New Standards for Phase I Environmental Site Assessments
Enviro-Letter: The new ASTM standard practice Phase I ESA: E1527-21
Have questions about an environmental issue? Please feel free to contact Ray about any question or concern you have on your property or a listing. Remember, I only do the Phase I ESA or Real Estate Transaction screens.
I do not do Phase II type testing or Phase III remediation action requirements, so I have nothing to gain to recommend testing or other costly cleanups that may actually be unnecessary. Give me a call so we can discuss any potential issues.
Quiz
What commercial use does the EPA consider the number one “high risk” environmental issue in the retail areas? (Answer below)
On November 1, 2021, the American Society for Testing and Materials (ASTM) Committee on Environmental Assessment, Risk Management and Corrective Action approved a new standard practice for conducting Phase I Environmental Site Assessments (ESAs). For the last eight years environmental Professionals (EP) have been performing the Phase I ESA of real properties under the E1527-13 standard.
The new standard ASTM E1527-21 makes significant modifications to the E1527-13 of which the more significant requirement to “low-risk” commercial/retail properties is the review of standard historical sources. The previous E1527-13 gave the EP discretion as to what historical resources the EP believed were necessary to meet the objectives of an ASTM Phase I ESA. The new standard E1527-21 prescribes that at a minimum historical aerial photos, historical city directories, historical topos and historical Sanborn maps shall be reviewed not only for the subject property but also the adjoining properties (and adjoining properties now means not just abutting, but tracts across alleys and streets).
The new standard also gives new “guidance” and “clarity” as to Recognized Environmental Condition definitions and same will be explained in the report or as a new appendix to be added.
Phase I ESA Cost
The cost of a Phase I ESA is relatively cheap environmental insurance, but testing and remediation can be very expensive, and therefore the seller should always have a say who will do the environmental inspection. And the best way to assure that is to have a report prepared by your EP ready to provide potential buyers.
“It’s hard for the modern generation to understand Thoreau, the nature lover, who lived beside a pond but didn’t own a paddleboard or a snorkel.”
– Loudon Wainwright
Quiz Answer
The ASTM committee, when updating the new E1527-21 standard, learned from the EPA that many of the most highly contaminated properties in the US are former dry-cleaning facility sites.
ESA Terms to Know:
Registered Drop Station
This is a facility where clothes to be cleaned are dropped off and then delivered to the dry cleaning plant for actual cleaning. The cleaned clothes are then delivered back to the drop station for customer pickup. These facilities are not an environmental concern.