In this final post on E2247-16, we are going to highlight some other differences between E2247-16 and E1527-21. ASTM made a number of changes from E1527-13 in E1527-21 on definitions, historical sources and other items. We likely will see similar changes in an updated version of E2247 when it is issued by ASTM. There are a couple of other differences though worth noting that will likely remain when E2247-16 is updated to a new version by ASTM:
Other Historical Sources–The term “other historical resources” is defined in Section 8.3.4.9 of E1527-21 tomeans a resource or resources other than standard historic resources (aerial photographs, fire insurance maps, local street directories and topographic maps) or additional standard historic resources (building department records, interviews, property tax files and zoning/land use records) “that are credible to a reasonable person and that identify past uses of properties. This category includes, but is not limited to: miscellaneous maps, news articles, books about the history of the area being researched, imagery, land title records, and a variety of other resources that may provide information about past land uses. These other resources may be found in sources such as prior assessments…, newspaper archives, internet sites, community organizations, local libraries, historical societies, government agencies, current owners or occupants of surrounding properties, or records in the files and/or personal knowledge of owners and/or occupants.” ASTM may update the E2247 to follow a similar sequence on reviewing the standard historic resources, but then may deviate as other historic resources are listed. Because of the nature of forestland and rural properties, E2247-16 includes “mineral, oil and gas development maps” and “livestock dipping vats records” which would not ordinarily be reviewed for a typical Phase I for a commercial or industrial site Phase I under E1527-21. Livestock dipping was a practice where there were vats of substances containing arsenic or other contaminants used to remove ticks that caused Cattle Tick Fever.
Interviews—Among the required interviews under E1527-21 is the “key site manager” who is “person with good knowledge of the uses and physical characteristics of the subject property (the key site manager). Often the key site manager will be a property manager, the chief physical plant supervisor, or head maintenance person.” The key site manager interview is likewise required under E2247-16 but is defined differently due to the nature of the larger properties that are assessed under E2247-16: “Often the key site manager will be the property manager, farm manager, ranch manager, timber or natural resource manager, the chief physical plant supervisor, or head maintenance person.” E2247-16 further notes that there may be multiple key site managers for larger properties and that each may only have knowledge of a portion of the property.
As noted in our previous posts (Parts 1 and 2), the primary differences between E1527-21 and E2247-16 are when E2247-16 may be used and the approach to site reconnaissance necessitated by the size of the sites being assessed under E2247-16. The environmental professional and user need to consider these differences as well as the other less significant differences when using E2247-16 and any successor standard.
We plan to have a series of posts on the revised E2247 when issued by ASTM in the future.