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Brownfields Tax Credit Comments.pdf

2-11-21 LSPA comment letter on 830 CMR 63-38Q-1 Brownfields Tax Credit.pdf

Preview of Brownfields Tax Credit Comments

🔗 Source: lspa.memberclicks.net

📊 Size: 262 KB

👤 Author: wendy rundle

⬇️ Downloads: 55

Summary

The LSP Association comments on Proposed Regulation 830 CMR 63.38Q.1, Massachusetts Brownfields Tax Credit, suggesting changes to maintain consistency with statutes, ensure effective date is no earlier than 30 days after issuance of final regulations, and eliminate inconsistencies with the Massachusetts Contingency Plan. Key concerns include:
- Using terms not in the statute, such as "remediation" and "remediates"
- Requiring MassDOR to make determinations within MassDEP's expertise and authority
- Proposing a higher standard for eligible costs than those recoverable under M.G.L. c. 21E
- Inconsistencies with MassDEP policy, particularly regarding achievement of background and ineligible costs
- The need for a non-punitive appeals process, limiting reconsideration of application materials during appeal to items being appealed, and deleting punitive repayment provisions.

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Description

The LSP Association comments on Proposed Regulation 830 CMR 63.38Q.1, Massachusetts Brownfields Tax Credit, suggesting changes to maintain consistency with...

Technical Information

File Format: PDF
File Size: 262 KB
Pages: 4
Language: EN
Author: wendy rundle
Total Downloads: 55
Last Updated: 4 weeks ago

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This PDF document about Brownfields Tax Credit Comments provides comprehensive information and guidance. Whether you're a beginner or advanced user, this resource offers valuable insights into Brownfields Tax Credit Comments.