Phase I Environmental Site Assessments
If you’ve ever wondered what a Phase I Environmental Site Assessment (ESA) actually includes, you’re not alone. It’s a term that gets thrown around in real estate and environmental consulting, but unless you’ve been through the process, it can feel like a black box. McAlister Geoscience is here to help break it down.
Historical Research — Digging Into the Past
Before anyone walks the site, a lot of groundwork is done using historical records. These are like a property’s old yearbooks and report cards—they tell us what the site was used for and if anything (potentially messy) occurred on the property. Below are some of the records we research:
- Aerial Photographs — These overhead images, often from the USDA or USGS, are reviewed to spot changes in land use, development, or suspicious activity over time.
- Topographic Maps — Created by the USGS, these show elevation, drainage, and natural features that might influence environmental conditions.
- Fire Insurance Maps — Usually sourced from the Sanborn Library, these detailed maps were originally made for insurers to assess fire risk. Today, they help identify old tanks, building footprints, and potential hazards.
- City Directories — Think of these as the pre-internet yellow pages. Publishers like Cole, Polks, or modern digital business directories list what kind of businesses operated at specific addresses.
These records help build a timeline. If a dry cleaner operated there in the 1960s? That’s a red flag. An old gas station? Could mean buried tanks.
Public Record Review — What the Government Knows
Next, a deeper dive is done using local, state, and federal records, —some of which a
re accessed through FOIA (Freedom of Information Act) requests.
These requests are submitted to:
- City/County Building & Planning Departments
- Public Health & Environmental Health Departments
- Fire Department
- Utilities
- State Environmental Protection Agencies
The records may include:
- Permits for building, demolition, or underground storage tank removal
- Code violations
- Reports of hazardous materials use or spills
- Inspection records
Regulatory Database Check — National & State-Level Screens
In addition to FOIA records, your team checks federal and state environmental databases. These are essential and required under ASTM E1527-21, the standard that governs Phase I ESAs.
- National Priorities List (Superfund Sites): EPA’s list of the most hazardous sites in the U.S. Being near one can affect property value and liability.
- https://www.epa.gov/superfund/superfund-national-priorities-list-npl
- Engineering/Institutional Controls: Legal or physical tools (like caps or land use restrictions) meant to contain known contamination.
- Brownfields: Sites where redevelopment may be complicated by real or potential contamination. Often former industrial areas.
- ERNS (Emergency Response Notification System): Tracks oil and chemical spills that required emergency response.
- State-Specific Databases: These include unique records like heating oil tank decommissioning permits in Washington State or UST registries in Georgia.
Site Visit — What We See and Hear in Person
Once the paper trail is built, the site is visited to see if the current conditions match the records. During the site visit, your team will do the following:
- Observes the property and adjoining sites
- Identifies structures, stains, wells, tanks, vents, or other indicators
- Interviews tenants, site managers, and property owners about past and present operations
If something looks out of place—like a vent pipe that wasn’t in the records—it gets flagged.
The Findings — What We Call It (Technically)
At the end of the process, your team will pull everything together and give it a label. These labels are standardized by ASTM and help buyers, lenders, and regulators understand what level of risk is present.
- Recognized Environmental Condition (REC): A real or likely release of hazardous substances that may require further investigation. (Defined by ASTM E1527-21 Section 3.2.78)
- Historical REC (HREC): A past release that has been addressed to standards and doesn’t pose a current risk. (ASTM E1527-21 Section 3.2.40)
- Controlled REC (CREC): A past release that was addressed, but where restrictions or controls remain in place (e.g., deed restrictions, soil caps). (ASTM E1527-21 Section 3.2.17)
- De Minimis Condition: A minor issue that doesn’t present a significant threat and doesn’t trigger further action. (ASTM E1527-21 Section 3.2.27)
- Business Environmental Risks (BER): Risks not covered by ASTM—like asbestos, mold, or wetlands—that might still affect how a property can be used.
Why It’s Worth It
You might be thinking, “That is a lot of work just to buy a building.” And you’re right—it is. But here’s why it matters:
- Protection from liability: A Phase I ESA can shield you from responsibility for pre-existing contamination under CERCLA (the Superfund law).
- Uncovers hidden costs: Contamination can lead to expensive cleanups. Knowing what you’re walking into helps you negotiate price—or walk away.
- Better financing: Lenders usually require a clean Phase I before approving loans.
- Peace of mind: Even if you’re not required to do one, a Phase I gives you confidence that the site isn’t hiding a toxic secret.
Still Curious?
If you’re unsure about whether your site needs a Phase I ESA—or you just want someone to translate one for you—reach out to McAlister Geoscience. We’ll do the digging for you.
Resources:
https://www.foia.gov/
https://www.epa.gov/superfund/superfund-national-priorities-list-npl
https://www.epa.gov/brownfields
https://cdxapps.epa.gov/oms-substance-registry-services/substance-list-details/78
https://www.astm.org/
https://www.usgs.gov/programs/national-geospatial-program/topographic-maps
https://www.loc.gov/collections/sanborn-maps/about-this-collection/