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Straightforward requirement…
This prerequisite is very easy for most projects to achieve. It simply requires that you evaluate your site for potential contamination by performing a Phase I Environmental Site Assessment (ESA).
The Phase I ESA involves a site visit by a trained professional, who will conduct interviews and examine historical uses of the property. While this kind of assessment is not standard practice everywhere, it’s becoming more common—some commercial real estate lenders may even require it.
…But things can get complicated
Things can get significantly more complicated if the Phase I ESA finds reason to believe that the site may have been contaminated by previous uses—an especially likely scenario for projects located on or near the sites of old gas stations, laundromats and...
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20 Comments
Documentation of Remediation
We have a site we know to be contaminated and we are undertaking a remediation plan. In the LEED Reference Guide under SSp2-Documentation it says that documentation is required from the governing authority stating that remediation standards have been met. In the LEED Online Template they request documentation from either the environmental consultant or a governing authority. We would prefer to use documentation from our environmental consultant. Has anyone submitted without documentation from a governing authority?
Laura, I would go with what they ask for on the LEED Online form—GBCI can't argue with that. It's a V4 form so they've had plenty of time to edit it.
Phase I for an Existing School
Do we need a formal Phase I assessment for a school remodeling project (major renovation)? The school site was a greenfield site when it was originally constructed approximately 50 years ago. Thanks for any help, insights or advice.
John,
LEED 2009 for Schools New Construction and Major Renovations mandates compliance with the prerequisite SSp2: Environmental Site Assessment and would therefore require conducting a Phase I Environmental Site Assessment.
Timeline for Site Assessment
Does LEED 2009 require that the site assessment be performed within so many years of project construction? We have a project building starting construction this year, however, the site assessment was performed in late 2005.
Just on the face value of the information you’ve provided, I doubt LEED would accept the existing ESA. Six years is way too long for any ESA to remain valid, given the facts a Phase I requires a visual inspection of the property, including walking over the entire site, a comprehensive photographic log and interviews with the owner/manager/user of all adjacent properties. Additionally, it’s difficult to get lending institutions to accept a Phase I that is over 12 months old. You would be well advised to have an environmental expert "refresh" the existing 2005 report.
Phase II
If your project finds contamination on site during construction, does remediation have to be complete before the LEED design application can be submitted?
You need a narrative thoroughly explaining the type of contamination and the plans for remediation. It does not need to be completed. That's the way it was interpreted under NC v2.2 and I don't see anything in the 2009 RG or LOL form to indicate a change.
Elizabeth,
Although 2009 LEED for Schools prefers SSp2 be addressed at the “Design Review” phase, it doesn’t have to. The Design Review language specifically states “…enables project teams to assess the likelihood of achievement for some or all design-phase credits and/or prerequisites, prior to substantial project completion”. Also, the rating system permits a “Combined Review”, which means all documentation is submitted AFTER construction. If you haven’t yet submitted, just upload documentation from your environmental consultant describing the contamination, the remedial action planned and a schedule for the cleanup. If you have already submitted the “Design Review”, just cover it in the “Construction Review” phase. On occasion the location of the contamination identified is remote from the construction area and remediation is done simultaneously with the construction. In the end, LEED wants to know that the intent and requirement of credits/prerequisites have been met.
Thank you Michelle and Larry. We are just beginning the construction process, and are about to submit our design submittal. Your advice is most appreciated.
SPP2 says that If a site is contaminated, it must be remediated to meet local, state, or federal EPA region residential (unrestricted) standards, whichever is most stringent.
Do they really mean remediated or are engineering controls (such as barriers to dermal contact with soil) acceptable, if the local enforcing agency (state DEQ/DEP) finds them acceptable? This is an important distinction as the cost difference can be very significant (dig and haul to a landfill vs. encapsulation and O&M). The engineered barrier is in the final analysis the best solution, especially when in situ remediation is not practical.
Much thanks ...
Donald,
Engineering controls, such as encapsulating asbestos of laying asphalt over contaminated soils is acceptable. The intent in these instances is to remove the source from direct human contact.
Thanks for your quick response, Larry. I thought that had to be the case as the alternative seemed unreasonble.
Uploading Phase II ESA report - where?
In the online template, when I select the Option for utilizing a Phase II ESA report, it prompts me to upload info from the Phase II report. However, when I go to upload the document, it does not have a designated area for the Phase II report - only the Phase I (along with other specific possible documents to upload). Has anyone dealt with this yet?
I see the same thing you see on LEED Online.
I would either a) send a feedback question via LEED Online, or b) upload it into one of the other slots, like the alt compliance path slot, and include a note in the alt compliance path narrative area about why you did that, or c) don't worry about it -- if they don't ask for it, assume they don't want it. Or d) some combination of a through c.
They definitely want it uploaded. I uploaded it in the Phase I section (it is the closest to the intended compliance route) and will follow up with a question. Once I get an answer, I'll let you know.
Alternative standards
Does anyone know - can California's Preliminary Environmental Assessment (PEA) and Supplemental Site Investigation (SSI) stand in for the ASTMVoluntary standards development organization which creates source technical standards for materials, products, systems, and services Phase I and Phase II Environmental Site Assessments? The LEED for Schools RG and the credit language do not appear to allow for any equivalencies.
Martin,
Although SSp2 lists ASTMVoluntary standards development organization which creates source technical standards for materials, products, systems, and services Phase I and Phase II ESA in the requirements, CIRs have generally given allowances for alternatives as long as they meet the intent of the credit. For instance, a CIR issued on 07/10/2006 ruled, in part: “The geotechnical assessment as performed essentially meets the objectives of a Phase II Environmental Site Assessment…”. Given the fact that California’s environmental regulations are some of the most stringent in the nation, I could not foresee LEED mounting any challenge to this. LEED respects California standards as witnessed by their deferring to California’s testing procedures for VOCs1. Volatile organic compounds (VOCs) are carbon compounds that participate in atmospheric photochemical reactions (excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides and carbonates, and ammonium carbonate). The compounds vaporize (become a gas) at normal room temperatures. 2. A molecule containing one or more carbon atoms that tends to evaporate (volatilize) into the air at typical ambient conditions. Some legal definitions of VOCs are restricted to those that react with sunlight to generate smog. Some VOCs are carcinogens, suspected carcinogens, or known irritants at typical levels. on School projects. The website linked below refers to a 2009 DTSC proposed analysis at a school site under consideration. As described in the article, I would suspect that LEED would readily accept this.
http://www.ci.hercules.ca.us/index.aspx?page=23&recordid=173
International Projects - Environmental Site Assesment
In Germany, the law dictates an ESA, but the assessment is done according to Local norms and legislation and the qualifications of assessors is deturmined also by Local norms and legislation.
"The Phase I ESA must be in compliance with ASTMVoluntary standards development organization which creates source technical standards for materials, products, systems, and services Standard E1527-05. This standard also defines the qualifications of the environmental professional who conducts the assessment. "
I don't have this standard, yet. Could some please elaborate as to what the qualifications are, because I would attempt to submit the site assesment in German together with a translation to fullfill this prerequisite by including an additional section to show that the assessment meets the requirements of the American Standard.
I hope someone else might have more insight, but I don't know the details of the ASTMVoluntary standards development organization which creates source technical standards for materials, products, systems, and services standard, nor did a LEED consultant I checked with. In the U.S. we don't normally need to be familiar with the details of it.
You might check this Phase I ESA blog site, which has some more in-depth knowledge.
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