More on Phase I Environmental Site Assessments in the Chicago Area

1. The City of Chicago used to have a Department of Environment. Some nearby suburbs have Environmental Health Departments, and many don’t. More often than not, you can’t just fire off Freedom of Information Act requests (FOIAs) in an hour or two. Many experts set aside a half day. Simply put, one needs to have both spatial and temporal knowledge of which agency holds records, what records they’re likely to have, and how long it will take to get them.
2. Most properties comprise several parcels, each with historical and current addresses. Adjoining properties research, therefore, requires a keener eye to discern how many adjacent parcels are actually involved with the adjacent operations. There is an enormous volume of information available for even the simplest site, much of which can be crucial to findings. The work on a 0.14-acre parcel often involves a few generations of construction, address schemes, tenants, and operations.
3. As Chicago is an old city, located near both a river and one of the Great Lakes, there’s a long industrial history associated with those kinds of features that sprawl out a couple of dozen miles into the neighboring counties. A vacant lot here is almost never “just” a vacant lot.
4. The Chicago Fire of 1871 destroyed a large portion of the city and thus “buried” an entire phase of original city development. Many of the records prior to the Fire were also destroyed, thus making it difficult to track down records pertaining to the original development in the city, especially the downtown “Loop” area.
5. Many of Chicago’s residential areas developed along busy thoroughfares have been comprised of mixed-use buildings; thus, even a seemingly “residential” section of the city may have a lengthy history of various ground-floor commercial operations, including dry cleaning and/or automotive service facilities. Thorough historical research, in conjunction with local expertise, is required to properly screen potential historical operations of concerns in these areas.
6. The City of Chicago is constantly undergoing redevelopment. Specifically, areas across the south and west sides of the city with extensive commercial/industrial/warehousing history are frequently being redeveloped into large, multi-family high rises. Again, localized expertise is key in quickly identifying if a property in one of these areas is located within an area of known widespread contamination.
7. In the City of Chicago, typically, half of the adjacent sidewalk(s) is part of the property. It is not uncommon for heating oil underground storage tanks (USTs) to be installed around these areas; however, thorough research into records from the numerous regulatory agencies (past and present) overseeing tank installations in the city is crucial in identifying the likelihood of an orphan/undocumented UST on a property.