Skipping a Phase 1 ESA and going directly into a Phase 2.
Updated: Mar 23
Pitfalls to skipping the Phase 1 ESA and going straight to a Phase 2, instead.
When we receive calls asking for a Phase II Environmental Site Assessment without first having conducted a Phase I, it's usually because people think the property is already contaminated, so they want to save time by skipping the Phase I. We would explain to them, however, that they would be taking a risk if they were to omit the Phase I, as it could lead to them leaving out essential data and information which would influence the testing performed in the Phase II. Additionally, this would mean they were not conducting their due diligence required to qualify for clean-up costs covered by Superfund (CERCLA, Comprehensive Environmental Response, Compensation, & Liability Act, www.epa.gov). Furthermore, omitting a Phase 1 ESA could result in not detecting a neighboring property which was contaminated and extending their contamination plume onto the subject property. As such, a Phase 1 ESA is essential as it is an in-depth examination of not just the subject property, but also the surrounding ones. It may even be possible to save time and money if a Phase 1 ESA is conducted first. If the results of the site inspection and records research don't suggest an imminent risk, then a Phase II may not be recommended. Thus, why invest $10K-$15K on a Phase II plus added weeks to due diligence if it is not necessary? .