Phase I ESAs: Becoming a Historian

April 5, 2024
2 min read
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One of the fun parts of doing Phase I Environmental Site Assessments is turning into a historian. The purpose of the historical records review is to identify a property's past operations to determine the likelihood of hazardous substances and/or petroleum products being used on site. For example, if our historical review determines there was previously a gas station, we have to assume there were underground storage tanks of gasoline and diesel, which weren't regulated as heavily as they are now. That's a problem.

But one of the more amusing things we have come across are the historical records provided by the various governmental agencies. Here are a few examples of some things we've encountered during our reviews…

  • A complaint from 1987 of a concerned neighbor who found a "dead pig" in the nearby creek and was concerned the pig died from drinking the water and is contaminating the creek.

  • A letter from a frustrated resident to a New Jersey township planning board regarding a proposed subdivision application in 1980. "There is something definitely wrong with our new Planning Board procedures in comparison with the ones I knew years ago. A small legal defect or an interpretation by an engineer seems to kill the whole deal for at least another month, if not longer." "One of my major problems has been receiving a multi-page detailed letter the day before or the night of a meeting…" Hmmm… sounds familiar.

  • A letter from 1978 written by an unhappy resident who doesn't like seeing a fire-destroyed building on his way to work stating, "I drive by this abortion every day and can't believe a first-class Township, I believe Whitemarsh to be, has allowed this condition to exist for almost two years."

  • The West Whiteland Township Zoning Hearing Board denial decision from 1986 for a special exception application and hearing where no one from the applicant's team showed up. The Township officials reviewed the application while waiting for the applicant to arrive. Only then did they realize that the zoning change they adopted after the date of the submitted application no longer allowed for special exception uses in that district… in other words, they held a hearing to make a decision on something they had no authority to make a decision on because they changed the zoning ordinance before the hearing.

Let this serve as a reminder that written correspondence with governmental agencies is public record. I also found this weird plastic square during one of my file reviews. Does anyone know what it is?


West Chester

1250 Wrights Lane
West Chester, PA 19380

Phone: 610-918-9002
Fax: 610-918-9003


5020 Ritter Road #203 Mechanicsburg, PA 17055

A Howell Company

53 Old Solomons Island Rd. Suite I
Annapolis, MD 21401

Phone: 410-266-1160

A Howell Company

1250 Wrights Lane
West Chester, PA 19380

Phone: 610-692-7007

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