Voluntary cleanup agreements have been a staple of cleanups under both state and federal cleanup programs for decades. … California Health & Safety (“H&S”) Code § 101480 et seq. (“Section 101480”) allows local agencies to enter into voluntary cleanup agreements and recover their oversight costs. Section 101480 provides no framework or authorization for local agencies to adopt their own corrective action requirements but requires that they oversee the investigation and cleanup consistent with the Water Code. Several local agencies in California – including some of the most populous cities and counties – have used Section 101480 as enabling legislation to establish site cleanup programs (“SCP”), including San Francisco City and County, Alameda County, and Orange County.