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California Vapor Intrusion Blog

This California Vapor Intrusion (VI) Blog provides updates on CalEPA’s rule development process associated with reducing attenuation factors (AFs) for volatile organic compounds.  Winefield & Associates contends that the proposed new AF standard of 0.03 is neither scientifically sound nor necessary.  As such, the blog will provide scientific and regulatory data with the goal of developing sane VI criteria that remain protective of human health while not thwarting California development, especially as California experiences a severe housing shortage. 

Thank You CalEPA Secretary Jared Blumenfeld for Meeting to Discuss Vapor Intrusion Guidance

12/5/2019

1 Comment

 
I had the pleasure of meeting in a small group with CalEPA Secretary Jared Blumenfeld on November 4, 2019 at his office in Sacramento. Our team discussed challenges and opportunities of the Vapor Intrusion Guidance on brownfields investments and affordable housing development. We thank the Secretary and his senior managers for their time and attention to this important matter. Our PowerPoint presentation is linked below. We left behind the following recommendations with the overarching theme that without CalEPA intervention, the unrealistic 0.03 Attenuation Factor will continue to have severely negative unintended consequences.
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  1. Develop statewide VI guidance using the scientific peer review and public comment process (HSC 57004) after California data set is evaluated.
  2. Use existing DTSC guidance while new guidance is developed.  (DTSC, 2011 AFs are 0.002 for residential, 0.001 for future residential, 0.001 for commercial, and 0.0005 for future commercial.)
  3. Continue review of current CalEPA files to develop CA-specific AFs.
  4. Allow use of building-specific AFs and encourage accurate VI measurement using such tools as radon testing and the J&E model.
  5. Ensure re-opening of sites with existing NFA Letters will occur only in circumstances of imminent and substantial endangerment (rare)
  6. Clarify that AF and VI Guidance documents are advisory only and not intended to be used as rules – alternate approaches may be acceptable on a case-by-case basis.
  7. Expand programmatic efforts to spur brownfields remediation and clean-up of stalled sites in disadvantaged communities and for housing production in general.
1 Comment
Chris Spengler link
12/5/2019 06:02:44 pm

Hi Matt, kudos for the effort expended here. Another significant issue is that the DTSC has become more concern about protecting their liability than protecting human health. Hence, the promulgation of unworkable criteria. They are far more concerned with the fear of being sued for not protecting human health by activists than they are about providing sound and reasonable guidelines.

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  • Home
  • Investment Criteria
  • About The Founder
  • Press
    • NY Times Article
    • LABJ Article
    • Propmodo Article
    • Commercial Property Executive Article
    • Western Real Estate Business Article
    • California City News Article
    • The Sacramento Bee Article
  • Updates
  • Podcasts
  • VI Blog
  • Contact