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Large Tract Phase I ESA

Partner performs “Large Site” 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 tracts 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.

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