LAS has settled in with the new ASTM standard (ASTM E 1527-13), having retooled its Phase I ESA reports. We are not really doing anything different from our previous comprehensive site assessment approach, but vapor migration risks are now discussed as a regular feature.

We continue to be alarmed at the practices of the big national Phase I ESA firms, particularly the entrapment that invariably comes from how RECs are worded, and the incorporation of “Phase II” ESA recommendations in the report. Not only do you tie the hands of the client, but any bank involved is compelled to require their customers to proceed with perhaps exorbitantly expensive soil or groundwater testing. The more tied-in the bank, the less control the client has, and the big ESA companies know this all too well. They are feasting off this financially, falling back on their role as the harbinger of doom if what they recommendation is not followed. We are fine with what is an obvious REC, but time and time again, they are listed with insufficient professional opinions/justifications. If you are a professional, you should be able to sort through the environmental risks, weigh them, and see the nuances. Some of the Phase I ESAs we’ve read have amounted to blunt trauma. It’s really impossible to properly do a Phase I ESA in 1.5 +/- days and get a good feel for the issues, no matter how big and efficient you are. Inexperienced people are gathering the information and higher-ups in other cities are calling the final shots, based on economic and risk-adverse company policies. At LAS, we own up to our responsibilities and don’t try to pawn off all the risk to our clients. What good are we if we can’t make a close call?