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

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.