© 2012 Environmental Data Resources, Inc.

2014 DDD Tour

Agency File Review

Agenda

• Challenges associated with

performing agency file

reviews.

• Results of two surveys

2

What’s in them?

• Source files

• Other examples

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Details

• I’m doing a Phase I, and

can account for the closure

of four tanks. How many

were originally installed?

Page 4

Beyond the database report

• This is what was in the DB Report

Page 5

Details vs. DETAILS

• Two waste oil tanks

• 500 & 250 gallons

• Removed in ‘91

• Filled w/ sand & gravel

• Oversight by FD

• ESA performed

• No contamination observed

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Driver of Agency File Reviews

• As I think you will see from the survey, it’s best practice for

closing loops.

• It is a core ASTM 1527 data element, even before the 1527-

13 revision.

• That is why the task group included it as a clarification in the

ASTM 1527-13 standard.

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ASTM 1527-13

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Summary of 8.2.2

• Property or adjoining “hit” in any 8.2.1 database

• Agency files should be reviewed

• Subject to 8.1.1-7 (reasonably ascertainable, reasonable time

and cost)

• If not warranted, EP must explain

• Alternative sources

• Shall include summary of the information reviewed

• EP must comment on sufficiency

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Purpose

We wanted to learn, and communicate

to you, how the market utilizes this

practice, and the impact of the 1527-13

standard.

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Market Research

• Survey of EP’s.

• Calling campaign to all 50 state agencies to document

processes.

• ASTM task group participation.

• EP interviews

• Discussions with lenders

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Survey

• National: 335 total complete surveys PRE 1527-13

• 250 total surveys POST 1527-13

• CA DDD attendees

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When do you do it?

• When do they conduct them?

• 62% with the Phase I

• 31% afterwards

13

How far?

Available Online?

• I had to make an appointment 76%

• Hours are limited 37%

• 56% make copies

• 60% review and abstract

17

Once you’re there…

Subject or Adjacent?

• What are they looking for?

• Not subject property only

• Either subject property, or both TP and adjoining

18

19

How long does it take?

How do you charge for it?

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A lot of variability

• In reading the qualitative responses, a majority of the

respondents mention a very high variability in information

available, quality of information, access to information.

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• Operational

• Disparate

• No standardization

• Multiple programs

• Different accessibility

• Not to mention local

• Report templates

• Business

• Educating clients

• Fees

Challenges

23

Sample of CA Agencies

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CAL EPACALEPA, Dept. of Toxic SubstancesCalifornia Natural Resources AgencyCalifornia Spatial Information LibraryCentral Coast Region (3)Central Valley Region (5)County of SAC/HMDCounty of San DiegoDepartment of ConservationDepartment of Fish & GameDepartment of HealthDepartment of Toxic Substances ControlDepartment of Water ResourcesDept of Env. HealthLA CO Dept. of Public WorksLahontan Region (6)Los Angeles Region (4)North Coast Region (1)Office of Emergency ServicesOffice of Historic PreservationPublic Works, Waste ManagementSan Diego County Department of

Environmental HealthSan Diego Region (9)San Francisco Bay Region (2)San Jose Fire DepartmentSanta Ana Region (8)Solid Resources Eng. & Cons.SWRCBSWRCB, Aboveground Petroleum SSWRCB, Info Services BranchVictorville Branch Office (6)

CA DDD Attendees

• “Are you aware of the changes that E 1527-13 made

regarding AFR requirements?”

• 33% are NOT aware.

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CA DDD

Attendees

• “How often do you attempt to access agency files for Phase I

ESA projects?”

• 74% “always” do

• 92% “always” or “often”

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CA DDD

Attendees

• “Have your AFR practices changed since the publication of

ASTM 1527-13?”

• 83% “No, I did them before, and I do them now.”

• 15% “Yes, I am conducting AFR’s more now.”

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Have your AFR practices changed since the publication of ASTM E1527-13

No, I did them before and Ido agency file reviews now

Yes, I am conductingagency file reviews morefrequently now than i didbeforeYes, I didn’t do agency file reviews before but I do now

Yes, I'm doing agency filereviews less frequently nowthan I did before

Qualitative Results

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• We always did them for the site and nearby listings of

significant concern. Now we complete them for a lot more

adjoining properties.

• I've always conducted them, but I have been requesting more

files than usual for off-site properties.

• Yes, for adjoining properties. No change for Subject Property

• If sites of concern are identified within radii of concern to the

Subject Property, then we review the files.

• If there are indications of past investigations or assessment

and the client has not provided the documentation, file review

is a must.

• GeoTracker has made this easier, but lots of local CUPAs do

not put their information on line and a trip to the agency is

required (and often requires a change order)

Questions Lenders are asking EP

Firms

• “Remind me…are you completing AFR’s as a standard part of

the Phase I scope of work you conduct for me?”

• “Will completing a file review affect the TAT and price of my

Phase I?”

• “Should we be revising our scope of work to make it more

clear whether we expect AFR?”

• Regardless of the answers, they want to feel confident that

their EP partner has a rock solid understanding of the details

of the changes.

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NFA

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