Sagua Consulting

Phase I Environmental Site Assessments

A Phase I Environmental Site Assessment identifies recognized environmental conditions at a property through non-intrusive means — records, observation, and interviews. No sampling is performed. Conducted properly, it satisfies the All Appropriate Inquiries rule at 40 CFR Part 312, which underpins the innocent landowner, bona fide prospective purchaser, and contiguous property owner defenses to CERCLA liability.

Sagua conducts every assessment in accordance with ASTM E1527-21, the standard EPA recognizes as compliant with AAI.

Approximate ASTM search radii around the subject property 0.5 MI 1.0 MI
  • Property & adjoining — institutional controls, RCRA generators, ERNS.
  • 0.5 mile — RCRA TSD facilities, delisted NPL, CERCLIS, LUST, landfills.
  • 1.0 mile — NPL sites, RCRA CORRACTS facilities.

Scope of work

Records review. Federal, tribal, state, and local environmental records within the search distances the standard prescribes, together with a search for recorded environmental cleanup liens and activity and use limitations.

Historical research. Fire insurance maps, historical aerial photography, city directories, topographic maps, and property records — developed for the subject property and adjoining properties back to first developed use or 1940, whichever is earlier.

Site reconnaissance. Visual inspection of the property and adjoining properties, documenting current and historical uses, storage practices, staining, containers, and other conditions bearing on the assessment.

Interviews. Current and past owners, operators, and occupants, along with local government officials where relevant. Conducted in English, Spanish, Russian, or German as the property requires.

Evaluation. The Environmental Professional's analysis of everything gathered, and the opinion the standard requires.

What you receive

An executive summary written to stand on its own. Findings organized as recognized environmental conditions, historical RECs, controlled RECs, and de minimis conditions — each classification reasoned rather than asserted. Identified data gaps and an explanation of their significance. Photographic documentation of observed conditions. Supporting appendices covering the database report, historical sources, and interview records. And the Environmental Professional's signed declaration and qualifications statement.

Continued viability

Phase I ESAs do not stay current indefinitely. Five components — the government records review, the environmental lien search, the site reconnaissance, the interviews, and the Environmental Professional's declaration — must be conducted or updated within 180 days of acquisition. The report as a whole remains viable for one year, after which a new assessment is required. Every Sagua report identifies the applicable dates, so there is no ambiguity about when individual components require updating or when a new assessment becomes necessary.