Clients often ask me why the costs associated with preparing a Phase I ESA Report vary so widely among consultants. Since ASTM has specific requirements that must be adhered to, how can some EPs fulfill ASTM E1527 Standard requirements charging as little as $1,500 while others charge $3,500 for the same property? Clients are left wondering “is my Phase I ESA less valuable because I selected the lowest bid?”
As the 1527 Task Group wraps up proposed revisions to ASTM Standard E1527-05 (which will go to ballot in the near future), I have come to the conclusion that the majority of the proposed revisions to the Standard are the result of inconsistent work on the part of those claiming the title “Environmental Professional” (EP). Some are not adequately trained or do not have the experience to use and apply ASTM E1527-05 to meet AAI. Other EPs simply cut corners when preparing Phase I ESAs to reduce costs.
I have been a member of ASTM for several years now. During the recent meetings held in Anaheim last month, the general consensus of the ASTM E1527 Standard Task Group is that clarification of the terms “de minimis conditions” and “HRECs” is needed to bring about consistent use in Phase I ESA Reports. The new and improved language that has been suggested (which will be sent to ballot in the near future) is intended to correct industry-wide misunderstanding and misuse of the terms de minimis and HRECs. The intent is not to change the Environmental Professional’s current practice of identifying a condition and considering its impact on the property.
I recently read a Seattle Times article on the impact the Freedom of Information Act is having on public agencies in the Northwest, including city and county departments, the Department of Ecology, and the regional EPA office. Due to recurring budget cuts and employee layoffs, these agencies are unable to keep up with the growing demand for public records from both businesses and private parties. The enormity of the resulting production backlog is impacting the environmental due diligence world. How?
Do you know the difference between ASTM E 1527-05 limitations and limiting conditions? How about the difference between limitations and deviations? These terms can be easily confused, so let’s break them down and establish a general understanding.
The second ballot containing proposed revisions to the E1527-05 Standard was submitted to E.50.02 subcommittee members March 2, 2012. This ballot reflects new and revised language recommended by the E1527 Task Group in response to feedback
from the User and Producer communities generated by the August 2011 ballot. Some of the recent revisions were devised to address negative ballots and comments; others are a response to Focus Group recommendations to clarify E1527-05 language.
I just returned from the 3-day Environmental Bankers Association Meeting in Santa Fe. These semiannual meetings provide an opportunity for Phase I ESA Producers and Users to come together and discuss topics related to environmental due diligence, risk management, and current trends in the marketplace. It also is an occasion for the ASTM E1527 Task Group members at the Meeting to provide a summary of proposed revisions to the E1527 Standard, and relay recent updates. One area of revision that was a hot topic of discussion at the Meeting was Section 6 dealing with User responsibilities.
A shorter blog this time to announce a long-anticipated event: After months of meetings, discussions, and negotiations, the first ballot containing proposed revisions to the ASTM E1527 Standard Practice for Environmental Site Assessments has now been submitted for vote. This initial vote is the first step in a series of balloting that is part of the approval process involving related task group, subcommittee, and committee members.
The E1527 Task Group for Phase I just completed its semiannual meeting in Tampa, Florida with approximately 40 attendees from the User, Producer, and General Interest groups. The purpose of the meeting was to review the comments and negatives submitted following the first ballot that recently went out to Real Estate Assessment and Management Subcommittee members for a vote. The ballot contained proposed revisions to E1527, intended to strengthen and clarify E1527 requirements.
I just returned from the Semi-Annual ASTM E50 Committee Meetings in Anaheim, California, where the future of the E1527-05 Standard and possible revisions were discussed. I have to say that this meeting was one of the more productive and informative in my 9 years of participation as an active ASTM member. Among the approximately 40 members attending were Users, Producers, Attorneys, Regulatory Agencies, and General Interest groups, all of whom provided valuable input regarding the proposed changes. Hearing first-hand the opinions and needs of both the User and Producer communities was very beneficial.