The Importance of Evaluating a Property’s Historical Uses during Environmental Due Diligence

By: Brianna Sadoski

Evaluating a property’s historical uses is a key step in identifying potential issues and liabilities during environmental due diligence investigations. Consulting multiple historical sources can assist in developing a history of the previous uses of the subject property and surrounding properties to determine the likelihood of past uses having lead to recognized environmental conditions (RECs) in connection with the subject property.

The ASTM E1527-13 Standard for Phase I ESAs indicates all obvious uses of the property shall be identified from the present, back to the property’s first developed use, or back to 1940, whichever is earlier. The task requires reviewing only as many of the standard historical sources as are necessary, and both reasonably ascertainable and likely to be useful. Standard historical sources typically include:

  • Sanborn Fire Insurance Maps: Detailed maps of U.S. cities and towns in the 19th and 20th centuries. These maps show intricate details in buildings, properties, and streets, and can assist in identifying former property uses of the subject property and surrounding area and historical storage tanks.
  • Historical Aerial Photographs: Assist in determining past property development, locations of old buildings, roads and equipment, past conditions of vegetation, and other features.
  • Historical Topographic Maps: Essential for evaluating historical topographic characteristics of a property and historical development on a property.
  • City Directories: Listing of property occupants that can assist in identifying past uses of subject property and surrounding properties.

These resources are typically obtained through a third-party vendor and reviewed collectively to observe as much of an area’s past as possible to develop a historical understanding of a property. Additionally, some publicly available information including Property Tax Files (typically available through the county) and Town/City Building Department Records often provide additional useful information including date of improvements on a property, property alterations, or property sale/transactions.

When reasonably ascertainable, it is important to attempt to obtain and review one historical resource for every five years since property development. Potential RECs that may be identified in connection with a property’s history may include:

  • Historical occupancy of a filling station, dry cleaner, chemical plant, manufacturing plant, etc.
  • Historical use of adjacent properties as filling stations, dry cleaners, chemical plants, manufacturing plants, etc.
  • Historical presence of storage tanks, or material storage (e.g., drums, disabled vehicles) on the subject property
  • Stained surfaces or stressed vegetation observed on a historical aerial photograph
  • Former presence of ponds or areas that have been filled in over time

Understanding a property or general area’s history is often a key tool in completing additional portions of the environmental due diligence process, from interpreting database report results, to completing a reconnaissance of a property, and interviewing past and present property owners.

For more information on how EHS Support can help you manage corporate environmental liability, please contact Brianna Sadoski at 631-972-8623 and brianna.sadoski@ehs-support.com  or Bruce Martin at 703-944-4709 and bruce.martin@ehs-support.com.

 

Brianna SadoskiABOUT THE AUTHOR Brianna Sadoski has over five years of hands-on experience in the environmental consulting industry. Her experience includes environmental due diligence including the preparation of Phase I and II Environmental Site Assessments (ESAs) on commercial, residential and industrial properties, the development and implementation of Remedial Action Plans and Stormwater Pollution Prevention Plans, and extensive research and analytical investigation associated with Environmental Impact Assessments. She is proficient in the use of mapping programs including ArcGIS and AutoCAD and has been responsible for the preparation of various informational maps and figures supporting analytical reports….. Read More
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