The Boeing Company, Santa Susana Field Laboratory, Canoga Park, California

The Los Angeles Regional Water Quality Control Board (Los Angeles Water Board or board) recently received a letter from Public Employees for Environmental Responsibility (PEER) that contains several inaccuracies and false allegations against current and former board members. The letter was dated June 8, 2022, the same day as two press releases issued by PEER about the same matter. The Los Angeles Water Board takes its roles and responsibilities to protect water quality at the Santa Susana Field Laboratory (SSFL) site very seriously and ensures all its decisions about SSFL are and will remain untainted by any actual or perceived conflicts of interest. The board firmly refutes the false allegations in the letter and the press releases, and it rejects the statement that the board has a legacy of improper ties to The Boeing Company (Boeing). The board provides the following for the record:

• Acting Chair James Stahl was never a consultant for Boeing. His prior employer, the MWH firm, employed thousands of individuals and a few hundred executives. Though Acting Chair Stahl was one of many vice presidents at MWH, Boeing was not a client of his. He did not receive any income from Boeing and did not supervise anyone’s work on projects involving Boeing during his time at the firm (2007 to 2015). He was not involved in the development of the Standard Risk Assessment Methodology (SRAM) in any way. There is no actual conflict or appearance of conflict, and his recusal from upcoming proceedings is neither appropriate nor necessary.
• Former Board Member and Chair Lawrence Yee was not removed from the board as alleged. He resigned after 10 years of service for personal reasons.
• As is customary protocol, Vice Chair Stahl assumed the position of acting chair until the board goes through the process of electing a new chair.
• Donations by Boeing to a non-profit organization led by Board Member Muñoz have been evaluated by the Water Boards’ legal counsel and do not disqualify her from serving on the board. Further, Board Member Muñoz has continually recused herself from all Boeing-related decisions for many years. She did not participate in the renewal of the NPDES permit for Boeing in 2015 and has not participated in any decisions by the board related to Boeing since that time, including enforcement decisions. Similarly, she has recused herself from any involvement in the mediation with CalEPA, DTSC and Boeing that resulted in the comprehensive framework for cleanup of the Santa Susana Field Laboratory, and she will not be participating in the board's decision on the proposed MOU.
• With respect to former Board Member Charles Stringer, he never had an economic interest that was required to be reported on his Statement of Economic Interests (also known as the Form 700) related to the work his employer, Renewable Resources Group (RRG), previously performed for Boeing, nor was he ever a lobbyist for Boeing. Nonetheless, Mr. Stringer voluntarily recused himself from all matters related to Boeing from the time of his appointment through the end of his tenure on the board in November 2021.

These unfounded attacks on board members themselves, presumably to create a false narrative to discredit the board before it makes difficult and important decisions, do not advance the public process.

Response to PEER’s June 8, 2022 Letter

Read Statement by Executive Officer Renee Purdy – April 14, 2022 Los Angeles Regional Board Meeting about Member Munoz’s longstanding recusal and non-participation in Boeing matters, including enforcement matters.

Prior to and during the February 10, 2022 board meeting, false allegations of bribery were made against Board Member Muñoz in connection with donations made to her non-profit organization, Mujeres de la Tierra, by The Boeing Company, an NPDES permittee. I want to state clearly and unequivocally that these allegations are false. At that time, given Board Member Muñoz’s strong statement refuting these false allegations, and the fact that the board continued the hearing to the following Thursday, I thought I would be provided an opportunity the following Thursday to address the allegations made. Because that did not happen, I regret that this is coming well after the February 10th meeting. Since the February 10th meeting, we’ve received an inquiry from the Ventura County Star and a Public Records Act request from Public Employees for Environmental Responsibility (also known as PEER), the organization that made the allegations. I and the Office of Chief Counsel took these opportunities to again set the record straight that these allegations are false.

Board Member Muñoz did not participate in the renewal of the NPDES permit for Boeing in 2015 and has not participated in any decisions by the board related to Boeing since that time, including enforcement matters.

This includes the June 2019 decision to grant Boeing relief from monetary penalties for violations of effluent limits due to the 2018 Woolsey Fire. The decision was made by the Board’s enforcement staff who determined that an appropriate affirmative defense existed under the Water Code and based on that, did not levy the full penalty. This is consistent with prosecutorial discretion and the enforcement staff had that authority. I was informed and supported the decision. Board Member Muñoz and the other board members were not involved in making that decision in any way. However, as is customary for matters that may result in high public or media interest, I informed both Board Member Muñoz, who was chair at that time, and then-vice chair Yee of the decision after it was made and immediately before the letter was sent. I then informed the other board members.

Further, I want to state that the Board’s legal counsel has evaluated the aforementioned donations and concluded that they did not disqualify her from serving on the board under applicable law. I have worked with Board Member Muñoz for over a decade, including several years as chair of this Board, and have great respect for her and the work she does serving the communities of our region.



Read Statement by Board Chair Lawrence Yee about Member Munoz’s non-participation in Boeing matters.

At our February 10, 2022 LA Regional Water Board meeting during the testimony for Item #13, the Santa Susana Field Lab Boeing Company NPDES Permit Renewal, it was alleged by Daniel Hirsch in his presentation that Board member Irma Munoz while she acted as Chair of the Board participated in the making of a decision that resulted in the waiver of fines levied against The Boeing Company from contamination caused by the Woolsey fire of 2018. That is not true. She was informed by staff of the waiver, but she was not party to the making of the decision to grant the waiver. I know because at the time I was serving as Vice-Chair and I was on the call when we were told.

I have known Board member Munoz for the 11 years she has served on the Board as we were both appointed at the same time by Governor Jerry Brown. Without question, she has served with distinction. I consider her a trusted colleague and have nothing but the highest regard for her character, her credibility, and her integrity. She behaves with only the highest of ethical standards.



Read Member Muñoz’s statement provided at the February 10, 2022 meeting.

I have voluntarily recused myself from the proceeding on the Boeing Company's NPDES Permit for the Santa Susana Field Laboratory Site, or SSFL.

Since September 2020, false allegations have been made against me. I have received anonymous threatening letters at my home, my work, and at the Regional Board headquarters, accusing me of taking bribes, acting unethically. Recently, similar anonymous letters were also forwarded to CalEPA and the State Water Board, accusing me and my nonprofit, Mujeres de la Tierra, of corruption. And I have been informed that just a few weeks ago, a consultant contacted a fellow Board Member and accused me of taking bribes to support the permit and said I had faced investigation by the FBI and potential felony charges. Finally, I am aware of the request that the Attorney General's Office investigate me and donations that Boeing made to Mujeres de la Tierra.

These letters and threats, whether they’re anonymous or not, I will not be intimidated by someone. If someone has something to say to me, then say it to me and grant me the opportunity and courtesy of correcting any misinformation you may be operating under.

I have been a Board Member for 11 years, since 2011, and I have been the Board's Chair twice. It has been one of my proudest acts of public service and I’ve always acted with the utmost integrity and respect for my office. Being a Board Member has been and continues to be one of the greatest honors of my career.

In an abundance of caution, I have not participated in any decisions involving Boeing since 2015. Since 2014, Boeing has donated money to Mujeres during fundraising activities and to support various programs, such as programs on water quality education, including the Telenovelas in the Park program. Money donated is separately accounted for and is used exclusively for those programs. I have not personally received a financial benefit. While I receive a salary for my nonprofit, none of the money donated has ever gone to pay for my salary. I'm not required to disclose contributions from Boeing to Mujeres on my annual Statement of Economic Interests, also known as the Form 700, nor am I required to disclose Boeing’s contributions on the record for this or prior proceedings.

In addition, I do not have any actual bias for or against Boeing that would create a conflict of interest. I am aware, however, that any hint of even a perception of bias could be misinterpreted, and I do not want any of the Board's decisions to be clouded unnecessarily.

Therefore, as I have done in the past, I am voluntarily recusing myself on this matter to avoid even a perception of a conflict of interest.

For the record, I have not discussed or attempted to influence my fellow Board Members or Board staff regarding the current and this tentative permit, or any other Boeing item. This includes any matters related to enforcement of the current permit and the ongoing mediation that is a matter of public record between the Regional Board, DTSC, and Boeing. Therefore, any claims or allegations that I have had any undue influence on this or past proceedings are absolutely false. I will not be intimidated. Thank you for your time and attention.