Environmental site assessments are a standard part of most environmental due diligence activities during real estate or property transactions. GEC provides a wide range of environmental due diligence investigations and site assessment services including the identification of recognized environmental conditions for US EPA’s All Appropriate Inquiry Rule (40 C.F.R. § 312.20) and ASTM investigations. GEC’s investigations range from single property transactions to acquisitions involving hundreds of properties, and from large undeveloped woodland tracts to industrial complexes.
Environmental site assessments are a standard part of nearly all real estate due diligence, including refinancing, purchase/sale, or insurance. GEC designs and implements site assessments to evaluate whether a release of oil and/or hazardous materials (OHM) exists. We conduct assessments for financial institutions, manufacturers, real estate trusts, industry, state agencies, and homeowners on properties throughout New England and across the United States.
Our site assessments include the following:
- All Appropriate Inquiry (AAI) assessments AAI/ASTM E1527-13 Phase I Environmental Site Assessment,
- ASTM E1527-13 Phase I Environmental Site Assessment,
- ASTM E1528-14 Environmental Transaction Screenings, and
- Limited subsurface investigations (ASTM Level Two site assessment) customized with site-specific conditions in mind to deliver cost-effective solutions that meet regulatory requirements and client needs.
GEC has completed numerous 21E Environmental Site Assessments, also known as Phase I Environmental Site Assessments for lenders, investors, government agencies, developers and borrowers. Phase I Environmental Site Assessments are a standard part of due diligence in nearly all real estate transactions, including purchase/sale, refinancing, stock transfer or insuring of property. GEC can handle and develop an appropriate scope of work for both simple and complex Phase I Site Assessments and can tailor these assessments to the issues at hand and needs of the client. GEC has developed an efficient approach to Phase I Environmental Site Assessments which allows us to complete extensive Phase I Reports at competitive rates. In addition to Phase I Environmental Site Assessments, GEC can complete Phase I Environmental Site Assessment Updates if provided with a Phase I Environmental Site Assessment completed within the last year that meets the ASTM E1527-13 Standard. GEC’s Phase I Site Assessments are completed in accordance with US EPA’s All Appropriate Inquiry Rule (40 C.F.R. § 312.20) and the ASTM E1527-13 Standard.
GEC has vast experience in conducting environmental due diligence and environmental assessments to support real estate transactions. A Transaction Screen offers a standardized approach to limited environmental due diligence (less than a Phase I Environmental Site Assessment), and is intended primarily as a commercially prudent or reasonable approach to identify potential environmental concerns. If the driving force behind the environmental due diligence is a desire to qualify for one of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Landowner Liability Protections (LLPs), this practice should not be applied, and instead a Phase I Site Assessment should be conducted. Transaction Screens can be completed quickly and cost effectively. Transaction Screens are completed in accordance with the ASTEM E1528-14 Standard.
Limited Subsurface Investigations
When the findings of a Site Assessment identify Recognized Environmental Conditions (RECs) or potential environmental concerns, or your environmental due diligence goes beyond a Site Assessment, GEC can develop a Limited Subsurface Investigation to determine if potential contamination and/or oil and/or hazardous materials (OHM) are present. The presence of contamination could pose a liability to the property owner, operator or other party who may have a financial or regulatory responsibility. GEC provides quick-turnaround, high-quality Limited Subsurface Investigations to provide critical environmental information to property owners and potential buyers alike. During the Limited Subsurface Investigation, Recognized Environmental Conditions (RECs) identified in Phase I Environmental Site Assessment are assessed through the collection of subsurface samples for analytical analysis. Analytical data results are compared to state standards in order to assess conditions at the property and determine whether or not further assessment activities or remedial action is warranted or if a reportable condition exists.
GEC’s client, a scrap metal recycler, faced a citizen suit under the Clean Water Act for alleged stormwater non-compliance. GEC evaluated the operation, determined the applicability of the regulations, responded to the notification, filed for permit coverage, and developed a written stormwater pollution prevention plan (SW3P), with including best management practices, facility inspections, employee training and benchmark sampling to achieve compliance. Then, GEC designed engineering controls to collect and treat stormwater that enabled us to notify the EPA, on behalf of our client, informing them that our client was no longer subject to this regulation, saving thousands in ongoing compliance costs.
GEC consulted with both our client’s business and environmental attorneys to develop a mutually agreeable Consent Agreement and a plan for sustainable compliance, thus helping our client get into compliance, develop cost-effective engineering solutions, and avoid protracted litigation.