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Large Tract Phase I ESA

Partner performs “Large Site” or Large Tract Phase I Environmental Site Assessments (ESAs) for forestland, rural, or agricultural property in accordance with the ASTM E2247-08 Standard, which EPA has approved as constituting All Appropriate Inquiry (as with ASTM 1527-05).

The ASTM E2247-08 Standard has a few key differences from ASTM E1527-05, which present some unique challenges. The main scope of work differences for assessing Large Tract Phase I ESAs such as forestland or rural property are:

  • Site reconnaissance
  • Regulatory records search
  • Historical sources

The E2247-08 Standard allows for reliance on remote sensing such as aerial photography as an approach to inspecting the property when necessary by inspecting the aerials to identify structures and potential areas of concern (disturbed soil, trenches or other features) and physically inspecting those areas and other accessible areas. In unusual circumstances where the property cannot be accessed at all, there are provisions for other methods such as viewing the property from nearby vantage points.

The E2247-08 Phase I Environmental Site Assessment regulatory records search requirements are slightly different, as there are “additional environmental records” sources and search distances must be from the property boundaries.

Finding appropriate historical information may involve checking non-standard sources. Only historic aerial photographs and topographic maps are considered “standard historical sources,” and “other sources” include things like mineral/oil/gas development maps and livestock dipping vats records.

Clients will want to look for a consultant with a familiarity with the area and what resources are available, a practical yet thorough approach to the site visit, and experience with these ESAs. Partner has done numerous E2247-08 Phase Is across the US and is well versed in their unique requirements. Assessing these sites is manageable with the right knowledge and approach.

What's Involved

Large Tract Phase I ESAs present unique challenges compared to smaller properties:

  • Extensive Research Area: Historical research and regulatory database review encompass a much larger geographic area.
  • Varied Land Uses: The property might have a mix of uses (forestry, agriculture, industrial) requiring tailored investigation strategies for each area.
  • Accessibility Issues: Certain areas of the property might be difficult to access for site inspection.

Related Insights

Frequently Asked Questions

If environmental concerns are identified, further investigation may be warranted, such as a Phase II ESA, to assess the extent of contamination and potential risks. Depending on the findings, mitigation measures may be recommended.

The time frame can vary depending on the size and complexity of the tract of land, but it typically takes several weeks to a few months to complete the assessment and prepare the report.

Large tracts present unique challenges compared to smaller properties:

  • Extensive Research Area: Historical research and regulatory database review encompass a much larger geographic area.
  • Varied Land Uses: The property might have a mix of uses (forestry, agriculture, industrial) requiring tailored investigation strategies for each area.
  • Accessibility Issues: Certain areas of the property might be difficult to access for site inspection.

The report will typically include:

  • Detailed description of the property and its various zones.
  • Comprehensive historical research for the entire tract.
  • Regulatory review focused on relevant environmental concerns for the property’s location and intended use.
  • Site inspection findings tailored to different areas within the large tract.
  • An opinion on the likelihood of Recognized Environmental Conditions (RECs) across the property, considering potential variations in different zones.
  • Recommendations for further investigation if needed in specific areas.

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