Real Estate Industry Comments on EPA Guidance, March 2002

NYC 9/11 Public Portal Document

Ms. Elissa Feldman March 25, 2002 Page 5

To improve the prospects that the Guidance is not misused please consider the following additional specific edits:

• in the second sentence on page 4, change “highly critical” to “more important”; • delete the second sentence under “Conclusions” or modify it to conform to the language set forth above; • modify the third sentence of the second paragraph under “Conclusions” to state that “some” of the recommendations can be implemented reasonably quickly

Additional Comments “Know Your Building” (p.d): • One comment pointed out the building survey section, while generally correct, contemplates the collection of data via a building “walk-through” but provides no useful information about the practical implications of that data. There are instances where a connection is made to the walk-through investigation survey in later sections (e.g., discussion of modifying HVAC system on p.5). Many of the questions asked in that section, however, are not connected practically to the rest of the document. • Another comment suggested the list of questions in the survey section be expanded to add as a final question; “type of filtration utilized other technologies UVC lamps?” b.) Importance of Personnel Issues: With cleaning contractors and other vendors having access to most areas of offices and other types of commercial real estate, it is very important to know who works in your buildings at all times and who has access to what areas of each building. While the section on key card access goes some distance to addressing this issue, one major office building owner commented that the personnel issue should have been highlighted more directly. c.) Identification/Protection of Occupants within Specific HVAC zones: A major retail tenant commented that the guidance should at least raise the issue of identifying actual occupants of each HVAC zone. It is one thing, the retail company noted, to physically localize any CBR impacts, but the people that could have been affected should also be easily and quickly identified for treatment, monitoring, etc. The comment noted that this issue may be covered in future documents in more detail, but that this set of recommendations would be is remiss without mentioning the point now. d.) Emergency Response Plans: According to one comment, the Guide references response plans for dealing with diverse (non-terrorist) contingencies including fire and natural disasters. The comment suggests these plans should also be taken into account in the decision-making process related to management of the HVAC systems. The comment suggests that reference to these plans in the 2nd paragraph of the “scope” section on page three, should be amended by adding the words “that takes into account an overall emergency response plan.” at the end of the third sentence.

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