Phase I Environmental Site Assessments, ASTM Standards, and Changes

A Phase I Environmental Site Assessment (ESA) is a standard and widely sought-after service environmental consulting companies provide.

The Phase I ESA has many purposes, such as to deliver appropriate inquiry into the previous ownership and uses of the Subject Property, to identify Recognized Environmental Concerns (RECs), Controlled Recognized Environmental Concerns (CRECs), Historical Recognized Environmental Concerns (HRECs), and Business Environmental Risks (BERs).

A reputable environmental consultant company strives to provide thorough and quality reports that can be reviewed and understood by clients and other consultants. Therefore, the American Society for Testing and Materials (ASTM) “Standard Practices for Environmental Site Assessments: Phase I Environmental Process,” designation E1527-21, is utilized by environmental professionals throughout the United States. This standard ensures Phase I ESAs have appropriate formats and content. ASTM International is responsible for publishing widely accepted technical standards for developing products, reports, and services. On November 1, 2021 ASTM International released an updated version of ASTM E1527, ASTM E1527-21. The standard is updated every eight years to remain current.

A Phase I ESA provides comprehensive information about a Subject Property, its adjoining properties, and the surrounding area. This information is obtained through inquiries of the environmental professional and additional resources. Site reconnaissance of the Subject Property and a visual survey of the adjoining properties occurs to observe land use and potential RECs. This includes interior and exterior observations at the Subject Property. In addition to this, interviews are conducted with selected individuals knowledgeable about the Subject Property and adjoining properties. A review of applicable and reasonably ascertainable information about the Subject Property is completed. This information includes aerial photography, USGS topographic maps, state and federal databases, Sanborn Maps, and other governmental sources that are publicly available. If the required information is not attainable, this is considered a data gap and must be addressed within the Phase I ESA report.

Basic changes made to the designation ASTM E1527-13 include format reorganization and changes in punctuation and capitalization. More significant changes in the standard include reconstructed definitions, deleted and added abbreviations, and newly required information for Phase I ESA reports. For example, the definitions for RECs, CRECs, HRECs, and BERs have changed to improve clarity and distinction between them. Another significant change in a Phase I is clarifying the viability period of a Phase I ESA. Specific dates of completed components in a Phase I ESA should be completed within 180 days of each other to be considered compliant.

The standard allocates responsibilities between the environmental professional and the client or “user,” and therefore, clients are expected to provide different types of information before and during a Phase I ESA. Alterations were made to the User Questionnaire to clarify better information being sought from the client. Another change that was made is the scope of the environmental lien search and Activity and Use Limitation (AUL) search. The change includes a title search back to 1980, which is typically requested through a third party but is ultimately the responsibility of the User to obtain unless it is identified in the scope of work of the environmental professional. Lastly, a helpful addition to the standard includes a logic flow chart to aid the environmental professional in identifying RECs.

Keeping Phase I ESA reports up to date with standards and regulations and other reports allows the environmental professional and their clients to have the best environmental records of their Subject Properties. We trust you will consider the Aegis team your Phase I ESA experts when you need a report.