I agree with the comments provided by Jim Thornhill and Channing Martin, and want to emphasize the importance of keeping the VRP attractive to property owners and developers by clearly defining all requirements of the program.  

Delineating off-site contamination can be problematic, and requirements for off-site delineation need to be well defined and consistently applied.  However, the regulations should also allow for some discretion by DEQ to ease requirements in cases where site-specific circumstances present significant burdens for off-site delineation efforts.  

Increase the enrollment fee, if necessary, to cover the gap in program funding.  The VRP often offers owners or buyers the only opportunity to fund and develop an impacted property, while offering the Commonwealth the only opportunity to remediate the impacted property.  The value of VRP as a Win-Win regulatory program cannot be overstated; the cost of VRP (to applicants and to the Commonwealth) is small when measured against the better use of land, increased tax revenues, employment, and other benefits of redeveloping blighted and under-utilized properties.

John Sweeney, Environmental Consultants and Contractors (ECC)