The most common way to clear a Recognized Environmental Condition (REC) from a Phase I Environmental Study is to complete a Phase II Environmental Study. The results will answer with hard science, if the REC is a concern and if it needs to be further remediated.
What is a REC?
A REC is basically an official warning that something the environmental professional found while performing the Phase I ESA is a risk which may be negatively affecting the value of commercial real estate.
What is the criteria of a REC?
The Environmental Professional completing the Phase I ESA has to decide whether the presence or likely presence of any hazardous substances or petroleum products in, on or at a property should be considered a REC. Typically three scenarios help make this decision: 1) a known release to the environment has occurred, 2) conditions exist at the property that indicate a release to the environment, and 3) conditions exist that pose a material threat of a future release to the environment.
A Phase I Environmental Study may also identify other Recognized Environmental Conditions.
In 2013, the ASTM Phase I ESA Standard was updated to E1527-13 which includes what can be more accurately called, ‘PAST’ Recognized Environmental Conditions. These past RECs are categorized as Historical Recognized Environmental Conditions (HRECs) and Controlled Recognized Environmental Conditions.
Unlike RECs, HRECs and CRECs do not require any additional investigation. They are known conditions identified at a property that have been either remediated or ‘cleared’ from further investigation, but may require continued controls to prevent further harm to the environment.
What is a HREC?
A Historical Recognized Environmental Condition (HREC) is defined by the ASTM Phase I Environmental Study Standard E1527-13 as a past release of hazardous substances or petroleum products that occurred in connection with the property but has been addressed to the satisfaction of an applicable regulatory authority or meeting unrestricted use by the regulatory authority without requiring any controls on the property. In order for a past REC to be considered an HREC, a confirmed release must have been identified. In other words, an aboveground storage tank that was formerly located at the property, that was decommissioned and removed but never had a release cannot be identified as an HREC.
What is a CREC?
A Controlled Recognized Environmental Condition (CREC) is defined by the ASTM Phase I Environmental Study Standard E1527 – 13 as a past release of hazardous substances or petroleum products that occurred in connection with the property but has been addressed to the satisfaction of an applicable regulatory authority through issuance of a No Further Action/Remediation letter or equivalent, or meeting risk-based criteria established by the regulatory authority. However, the use of controls, such property use restrictions, engineering controls or institutional controls, are required to allow hazardous substances and petroleum products to remain in place at the property.
If you need a Phase I ESA or a Phase II ESA on your property or one you are interested in purchasing, give A3 Environmental Consultants a call. We’ll work to get your Environmental REC removed with the utmost in confidentiality, we’ll meet or exceed ASTM Standard E1527-13 on any sort of commercial or industrial property. Our reports meet the requirements of all lenders and government agencies such as the Small Business Administration (SBA), Housing and Urban Development (HUD) and the United States Department of Agriculture (USDA). A3 Environmental Consultants can be reached at (888) 405-1742 or by email at Info@A3E.com.
