Much energy has been expended in this community in bemoaning the low prices of Phase I Environmental Site Assessments. No doubt we have seen prices drop during the great recession. Much of my practice is spent working for clients who are price sensitive, but I also have as many clients that are more concerned about quality!
Value for value
Look, we are consultants and we more or less sell or time. If a $2,000 Phase I ESA includes 20 hours of staff time (for easy math, often it is much more than that for the same price), then you get 30 hours for a $3,000 Phase I ESA. What can we do for you in those extra 10 hours? What can we do for you in 50 hours? I think we as an industry need to communicate the value for paying more.
Don’t get me wrong, I believe that the standard ASTM E1527 Phase I ESA is a good value—especially the type of Phase I ESA generally produced by an EBA firm. Never the less, ASTM E1527 is a flexible document and if we put our mind to it we can do more.
What can we give our clients in a $5,000 Phase I ESA? Here are a few things that are above and beyond a standard ASTM E1527 Phase I ESA:
Business Environmental Risks: Certainly non-scope items that are left out of a standard ASTM Phase I could be included in the $5,000 Phase I, such as asbestos or lead sampling, compliance review, etc. This requires good discussion with the client and preliminary knowledge of the subject site ahead of time to know what potential risks to evaluate.
Better Aerials: The number and quality of aerials we get for each Phase I Environmental Site Assessment is highly dependent on what is reasonably ascertainable within budget and time constraints. Much of the industry orders digital aerials from a data provider. A fine set of aerials and generally acceptable quality, but not always the best source for a particular area. There are many local aerial companies, public libraries or local government offices with aerials around the country that will allow you to see the actual photographs (not copies or scans) which can yield better clarity. However, often the subject property is nowhere near the local source, or there are multiple possible sources with different sets available, which can render the additional time and cost to obtain them unrealistic unless you have a healthy budget.
Often the local sources can facilitate a 3D aerial review using a stereoscope. The difference can be substantial. Occasionally we find ourselves huddled around a computer screen staring at a dark gray smudge on an aerial asking each other if this smudge represents a recognized environmental condition.
One of my employees once secured an engagement for $15k to do a review of aerial photographs for a contaminated site. And he delivered commensurate value as he poured a great deal of time analyzing aerials from multiple sources. He analyzed every quadrant of the site via a stereoscope. My point is we can deliver more when the client is willing to pay for higher value.
Review All Possible Historical Records: ASTM allows flexibility in what records to review and rightly so. Environmental professionals can choose historical records that yield the best bang for the buck and skip less useful records such as historical topographic maps, or Sanborns in a very rural area. My $5,000 Phase I ESA clients can expect that we gather 100% of useful data, including historical topographic maps, data from local historical societies, etc.
More Interviews: Interviews are an underestimated resource. A couple interviews are standard in a good Phase I ESA when there is adequate cooperation. But if you want to go beyond the industry standard, interview 10 people. Yes, 10 people. Interview the tenants, the owner, the property manager, past owners and tenants (often difficult and time consuming to track down), the neighbors, waste haulers, city officials and regulators (above and beyond standard local agency interviews), and maybe even the town historian. Multiple interviews on the same subject can be interesting especially if you get different answers.
Experienced Registered Professionals: A lot of our work is reviewed by an RG or a PE. Some clients require it. Go a step further and require the RG or PE do the site visit. Having a 15-year registered professional doing the site visit is no doubt beyond what is required by ASTM (ASTM is rather week on this subject, contributing to commoditization), but a trained eye can have great value on a really complicated site. You may even consider sending two professionals, an environmental professional and in industrial hygienist; or an EP and a younger staff member to do a tedious tasks such as inventorying drums.
Our survey on errors in Phase I ESA revealed that two of the top five reasons for errors in Phase I ESAs were due to weak inspectors.
File Reviews: Are regulatory file reviews part of ASTM E1527? There was much debate on the subject at the EDR client summit. Is the fee paid relevant to the answer to this question? What if the site is in Dallas, Texas and the file is at the TCEQ in Austin, Texas (4 hour drive). If the client gives us an appropriately large fee and four weeks to do the project, then a file review is clearly reasonably ascertainable.
Constantly talking about some ridiculously low fee becomes a destructive mantra. Instead encourage clients to specify a scope of work that goes beyond ASTM and understand that the fee will move up accordingly. Of course, you don’t have to do $5,000 Phase I Environmental Site Assessments to push the limit on quality. Ask our clients to commit to paying between $2,500 and $3,000 and then deliver reports that go beyond ASTM.