehouse Hotel Ltd. (owner of the property) donated an historic preservation conservation easement to protect the facade to the Preservation Resource Center. Whitehouse's appraiser estimated the value of the conservation easement at $7.445 million (not $7,445 million as the 5th Circuit opinion mistates). The IRS cried foul and valued the conservation easement at $1.15 million and also dinged Whitehouse for an extra 40% for underpaying by more than 400%.
Unsurprisingly, litigation ensued. Whitehouse v. CIR, 2014 WL 2609866 (5th Cir. 2014), decided on June 11th is the second time the case has made it up to the 5th Circuit. The disputes have generally been battles of appraisals and valuation methods. I am not going to express any opinion about the appraisal methods but thought I'd point out a few things.
What does the conservation easement allow?
There was a big dispute here as to whether the conservation easement actually had any value. One of the appraisers suggested that because the conservation easement would not actually prevent Ritz Carlton from building what it want to build, the value should be zero. The highest and best use of the property is unchanged by the conservation easement. This conclusion turned in part on the language of the conservation easement and whether it actually prohibited the potential building of 60 additional rooms on part of the hotel complex. The Tax Court agreed with the appraiser that the conservation easement did not have such a prohibition. Whitehouse I, 131 T.C. 112 (Tax Ct. 2010). The Fifth Circuit disagreed. Whitehouse II, 615 F.3d 321 (5th Cir. 2010). On remand to the same judge, the Tax Court reviewed Louisiana servitude law and again stated its belief that the conservation easement did not restrict the additional building and should not have value BUT the Tax Court acknowledged that it was bound by the 5th Circuit's precedent and estimated the conservation easement value based on that assumption (coming up with as the 5th Circuit said "merely $1,867,716"). Whitehouse III, 139 T.C. 304 (Tax Ct. 2012).
Undoubtedly feeling that it got a raw deal from an unbiased judge, Whitehouse appealed but the 5th Circuit upheld the Tax Court stating that even though the Tax Court went out of its way to voice its disagreement with the 5th Circuit that was allowed as long as it actually followed the 5th Circuit.
Can you rely on tax professionals' assessments of your conservation easements?
Well, at first blush the answer to this question looks like "no" because the appraiser was so wrong. But the key question to consider for this case is whether Whitehouse's reliance on its appraiser and other professional should protect it from the penalty for gross underpayment (the 400% thing I mention above). There is a reasonable cause exception that allows taxpayers to get out from under this rather steep penalty. This issue is important for people interested in conservation easements because we see over and over again how far apart the private appraisals can be from those the IRS calculates. How much should we penalize landowners for their underpayments made in reliance on qualified professionals? The Tax Court imposed a 40% gross underpayment penalty, holding that Whitehouse had not done enough to demonstrate that it had reasonable cause to believe the appraisal. The court may have been particularly persuaded by the fact that the appraisal of the conservation easement exceeded the price actually paid for the property. The 5th Circuit reversed on this issue because Whitehouse had consulted with more than one appraiser and consulted other tax professionals. The 5th Circuit found this to be adequate.
I am really torn on this one. We want landowners to be able to rely on qualified appraisers and to impose a 40% tax penalty could be particularly painful to small landowners. But there have been repeated examples of bad appraisals around and it seems like there has got to be some type of smell test. Where a conservation easement is valued so much higher than the purchase price of the property, I hesitate too. Of course, I understand that the purchase price doesn't really tell you the value of the property and the value of what an entity like Ritz Carlton can get out of a property, but at the end of the day as a taxpayer, I don't even like the fact that the landowners here got a $1.8 million dollar charitable tax credit to build a big fancy hotel and condo complex that will make them oodles of dollars. Arguing that they lost $1.8 million because they couldn't make it as absolutely big as they might have just leaves a bad taste in my mouth.
June 26, 2014 in Architecture, Caselaw, Conservation Easements, Development, Economic Development, Federal Government, Historic Preservation, Land Trust, Real Estate Transactions | Permalink | Comments (1)
Monday, June 23, 2014
Tax Deductible Exacted Conservation Easements: That's an oxymoron isn't it?
As long-time readers know, I have an obsession with interest in conservation easements. In particular, I have been intrigued with a category I call "exacted conservation easements," which I view as any conservation easements that have been created in exchange for some type of land-use permit or development benefit.
Many conservation easements are donated to land trusts and government entities. Those landowners are then able to seek deductions for charitable contributions on their federal tax returns based on the fair market value of the conservation easement. Of course, calculating the fair market value of a conservation easement may not be a simple task, but we can leave that discussion for another day. Today, I want to talk about the potential for tax deductions on exacted conservation easements.
Exacted conservation easements exist because a landowner is seeking the right to develop or change her land in a way currently restricted by law. For example, where a landowner wants to convert endangered species habitat into a residential development, the landowner often agrees to burden other land with conservation easements in exchange for an incidental take permit. Now, in what I hope is an uncontroversial statement, I often assert that such conservation easements should not garner landowners any charitable tax benefits. Unfortunately, I heard many stories of landowners seeking and obtaining tax deductions for such properties.
In a recent tax court opinion, we see an example from Colorado. In Seventeen Seventy Sherman Street, LLC [SSSS] v. CIR, T.C. Memo 2014-124, the Tax Court examined the deductibility of historic facade and interior conservation easements. SSSS wanted to develop an historic site (the Mosque of the El Jebel Shrine of the Ancient Arabic Order of Nobles of the Mystic Shrine) in Denver into condos. Because the property is a designated landmark, the architect proposed building in the parking lot and preserving the shrine "as leverage to induce the city of Denver to modify the zoning restrictions governing the use and development of the [property,]" which at that time was not zoned for residential development (T.C. Memo at 5-6). SSSS then entered into negotiations with the city's Community Planning and Development Agency regarding changes to the Planned Unit Development (PUD) for the area, the conservation easements, height variance, etc. The Agency asserted that it would not recommend any changes to the PUD or granting of the height variances without the conservation easements.
Hopefully, you see quickly why I label these exacted conservation easements (or I sometimes call them "coerced conservation easements") and why they differ from the vision most folks have of conservation easements protecting the family homestead and helping farmers keep the property in the family. Here, we have a developer with no emotional connection to the property simply making a deal to obtain the development rights that the developer sets as its goal. This doesn't mean that the developer doesn't value the historic, scenic, and cultural benefits of this property. Indeed, a developer may purchase an important or beautiful site exactly because it believes those features are important, BUT we may not have the same ideas of freedom of contract or donative intent involved. We might want to view such conservation easements differently, more critically.
So what kind of tax break should SSSS be able to get here? My initial take on these has always just been zero. The conservation easements were exchanged for a varaince and favorable development measures; they are not donations. But as the Tax Court points out, we may be able to find some instances where some of an exacted conservation easement was done in exchange for a permit or some other benefit, but the value of the restriction actually exceeds the value of the permit. Frankly, while I agree generally with that sentiment, I have trouble picturing where that might occur. How do we calculate that? Without the conservation easements here, we know there would have been no permit. So can we really say that the value of the conservation easements exceeds the value of the permit? If so, are there ways to confine the conservation easement to bring it in line with the value of the permit? They have to be perpetual, so we could only change other characteristics. Suddenly I feel like we are immersed in some Dolan-like analysis of value and proportionality.
The conservation easements in this case were first valued at over $7 million. On its tax forms, SSSS did not indicate that it had received anything of value in exchange for the conveyance of the conservation easements (to Historic Denver). The IRS responded that SSSS had failed to meet some filing and appraisal requirements and asserted that the conservation easements should only be valued at a little over $2 million but claimed that the interior CEs were not deductible at all, leaving the potentially deductible amount at $400,000. Here, the Tax Court did not need to determine the value of the conservation easements or the value of the development benefits SSSS received in exchange for them because SSSS failed to identify that it received consideration for the CEs as required by the Tax Code. The court continued to explain that the exchange sure looked like a quid pro quo one with SSSS agreeing to the CEs (whatever their value) in exchange for the Planning Agency's support (whatever its value).
I am glad to see the IRS taking a careful look at these conservation easements. Generally, I think we should be wary of any conservation easements emerging from development schemes.
June 23, 2014 in Architecture, Caselaw, Conservation Easements, Development, Federal Government, Historic Preservation, Land Trust, Zoning | Permalink | Comments (0)
Tuesday, April 8, 2014
McLaughlin on Perpetual Conservation Easements in the 21st Century
Nancy McLaughlin (Utah) has posted Perpetual Conservation Easements in the 21st Century: What Have We Learned and Where Should We Go from Here?, 2013 Utah L. Rev. 687. Here's the abstract:
April 8, 2014 in Agriculture, Conservation Easements, Environmental Law, Environmentalism, Federal Government, Historic Preservation, Scholarship, Servitudes | Permalink | Comments (0) | TrackBack (0)
Wednesday, April 2, 2014
Will the generous tax deductions for conservation easements stick around?
Potential tax deductions are one of the driving forces behind creation of conservation easements. The exact contours of the tax deduction (how much can you deduct and over how many years can you stretch your donation) has varied over the years. For the past several years, the deductions have been particularly generous.
Under standard law, individuals can deduct the value of the donated property up to 30 percent of their adjusted gross income, and any excess value can be carried forward for 5 years. But in 2006, Congress passed the enhanced landowner incentive. It allows deductions up 50 percent of donors' adjusted gross income and over a 15-year carry-forward period. That incentive ended this past December. The consistent support of this tax deduction by Congress led many to people the enhanced version would be extended without struggle.
Perhaps not. The most recent tax-extension proposal from the Senate Finance Committee does not extend the enhanced tax deduction for conservation easements. Russ Shay at the Land Trust Alliance has hypothesized that the bill drafters may want to change the nature of the deduction, but are still likely to keep the enhanced deduction available to some extent. In particular, this might appear an attractive opportunity to remove deductions for conservation easements over golf courses, something both parties (and the IRS) have indicated their support for. Others suggest that a better approach would be to craft legislation making the enhanced deduction permanent so it does not require periodic extensions.
April 2, 2014 in Conservation Easements, Federal Government, Historic Preservation, Land Trust, Servitudes | Permalink | Comments (1) | TrackBack (0)
Thursday, January 23, 2014
Is a Right-of-Way an Easement?
Turning old railroad lines into parks and bike paths seems like a great idea. When it results in things like NYC's Highline Park who can complain, but not everyone is happy about these rail to trail projects. In fact, it is the subject of a case currently pending before the Supreme Court. (This is not a case under the Rails-to-Trails Act but implicated perhaps thousands of miles of trails that came from rails).
Marvin Brandt is upset about the bike trail built by the Forest Service on an abandoned railway through his land. Brandt argues that the when the railroad abandoned the government-issued right-of-way, the feds did not have the right to create a new right-of-way in the form of the trail.
The tricky issue here is determining what exactly a railroad right-of-way is. When I hear the term ROW, I envision an easement. But as we all know there are some things out there that sound like easements but aren't actually easements. The government argues here that these railroad ROWs were not easements in the traditional sense. However, nor were they fee simple strips of land given to the railroad. Instead they are some third category of property law that no one can quite figure out how to define. A surface defeasible fee subject to a reverter perhaps? Let's break it down.
If it's an easement: The federal government gives the railroad an easement through public land. The common law rules of easements apply. This means that when the railroad abandons the track in the 1980s (or whenever it was), the easement is extinguished and full unencumbered fee simple title goes back to the underlying landowner. This particular parcel is no longer federal land because the Forest Service swapped it with the Brandt family. Traditional run of the mill easement law tells us that the Brandt family (owner of the servient estate) should have this land with no dominant easement holder left around to bug them (or ride bikes through their property). This is what Brandt's attorney argues. Not argued, but hinted at by Justice Sotomayor is that the easement holder was really the US and it temporarily transferred its easement rights to the railroad. Now that the railroad is done, it can keep using the easement for similar (transportation) uses through the Forest Service bike trail.
If it was a patent (i.e., fee simple absolute): The federal government gave the railroad a strip of land and the railroad owned that strip (or spaghetti noodle as the court seemed to like envisioning it). This would mean that the railroad owns the land for any purpose and once it stops using the railroad tracks for trains, it could use them for something else or it could sell them to the underlying landowner (or lose ownership via adverse possession if it stands by and does nothing while the forest service or underlying landowner makes use of the land). No one actually argues that the railroad had an unrestricted fee simple though. Instead, it might be that they had a type of defeasible fee (starting to give you flashbacks of your 1L property class yet?). That's right, the railroad had a fee interest subject to the possibility of reverter. That is, the federal government had a reversionary interest and would get the land back if the railroad stopped using it for railroad purposes.
Now of course, it is not as simple as just reading over the grant to the railroad and figuring out what it said. Instead, we have several wrinkles. For example, there is an 1922 Act (postdating the grant to the railroad) explaining that when the railroad stops using the land for railroad purposes and it reverts to the feds, the feds should first use the land for roads and streets, then consider giving to municipalities, and if that doesn't pan out give the land to neighboring landowners. There is a more recent statute adjusting that order of priority, but these statutes sure make it sound like the US had a reversionary interest. Of course, Justice Scalia pointed out that he doesn't care very much about how a subsequent Congress interpreted the railroad's property right. He is only interest in looking at the 1875 Act enabling grants of ROWs the railroad to try and figure out the property right.
There are some cases muddying the water including a 1942 case interpreting the 1875 Act, concluding that the railroad in question there had not gotten subsurface rights and instead had gotten something akin to an easement.
There is also the tricky part of the land conveyance to the Brandts. The Forest Service swapped some land with Brandt's father back in 1976. While the land conveyance noted the railroad's ROW, it did not mention any reversionary interest. Leading the Brandts (quite reasonably) to believe that the ROW was just a standard run of the mill easement. Can an underlying federal law be in trouble where the forest service neglected to mention it in a land conveyance? Perhaps Brandt's property lawyer should have researched more and tried to determine what was really going on…
The oral argument in this case is fun for land geeks, especially those of us who teach or study property and/or federal lands. The Court seemed particularly interested in figuring out how much lands the feds own and how much has been converted to other uses -- and what the implications of allowing such reversions would be. Several justices pushed the parties to try and explain how many acres or how many landowners were at stake. No one dared to put forth an estimate. I actually laughed out loud when the justices were shocked that the federal government didn't keep good track of its land holdings and dispersals. They are so cute sometimes.
January 23, 2014 in Caselaw, Constitutional Law, Federal Government, Property, Servitudes, Supreme Court, Takings | Permalink | Comments (0) | TrackBack (0)
Tuesday, July 9, 2013
Professor's Corner on Koontz
This month's ABA Real Property "Professors' Corner" teleconference will focus on Koontz, the end-of-Term exactions that is one of the most significant Supreme Court property-rights cases in recent years. (Jessie Owley has discussed it here, and Tim Mulvaney and others have weighed in around the net). This Professor's Corner session should be a good one with several leading scholars participating. Here's the announcement:
Professors' Corner: Wednesday, July 10, 2013: Koontz v. St. John's River Water Management District: A Significant Victory for Property Rights?
Professors' Corner is a monthly free teleconference sponsored by the ABA Real Property, Trust and Estate Law Section's Legal Education and Uniform Laws Group. Each month's call features a panel of law professors who discuss recent cases or issues of interest to real estate practitioners and scholars. Members of the AALS Property Section are invited to participate in the call (as well as to join and become involved in the ABA Real Property, Trust and Estate Law Section).
Wednesday, July 10, 2013
12:30 p.m. Eastern time (11:30 a.m. Central, 9:30 a.m. Pacific). Call is ONE HOUR in length.
Call-in number: 866-646-6488
Passcode: 5577419753
This program will feature a roundtable discussion breaking down the Supreme Court's important June 25 decision in Koontz v. St. John's River Water Management District. If "monetary exactions" have always seemed a little untamed to you, you're not alone. The 5-4 decision in Koontz leaves a lot of room for analysis, and this month's panel is prepared to guide you through it by parsing the decision and the dissent. Our distinguished panel will include Professor Jonathan H. Adler, who is the Johan Verheij Memorial Professor of Law and Director of the Center for Business Law and Regulation at Case Western Reserve University School of Law; John D. Echeverria, Professor of Law at Vermont Law School; and David L. Callies, who is the Benjamin A. Kudo Professor of Law at the University of Hawai'i.
For those that haven't already seen it, here's a link to the opinion:
Please join us Wednesday for this great program!
Matt Festa
July 9, 2013 in Caselaw, Conferences, Conservation Easements, Constitutional Law, Environmental Law, Federal Government, Property Rights, Scholarship, Supreme Court, Sustainability, Takings, Wetlands | Permalink | Comments (0) | TrackBack (0)
Tuesday, June 11, 2013
Blumm & Erickson on Wild Lands Policy in the Twenty-First Century
Michael C. Blumm (Lewis & Clark) and Andrew B. Erickson (Lewis & Clark) have posted Wild Lands Policy in the Twenty-First Century: What a Long, Strange Trip It's Been. The abstract:
The protection of federally owned wild lands, including but not limited to designated wilderness areas, has long been a cardinal element of the American character. For a variety of reasons, designating wild lands for protection under the Wilderness Act has proved difficult, increasingly so in recent years. Thus, attention has focused on undesignated wild lands, that is, unroaded areas managed by the principal federal land managers, the U.S. Forest Service and the Bureau of Land Management (BLM). These areas can benefit from a kind of de facto protected status if they are Forest Service areas that have been inventoried for wilderness suitability and not released to multiple use or are wilderness study areas managed by BLM. In the last two decades, considerable controversy has surrounded roadless areas in both national forests and BLM lands because protecting their wild land characteristics may foreclose development, such as oil and gas leasing or timber harvesting. Recently, the courts have settled longstanding litigation by upholding roadless rule protection in the national forests. But BLM wild land protection has remained more unsettled, as Congress recently rejected a Wild Lands Policy adopted by the Obama Administration. Despite this political setback, current policy is to survey and consider wild lands in all BLM land plans and project approvals. This promised consideration, however, leaves the fate of such lands in the hands of local BLM officials and to the political vicissitudes of future administrations.
This article traces the evolution of federal wild lands policy from its beginnings in the 1920s to the enactment of the Wilderness Act in 1964 and the Federal Land Management and Policy Act in 1976 to the longstanding dispute over the Forest Service's roadless rule to the present controversy over BLM wild lands policy. We maintain that, pending congressional decisions on wilderness status, the best way to protect wild lands in the 21st century is through administrative rule, as in the case of national forest lands. Such protection, however, will require at least acquiescence from Congress, which has not been evident in the case of BLM lands in recent years.
Matt Festa
June 11, 2013 in Environmental Law, Federal Government, History, Scholarship | Permalink | Comments (0) | TrackBack (0)
Monday, June 10, 2013
Ruhl on Ecosystem Services and Federal Public Lands
J.B. Ruhl (Vanderbilt) has posted Ecosystem Services and Federal Public Lands: Start-Up Policy Questions and Research Needs, Duke Environmental Law & Policy Forum, 2010. The abstract:
This Essay, based on a presentation at Duke Law School's 2009 symposium, Next Generation Conservation: The Government's Role in Emerging Ecosystem Service Markets, briefly examines the emerging policy front of ecosystem services and federal public lands and proposes a set of key policy questions, research needs, and options for building on what policy work has been done to date. Part I outlines the basic context for thinking about the role federal public lands might play in the management of ecosystem services and why it is worth considering using the ecosystem services concept in public land policy. Part II proposes several key research paths that must be addressed before federal lands can be effectively managed for ecosystem service flows. Part III bears down on the different roles federal lands might play in promoting or participating in markets for ecosystem services.
Matt Festa
June 10, 2013 in Environmental Law, Federal Government, Scholarship, Sustainability | Permalink | Comments (0) | TrackBack (0)
Monday, May 27, 2013
Memorial Day & Land Use
The U.S. tradition of Memorial Day has a long and complex relationship with land, history, and memory. This post has some thoughts on the subject from last year.
Today was Memorial Day in the US. There are lots of land use issues that we can associate with Memorial Day, which, stripped to its essence, is designed as a day to remember the military members who died in service to the nation. There is the obvious land use issue of cemeteries, and the related legal and cultural norms governing how we memorialize the dead (check out any of the interesting blogposts or scholarship by Al Brophy and Tanya Marsh on cemeteries). It gets even more relevant when we start talking about government-owned national or veterans' cemeteries, and the attendant controversies about First Amendment and other issues. [The photo is from last year's Memorial Day ceremony at Houston National Cemetery, which my daughter attended to honor fallen Marine Lance Corporal Matthew Sauer Medlicott.] Of course, there are always land use and local government issues involved with things like parades and public ceremonies, and in many communities there are specific rules that govern the "summer season" informally commenced on Memorial Day weekend.
Check out the whole post for some info about a couple of little-known and interesting events from the early history of Memorial Day and land use, including what may be the first Memorial Day celebration, by African-Americans in Charleston on the former planters' racecourse, and a U.S. Supreme Court case about eminent domain for historic preservation on Gettysburg National Battlefied.
We hope you had a safe and happy Memorial Day.
Matt Festa
May 27, 2013 in Eminent Domain, Federal Government, Historic Preservation, History, Property, Race, Scholarship, Supreme Court | Permalink | Comments (0) | TrackBack (0)
Thursday, March 7, 2013
Furman Center report on Housing & Superstorm Sandy
The NYU Furman Center has issued a timely report called Sandy's Effects on Housing in New York City. From the announcement by Vicki Been and Ingrid Gould Ellen:
We are pleased to share with you our latest fact brief: Sandy's Effects on Housing in New York City (PDF) Our report is the first independent, comprehensive analysis of the Superstorm's impact on housing in New York City.
The study revealed some surprising insights into the impacts of the Superstorm Sandy. It found that low-income renters were disproportionately impacted by the storm's surge; over half of the victims were renters, 61 percent of whom make less than $60,000 per year, instead of middle-class homeowners. It also exposed the age of the housing stock affected by the surge; 82% of the properties hit by Sandy were built before 1980, before the latest flood maps and building standards were established.
The report also summarizes newly available information about the characteristics of properties in the area in New York City flooded by Sandy's storm surge, as well as demographic characteristics of households that have registered to receive assistance from FEMA. The study was released in partnership with Enterprise Community Partners, who provided a similar analysis on Long Island and New Jersey.
The press release (PDF) and report (PDF) are now available online.
Lots of interesting maps and data in this report, which should be of interest to anyone researching law, land, housing, and disaster planning
Matt Festa
March 7, 2013 in Affordable Housing, Beaches, Coastal Regulation, Community Economic Development, Environmentalism, Federal Government, Housing, Local Government, New York, Property, Redevelopment, Scholarship, Water | Permalink | Comments (0) | TrackBack (0)
Monday, February 25, 2013
Bipartisan Policy Center Housing Commission Report
I am just finished streaming the press conference for the release of the Bipartisan Policy Center's Housing Commision Report. Led by its Co-Chairs, Sens. George Mitchell, Mel Martinez and Kit Bond, as well as former HUD Secretary Henry Cisneros, the Commission is offering a far-reaching set of recommendations regarding the housing finance system, public subsidy for affordable housing development and preservation (particularly in rural areas) and promotion of housing counseling as a vital resource. Even if the Executive Summary is too long for you, I would encourage you to check out a two-page article available on Politico authored by the four co-chairs.
Jim K.
February 25, 2013 in Affordable Housing, Federal Government, HUD, Mortgage Crisis, Mortgages | Permalink | Comments (0) | TrackBack (0)
Wednesday, February 20, 2013
Serkin on The State's Constitutional Obligations to Property Owners
Christopher Serkin (Brooklyn) has posted Affirmative Constitutional Commitments: The State's Obligations to Property Owners, Brigham-Kanner Property Rights Conference Journal, Forthcoming. The abstract:
This Essay, prepared for the 2012 Brigham-Kanner Property Rights Conference, argues that social obligation theories in property generate previously unrecognized obligations on the State. Leading property scholars, like Hanoch Dagan, Greg Alexander, and Eduardo Peñalver, have argued that the institution of property contains affirmative duties to the community as well as negative rights. This Essay argues that those affirmative duties are two-way streets, and that moral bases for social obligations also generate reciprocal obligations on the State to protect property owners. The social obligation theories rely upon a dynamic not static vision of property rights. The community's needs change, the conditions of ownership change, and the appropriate allocation of benefits and burdens within a society changes over time. Therefore, a legal obligation that is justified and permissible at the time it is enacted because it is consistent with moral obligations may become impermissible over time, even if the content of the legal obligation does not change. At the extreme, the State's failure to respond to certain kinds of changes in the world can lead to a regulatory taking.
An interesting and important take on some of the implications of progressive property theory. Especially interesting is Serkin's appreciation for the changing social notions of property over time, and how that challenges static notions of property rights and obligations.
Matt Festa
February 20, 2013 in Conferences, Constitutional Law, Federal Government, History, Property, Property Rights, Property Theory, Scholarship | Permalink | Comments (0) | TrackBack (0)
Wednesday, February 13, 2013
Missouri Law Conference on Promoting Sustainable Energy through Tax Policy
The University of Missouri School of Law is hosting a Symposium on February 22, 2013, called Promoting Sustainable Energy through Tax Policy. Sponsored by the Journal of Environmental and Sustainability Law and the Missouri Tax Law Society, the event will be introduced by Mizzou profs Michelle Arnopol Cecil and our own guest blogger Troy Rule, and features panels with Alexandra Klass (Minnesota), Steve Gaw (The Wind Coalition), Felix Mormann (Miami), Roberta Mann (Oregon), Robert Peroni (Texas), with a keynote by David Weisbach (Chicago). Here's the info and link:
Renewable energy and sustainable development are valuable means of combatting climate change and of reducing the nation's reliance on foreign energy sources. Recognizing the importance of sustainable energy, state and federal policymakers have employed aggressive tax incentive programs to stimulate unprecedented growth in wind energy, solar energy, biomass, green building, and related industries in recent years. Unfortunately, shortfalls in many state budgets and growing concerns about the national debt are now creating pressure for governments to extinguish these tax programs — a move that could bring progress in the nation's fledgling sustainable energy sector to a grinding halt.
This year's Journal of Environmental and Sustainability Law symposium is being sponsored jointly with the University of Missouri Tax Law Society. The symposium explores questions about the long-term role of tax policy as a tool for promoting renewable energy and sustainability in the United States.
Cost and Registration
The symposium is free and open to the public.
Registration is suggested by Friday, February 15.
To register, please contact:
Journal of Environmental and Sustainability Law
University of Missouri School of Law
12E Hulston Hall
Columbia, MO 65211
More Information on 2013 JESL Symposium
Matt Festa
February 13, 2013 in Clean Energy, Climate, Conferences, Environmental Law, Environmentalism, Federal Government, Local Government, Oil & Gas, Politics, Scholarship, State Government, Wind Energy | Permalink | Comments (0) | TrackBack (0)
Tuesday, January 1, 2013
Craig on Treating Offshore Submerged Lands as Public Lands
Robin Kundis Craig (Utah) has posted Treating Offshore Submerged Lands as Public Lands: An Historical Perspective, forthcoming in Public Land & Resources Review (2013). The abstract:
When President Harry Truman proclaimed federal control over the United States's continental shelf in 1945, he did so primarily to secure the energy resources — oil and gas — embedded in those submerged lands. Nevertheless, the mineral wealth of the continental shelf spurred two critical legal battles over their control and disposition: First, whether the federal government had any interest in the first three miles of continental shelf; and second, if so, whether the federal government had authority to regulate the continental shelf under traditional federal public land laws, such as the Minerals Leasing Act. Congress's reactions to federal courts' resolutions of these questions, embodied in 1953 in the Submerged Lands Act and the Outer Continental Shelf Lands Act, continue to provide the foundations for state and federal management of the nation's continental shelf and its energy resources.
Nevertheless, the Outer Continental Shelf's status as federal public lands remains ambiguous. This
Article takes an historical approach to assessing that issue, reviewing the traditional definition of federal "public lands" and the historical context of the public lands issues that arose for the Outer Continental Shelf. It concludes that the Outer Continental Shelf, from a natural resources perspective, qualifies as the newest of the federal public lands, but it also acknowledges that — unlike for many other public lands — federal statutes repeatedly and consistently exclude the states from gaining ownership of those submerged lands.
Matt Festa
January 1, 2013 in Environmental Law, Federal Government, History, Oil & Gas, Property, Scholarship, Water | Permalink | Comments (0) | TrackBack (0)
Saturday, November 17, 2012
Adler on Merrill on "Fear of Fracking"
Yesterday, Case Western Reserve University School of Law hosted a symposium called The Law and Policy of Hydraulic Fracturing: Addressing the Issues of the Natural Gas Boom. As Steve noted on Property Prof, Professor Thomas Merrill (Columbia) was slated to give the keynote. Case Western's Jonathan Adler was part of the event, and he posted an extensive commentary on Merrill's remarks over on the Volokh Conspiracy. Looks like it was a fascinating talk with lots of observations on how to deal with the potential environmental impacts of fracking, and a perhaps counterintuitive suggestion on the possible upside of the gas boom with respect to climate change. But here, I'll focus on some of Merrill's observations on why fracking developed in the U.S., because it may have a lot to do with property law and land use regulation. As Adler describes:
Why did fracking arise in the United States? Contrary to some analysts, Professor Merrill does not believe it is attributable to federally funded research and development. . . .
Professor Merrill also doubts industry structure has much to do with fracking's rise either. . . .
A more likely factor is the way U.S. law treats subsurface rights. The U.S. is something of an outlier in that subsurface minerals are the property of the landowner, and not the government. This results in decentralized ownership and control over subsurface rights facilitates experimentation and innovation in figuring out how to exploit and manage subsurface resources.
Further decentralization, and experimentation, results from the federalist regulatory structure. Different states have different regulatory approaches than others, creating opportunities for further innovation and the opportunity for jurisdictions to learn from one another. The existence of a few jurisdictions that will allow a new technology to be tried provides a laboratory from which others may learn, whereas under a more centralized regulatory structure such innovation is unlikely to get off the ground.
The existence of a relatively open infrastructure network – a pipeline system that is subject to common-carrier rules – also plays a role in facilitating entry into the market. These factors have a common theme: decentralization. Taken together, Merrill suggests, they are the most likely source of fracking's rise in the United States.
Looks like another fascinating event, with participation from a number of land use, environmental, and energy scholars on the subsequent panels. I look forward to the symposium isse in the Case Western Law Review.
Matt Festa
November 17, 2012 in Clean Energy, Climate, Comparative Land Use, Conferences, Environmental Law, Environmentalism, Federal Government, Lectures, Oil & Gas, Property, Property Rights, Scholarship, Water | Permalink | Comments (2) | TrackBack (0)
Friday, October 19, 2012
Johnson on the Economic Crisis, Homeownership, and Race
Marcia Johnson (Texas Southern) has posted Will the Current Economic Crisis Fuel a Return to Racial Policies that Deny Homeownership Opportunity and Wealth to African Americans?, published in The Modern American, Volume 6, Issue 1, Spring 2010. From the introduction:
Perhaps the greatest threat to the continued realization of the American dream is the latest economic crisis rooted in the sub-prime mortgage collapse.12 Some blame the CRA of 1977 for creating a market that they claim provided housing loans to noncreditworthy borrowers – particularly African American families – in the low and moderate income range.13 However, this charge is without direct factual support as the post-CRA period saw a decline in homeownership for African Americans but a mild increase for White homeowners.14 Illegal and fraudulent practices in property appraisals and income reporting directed program benefi ts away from those the program was meant to aid. . . .
This paper is written to examine the potential effect of the market collapse on our nation's homeownership policies. Part I reviews America's historical housing and homeownership policies. Part II considers the expansion of homeownership opportunities to historically non-participating communities, particularly the African American community. Part III reviews the culprits of the economic crash of 2008 and explains why sub-prime borrowers often get blamed. Part IV examines solutions to maintain America's pro-homeownership policy, and Part V concludes that America's homeownership policy should continue to be vigorously pursued with a goal of including African Americans who have long been excluded by government policies and sanctions from building wealth and thereby stabilizing their communities.
Matt Festa
October 19, 2012 in Federal Government, History, Housing, Houston, Race, Real Estate Transactions, Scholarship | Permalink | Comments (0) | TrackBack (0)


text:
How long do unopened bottles of hard liquor/liquers stay drinkable for? And opened?
- s
- Shayna Madel Oct 21, 2007 04:52 PM
I don't drink much hard liquor at all, for no particular reason. But, years ago, I did establish a little bar in my wall unit. I have bottles of scotch, rye and a few other things, unopened, for at least 10 years. My joke is that the 12 year old scotch is now twice that, at least.
Then there's the open vodka, dark rum, light rum, amaretto, frangelico, brandy, grand marnier and framboise that I do drink and cook/bake with, but which I have had for quite awhile also, some maybe a couple of years. How can I tell if this is still usable, even for cooking/baking?
In general, distilled spirits are quite hardy. Unopened bottles of whiskey can last for generations. An unopened ten or 12 year old Scotch or rye should be good as new (assuming it has been handled properly, not subject to extreme temperatures, etc.). Opened, it will still last many years, though you might have a little fading of flavor due to oxidation, which will increase as you use the liquor and the amount of oxygen in the bottle increases.
I assume this would be the same for vodka and rum which are similar distillates.
I'm not sure about the liqueurs, whose flavor may fade faster, once opened, than the other liquors.
re: sku
I have a bottle of Sandeman scotch that I bought a long time ago (maybe 1975) mostly because the bottle was said to be a special very small run by the company for some honored friend (the Don is white???) but which in the end was not given to its intended recipient but sent to commercial channels. So I bought it for the bottle, the box, the tax stamp, etc., and still have all that; I never opened it. But it had a cork stopper, and as a result the angels have apparently gotten most or all of it. So whether the scotch quality lasted or not, apparently one risk is that it will simply disappear.
Rather indefinitely. Beware of the dried and brittle corks. Once opened things change. Oxidation is one issue, but I have also had a few that lsot some more to "the Angel's share." Once bottle that I left a few drams in suffered a lot of evaporation. When I tired it after a while, the brown liquid was no longer a spirit, just a murky, waterly liquid. The alcohol evaporated faster than the water in the whiskey. It was once good stuff. Alas.
re: Captain
So....the opened bottle of gin my new inlaws bought when they stayed with us for our wedding 18 years ago...should I toss that?
re: danna
Trying it is not going to hurt you. If all the alcohol has evaporated, then you won't want it anyway. So long as it has about 5 percent alcohol nothing bad should be able to grow in it. In the "New Complete Joy of Homebrewing" one of the good things made clear is that once beer is fermented, nothing pathenogenic can grow in it. Beer has as little as about 3.5 percent alcohol. So pretty much all of the alcohol needs to evaporate before something (other than the alcohol itself) can grow in it that will make you ill. If the bottle is still near full, it is not bad.
I have been told, and also told otherwise, that distilling beer (as if you were to make your own whiskey) can create a dangerous product, but that is because distilling concentrates some of the by products of yeast, such as the fruity esters one might taste in an ale.
Taste them and see!
If they're true distilled spirits as opposed to say, fortified wine, they should last quite a while, years even. It helps to keep them in a cool, dark place: sunlight and warmth are bad for them, accelerating discoloration, alcohol evaporation, and in sweet liqueurs, crystallization of sugars.
I've also found that cream liqueurs can spoil over time; I had a friend recently sample some Bailey's that's been sitting on my bar for years (where the heck it came from, I have no idea), and it had turned.
re: MC Slim JB
Okay, so scotch, rye, gin, vodka and rum should be okay if not opened? Given that I don't drink the first three and the bottles are sealed, I am going to leave them sealed, since (don't laugh) I would not know what they are supposed to taste like anyway. Basically, I think the rest of what's there is/are liquers and I guess I can peer in the bottles and see if they look separated or there are signs of crystals or settling on the bottoms of the bottles. I think there is an unopened bottle of Baileys there and I will just take a shot and leave it there unopened for now.
By the way, all of this has been stored out of direct sunlight. Never gets that cold in the apartment, but occasionally gets kinda warm, though I do run the a/c all summer.
Guess I need to invite some drinkers over...
re: Shayna Madel
The Bailey's may be bad even if it is unopened. It only has around a two year shelf life unopened, and supposedly six months opened if kept in the fridge.
Personally I think Bailey's is bad right from the start. Has a weird chemical taste and plasticy mouthfeel.
re: Shayna Madel
Bailey's, because it's a cream-based drink, will indeed go bad over time. Straight distillates -- gin, vodka, whisky, etc. -- should be fine over time as long as they are UNopened. Once opened, they begin to s-l-o-w-l-y lose some of their aromatics, and -- if in a warm environment -- some of the alcohol may evaporate.
But it will not be harmful to taste.
My folks don't drink much at all, but keep a full alcohol cupboard for guests. Last Christmas, a guest discovered an unopened bottle of Remy Martin cognac that my late grandfather had bought in the 70s (store label still attached!). It tasted pretty amazing.
I once had an opened bottle of Danziger goldwasser last a decade before I doled out a liqueur glass of it to each guest on Christmas or New Years eve. I've never heard of or had a bottle of booze of any sort spoil. Non fortified wines are the exception, but even fortified wines are pretty stable.
re: Caroline1
Fortified wines generally are more stable than table wines, true, but Porto is not all THAT stable -- many of the aromatics and some of the flavor begins to fade rather quickly. The older the Porto, the more quickly the "damage" is noticed.
With Sherry, the opposite is true -- young Spanish Finos and Manzanillas fade and fall apart rather quickly. An aged Oloroso can last a long time, but isn't indestructible. Aged Madeira, OTOH, may come closest to lasting forever . . . at least it seems to suffer the least "fading" of aromatics once opened.
re: zin1953
Vermouth is another fortified wine that people don't think about as such. It -will- go bad, and your Martini or Manhattan will not taste good, if you leave it out at room temperature. Store it in the fridge and it will last for some time, but still not forever.
re: Captain
I presume it was a bottle of Laphroaig 10 Year Old Scotch, or rather, what you had was a 15 year old bottle of Laphroaig 10 Year Old Scotch. Opening a newly purchased bottle of Laphroaig 10 Year Old Scotch, and tasting it side-by-side with a bottle purchased fifteen years ago, should show very subtle differences -- often more to do with style, rather than any actual differences between the whiskies.
re: zin1953
Interesting coincidence. After a discussion of Iodine aromas in very coastal Scottish malts, I recently checked one I thought I remembered for that: A cask-strength North Port 23-year old (Mitchell Bros. "Rare Malts Selection" bottling, distilled 1971, bought in UK 1996 for 48 pounds sterling). It was the tail end of the bottle. Last sampled a few years ago. It had lost a little subtlety, but also its sharp edges, including any Iodine. But at the same time, had mellowed in proportion. In other words, whatever it lost after being opened 11 years ago (and recorked) was not lamented.
This is exactly typical of my experience with artisanal spirits. They last, with slight loss of detail, a long time, provided you keep them cool and, even more important, well concealed from any neighbors, business partners, or in-laws who consume with equal relish (and in great quantity) industrial whiskey, rare malts hand-carried from overseas, or vanilla extract. (I say this only theoretically of course.)
We just found an unopened bottle of Baily's... it was a gift 6 or 7 Christmas's ago... I heard laughter and the clinking of a butter knife inside glass... I found my wife extracting this thickened substance from the bottle... looked like pudding... there was actually a tiny bit of liquid at the very bottom of the bottle... yep, still smelled \ tasted fine, just weird...
OTOH - We've had some weird experiences (as if that wasn't *weird* enough...) with fresh bottles of tequila (reposado \ 100% agave only) that would change flavors within two weeks of opening... rather disappointing... as one friend has shared, one should always finish a fresh bottle of tequila in one sitting :)... anyone else had this experience of tequila shifting flavors? Storage has always been in room temp \ darkened cabinet...
I have quite a large selection of various alcohols--mostly opened. I am concerned that the extreme heat in my place during the summer months will render all that booze useless. There's half a bottle of Remy Martin XO ($100) that's been sitting for years. I consume a snifter occasionally and haven't noticed any ill taste, but maybe I should try a glass at a hotel bar to compare.
KurtG, your friend finishes a bottle of tequila in one sitting? Unless I had some help or was going on some 'lost weekend' bender, I don't think that would be possible. I enjoy an occasional shot of really good sippin' tequila. Should I just buy the little airplane bottles from now on?
My three experiences:
At a family gathering in the late 60's (before I was of drinking age), cousin George produced a bottle of Old GrandDad from an estate he had settled which was allegedly bottled in (or before) 1949. Anticipating the savor of well-aged bourbon, the adult consensus was dour looks of "What's this?" and confirmation that it tasted like "old wood shavings." Lesson #1: bourbon does not age in glass.
My bro' gave me a bottle of Macallan 25 for my 40th birthday. Sipping and sharing most sparingly, ten years went by until I got down to the last third of a dry corked bottle that tasted like - you guessed it - old wood shavings. Lesson #2: even the best of scotches in their fancy boxes need to be consumed within a reasonable time period.
I was extremely fortunate to have been invited to an Armagnac tasting presented by Sempe Armagnac in 2000. We tasted Armagnacs from various years back through the 1940's until the Directeur General uncorked a bottle of 1914 Grande Reserve and passed it around. Kegged in that year, it had remained in oak until 1990 when it was transferred to glass as the oak was starting to rot. It was the distilled spirits experience of a lifetime. Lesson #3: Spirits need to be in wood until they need to be rescued from the vehicle of their aging process.
I've also been to parties where none of the above are recognized. One inch of spirits in a bottle with a 25-year-old tax stamp does not impress me. However, I still have an almost full bottle of Creme de Menth from 1976 that still appears to be OK - but I haven't touched it since.
I have an unopened bottle of Cusano Rojo Mezcal picked up in Oaxaca back in the mid 70s. The worm is gone, the little packet of salt is gone. Can't even remember why I saved it in the first place. Been meaning to try it as a shooter and in a cantarita (?) or Paloma if I can ever find some of the Mexican grapefruit soda.
Non drinking friends of my parents would buy in spirits each Chritmas for entertaining guests. Every January they would pour away the leftovers as they would 'only go off'.
My parents wept.

subset: commoncrawl


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Friday March 16, 2012
Rihanna has said her musical collaboration with Chris Brown "made sense" and is "innocent".
The rapper appears on a remix of her song Birthday Cake, and she features on a version of his tune Turn up the Music.
Their musical union is noteworthy after Chris pleaded guilty to attacking his former girlfriend three years ago and is still on probation for the assault.
Rihanna says it was her idea for her ex boyfriend to appear on her song because he's "the hottest R&B artist" right now.
She says the partnership allowed fans to come together, adding: "There shouldn't be a divide... It's music, and it's innocent."
She made the comments to US broadcaster Ryan Seacrest on his radio show.
Photo: © Getty
The latest news and pictures of the hot young Hollywood actress and star of Silver Linings Playbook
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When it comes to pregnancy cravings, the Brazilian beauty – who's expecting her second child – has an unusual desire for a cold pint of beer. "It's very strange because I normally don't like beer. Now I want some but I cannot drink it. It's been very hard!" Lima – seen taking a dip in Miami with soon-to-be big sister Valentina, 2 – told PEOPLE.
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Plants Vs Zombies - End Of Humanity
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In order to promote his up and coming Musical, "Madea's Big Happy Family", Tyler Perry (African-American actor, director, playwright, screenwriter, producer, author, and songwriter) has been spoofing this years Oscar nominated films. As a promotional stunt, Tyler Perry has recreated the classic movie posters for hailed movies such as The Godfather and Black Swan.These ads are hilarious renditions of the best screenplay nominees and are highly creative!
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When the term 'ghost' gets a mention, I don't know if I'm alone here but the words 'Casper' and 'friendly' seem to come to mind along with visions of Patrick Swayze in his hey day. At first mention,I just don't associate ghosts the same way as I do other obviously spine-chilling suspects like zombies, vampires and aliens. Maybe it's because they aren't usually visually terrifying (obviously the pesky devils are invisible or transparent and so don't have the demented 'I'm gonna hurt you' look down).
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MGM's 'Hot Tub Time Machine' Sequel Going Out through Paramount
MGM has partnered with Paramount Pictures as the worldwide distributor of the sequel to 2010′s "Hot Tub Time Machine."
Paramount will distribute the film theatrically and via home video worldwide next year, but has not yet chosen a release date. Select international territories will be handled theatrically by MGM.
Rob Corddry, Craig Robinson and Clark Duke are reprising their roles from the comedy, which grossed $64 million worldwide. Steve Pink ("About Last Night") is directing from Josh Heald's script.
Adam Scott ("Parks and Recreation") also stars. The film is produced by Andrew Panay.
Story centers on Corddry's character getting into trouble and his friends firing up the hot tub time machine in an attempt to go back to the past -- only to land in the future.
MGM and Paramount have partnered on several projects, including the upcoming "Hercules," starring Dwayne Johnson and directed by Brett Ratner, as well as "G.I. Joe: Retaliation" and "Hansel & Gretel: Witch Hunters."
Related storiesEd Helms Firing Up 'The Naked Gun' Reboot for Paramount (EXCLUSIVE)Paramount Settles Film Slate Dispute With Content PartnersBrad Pitt's Plan B Leaving Paramount for New Regency, RatPac 2013 Variety Media, LLC, a subsidiary of Penske Business Media; Distributed by Tribune Content Agency, LLCCopyright © 2014, Chicago Tribune


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metals recycler,
Reamer Recycling Services,
Upstate Shredding-Ben Weitsman & Son,
Adam Weitsman,
Bill Reamer,
Lisa Gordon
PITTSBURGH Reamer Recycling Services Inc. has formally exited its relationship with Metalico Inc. and has now arranged to marry a direct competitor.
Ithaca, N.Y.-based Reamer Recycling is being sold to Upstate Shredding LLC-Ben Weitsman & Son Inc., company president Bill Reamer told AMM. "I think it is difficult for a small independent these days and is getting tougher and tougher. You either grow or shrink, so it is important to partner with people you are comfortable with."
Reamer purchased the yard, which has been around for more than 70 years, from his former employer 15 years ago. The seven-acre facility, which has rail service, sorts material and shears.
Upstate Shredding confirmed that a deal has been reached. "It is a great geographical location with a strong industrial base. The obsolete material generated will feed our Owego (N.Y.) shredder," Adam Weitsman, president, said.
The deal is expected to close within the next 30 days, after which Upstate Shredding management will work alongside Reamer and the 15 employees at the Ithaca yard.
Reamer Recycling and Cranford, N.J.-based Metalico dissolved their joint venture April 1. A lawsuit filed on the accounting aspect of the breakup was recently resolved, Reamer said (amm.com, April 2).
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Weather Links
Humidity 45%
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Sep 7, 2010 12:30 PM by Melissa Canone
CHALMETTE, La. (AP) - St. Bernard Parish Fire Chief Thomas Stone
says an early-morning power failure at Chalmette Refining released
at least a ton of spent catalyst powder over much of Chalmette and
Stone says that when people woke up Sunday, it looked as if a
sandstorm had blown through.
He says residents can clean it from cars and other property
without danger, but it's a nuisance.
St. Bernard President Craig Taffaro Jr. says people should
photograph it for their records before cleaning it.
He says the refinery has issued a toll-free claims number:
9 hours ago


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a sur name
see the happy moran he doesent give a dam i wish i was a moran OH! god prehaps i am.-quote Nana Moran
Beküldő: Donal Moran 2004. május 22.
A noob who posts a topic explaining to everyone how to correctly spell moron in the sport-touring.net Off Topic forum
"Moron is NOT spelled MORAN (note the letter A)"
Beküldő: Not An STN Noob 2008. február 6.
A Moran is a one armed gay bandit who loves taking it up the shit pipe off a big black cuck. his favourite sexual act is a alabahma hot pocket.
My mate is a right Moran last nite he took it right up his dark alley off tysons twin the gay bastard.
Beküldő: Chalky 123 2010. április 11.
Originated with a mock war protest who held up a sign that read "Get A Brain! Morans" and has since become an internet cliche not only for stupid people but also sarcasm and irony.
Samples from the mock protest: "Get a brain! Morans", "Ask Me About My Baby Killing Honor Student", "Soccer Moms For Blood" and "Bomb My Car"
Beküldő: Howard 2005. április 7.
Flaming Liberal/ Member of the Church of Scientoogy
Pro anything liberal and against anything good
Favorite Activity is motorboating Hillary Clinton
Pro anything liberal and against anything good
Favorite Activity is motorboating Hillary Clinton
Anyone who imitates Moran is a douche bag but not as abig a douche as Moran...No one could do that
Beküldő: Liberalhater 2007. december 3.
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The urban shopping villages that ring Chandler Fashion Center have had a lot of recent additions. And more are coming.
Here's an update on the new stores.
At Chandler Gateway, northwest of the intersection of Loop 101 and Chandler Boulevard, recent openings include a Men's Wearhouse and Shabu Fondue, a restaurant that serves up fondue and Japanese "hot pot" dishes.
Chandler Festival, northeast of the Loop 101-Chandler Boulevard intersection, has a couple of new shops — Silk Road Asian Bistro and ReCollections, a scrapbooking store.
In the Boulevard Shops that line Chandler Boulevard north of the mall, recent store openings include La-Z-Boy, Go Wireless and D & D Bridal stores. Dolce Medspa and Dolce Barbershop are in the planning stages.
Chandler Village Center, anchored by the Target Greatlands, is filling up fast. Recent openings include T-Mobile, Portrait Innovations and Snip-Its.
Expected to open this month in the Village Center are furniture giant Kirkland's, The Billiard Store, EB Games, Supercuts and local restaurant favorite Someburros.
SanTan Village, the underconstruction complex of big and little shops that straddles Williams Field Road west of the planned Santan Freeway stretch of Loop 202 in Gilbert, is filling up so fast its difficult to keep up with the changes.
Just this week, parent Westcor launched a Web site, www.shopsantanvillage.com, so tech-able neighbors can stay abreast of developments.
• Goodwill of Central Arizona's newest retail location is scheduled to open 9 a.m. Friday at 2039 W. Guadalupe Road in Mesa.
Special grand opening giveaways and other activities, including raffles for a television, DVD player and portable stereo; a balloon drop; and a wheel to spin for prizes, are planned throughout the weekend.
• If running, cycling or swimming are your bag, you can buy bags, clothing, gear and other stuff suited to your sport at Triple Sports, a new shop at the southwest corner of Miller and Indian School roads in Scottsdale.
Fellow enthusiasts opened the sports specialty store in June.
• Did you still love him, now that he's 64? Actually he's 65 as of today. Happy birthday to former Beatle Ringo Starr, whose pop artwork is available to buy or eye in the Rock Star Gallery at the Scottsdale Promenade, southeast corner of Scottsdale Road and Frank Lloyd Wright Boulevard in Scottsdale.
If you have a new shop to tell us about or you see activity at a retail location and are wondering what's happening, let us know.


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an arrow is shot into air. its range is 200m and its time of flight is 5s . if g=10m/s2 ,then horizontl compoent of velocity and the mximum height will be
June 17, 2012
a mother is 21 years older than her new born daughter.how old will the daughter be when her age is 1/4 that of her mothers
January 16, 2012
A spherical concave mirror has a radius R=360 mm forms an image of a h(object)=12 cm high object located d0=p=0.9 m from the vertex of the mirror. Find the position di=q(cm) and the height cm of the image.
December 7, 2010
A convex lens of focal length 10 cm forms image of object placed 30 cm in front of the lens. Find the magnification?
December 7, 2010
What actually happens if we mix the chloroform with hexane? what is the exact reaction between them & is the resulting product ia stable?
May 11, 2010
I want an essay based on the idiom topic "do unto others as you would have others do unto you".
August 7, 2009
Pages: 1


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Steven Greenhut over at The Orange County Register's Orange Punch blog recently reported more bad news for Sheriff Mike Carona. Key members of the powerful Republican Lincoln Club announced last week they believe it's time to form a civilian review panel over the sheriff's department, says Greenhu ... More >>
It looks like Irvine Republicans may have finally developed their own alternative to the Hometown Voter Guide. The Irvine City, School and Neighborhood Leaders Committee (ICSNLC) has paid for $28,011 worth of independent expenditures opposing Beth Krom, $7,612 to oppose Mary-Anne Gaido, another $7, ... More >>
Four ways to make Santa Ana the capital of Latino USA
Saigon, USA white-washes local history
Little Saigon sees a mainstream future


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Fall Career Fair-Employers Page
Wednesday & Thursday, October 8 and 9, 2014
Online registration begins August 13, 2014 Register Now!
Event location: Recreation Center, Building 43
Registration fee: $800 per table/day
Recruit students from all majors for career, co-op, and internship positions. An informal networking session is followed by optional afternoon interviews. Employers must have open positions in order to attend. Job descriptions are required at the time of registration. Students from all majors and all levels (first year through alumni) are invited to attend. List of Majors
Registration Fee
The registration fee is $800 per table/day. Employers have the opporunity to attend one of the two days. Your registration fee includes:
- One 6 foot rectangular table with linen and registration for three representatives. Additional representatives will be an additional charge $35 each.
- Event advertising: The Career Fair will be advertised on the campus electronic bulletin board, in presentations to classes, Mustang Daily ads, and on the Cal Poly Home Page. All job opportunities submitted during the registration process will be advertised to students in the ever-popular MustangJOBS.
- Continental breafast, lunch and afternoon refreshment.
- Campus parking and shuttle service to and from the parking lot
Optional Fees
Extra representatives (limit five per table) -$35 each
Extra table (additional tables are approved based on space availability) - $800 per table/day
Fall Career Fair Agenda:
8:00 a.m. - 9:30 a.m.: Check-in, table set-up and breakfast
9:30 a.m. – 1:30 p.m.: Open forum/networking with students
11:30 a.m. – 1:30 p.m.: Employer lunch (the career fair will remain open)
1:30 p.m. – 4:30 p.m.: Optional: Pre-arranged student interviews*
*Employers will have the option of conducting interviews at their event table during the afternoon session of the career fair. You will be provided with a blank interview schedule. Interview sign-ups will be generated by the recruiters at the job fair as they speak with students and invite them to interview. Once again all interviews will be conducted at your event table.
Request for Private Interview Rooms after the Career Fair
If you choose to interview the day after the career fair, you may reserve a private interview room. All reservations requested are accepted on a first-come, first-served basis and must be requested the day of the career fair, and there is a one room per company limit. Please see Career Services recruiting staff to reserve your space. On the day of the career fair, once you have secured your room you will be provided with a blank interview schedule. You control your schedule and may add candidates throughout the day. Your final schedule must be given to Career Services recruiting staff.
Career Fair Cancellation and Refund Policy
We hope that a company will not cancel, but in the event that a company chooses to withdraw completely from the career fair, the following refund schedule will apply. Once you have been notified that your registration has been approved, our cancellation policy is in effect. The following cancellation policy applies:
If cancellation occurs on or prior to August 27, 2014, you will recieve a refund minus a $100 cancellation fee.
If cancellation occurs after August 27, 2014, you forfeit your registration fee.
All changes and cancellations must be in writing. All refunds will be processed after the career fair. No refunds will be issued on or after August 27, 2014 and you remain responsible for paying any outstanding balance. We cannot "roll over" the registration to another event. Outstanding bills from this and previous events must be paid and may prevent participation in future Career Services events.
No Show
Organizations that do not check in by 10:30 a.m. on the day of the event will be considered a "no show." The table may be reassigned and the organization will be billed for the event. We cannot "roll over" the registration to another event or refund the fee.
More Information
You can find more information regarding this event here: Additional Details