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Records Search with Risk Assessment (RSRA)

May 12, 2022

A Records Search with Risk Assessment (RSRA), sometimes called a Desktop Review, is one of several products that Envirologic offers to help our clients meet their specific environmental due diligence needs. Alternatives to a RSRA include a Phase I Environmental Site Assessment (ESA) and an Environmental Transaction Screen, both of which offer different advantages.

The level of necessary due diligence for a project financed by a lending agency is often dependent on the requirements of the agency. Most agencies will require a Phase I ESA to fulfill their due diligence requirements. The purpose of a Phase I ESA is to assess the current and historical uses of a site and the surrounding properties and to determine the presence or potential presence of environmental contamination on site. Specific Phase I ESA activities include conducting reviews of available historical information such as city directories, aerial photographs, fire insurance maps, topographic maps, and plat maps; requesting/obtaining records from federal, state, and local governmental agencies (e.g., assessing, building departments, health department, public works, and government officials with knowledge of the property); and completing a reconnaissance of the property and associated structures. These various lines of evidence are utilized to form a conclusion regarding the identification of recognized environmental conditions (RECs), which represent concerns for environmental impacts to the site.

For certain projects, however, a RSRA, which is less comprehensive than a Phase I ESA, may be adequate to fulfill environmental due diligence requirements. A RSRA involves completing only select components of a Phase I ESA. While not compliant with the U.S. EPA’s Brownfield guidance regarding All Appropriate Inquiry (AAI), the U.S. Small Business Administration (SBA) may accept a RSRA over a Phase I ESA if the property is not defined as an “Environmentally Sensitive Industry” by the North American Industry Classification System (NAICS). A RSRA includes a basic review of government records associated with the property and nearby properties, along with a review of available historical and physical setting information. The completion of a RSRA will conclude with one of two findings: either the property is of low environmental risk or it is of elevated environmental risk. In accordance with SBA guidance, no further assessment of the property would be recommended for a property of low environmental risk.

A RSRA may be an efficient and cost-effective way to satisfy your environmental due diligence requirements, particularly for SBA loan projects deemed to be of low environmental risk. The completion of a RSRA costs less than a traditional Phase I ESA, and it can be completed in days, rather than the weeks it takes for a Phase I ESA. Envirologic’s staff approaches projects with the end in mind, implementing the appropriate scope of environmental assessment (whether that be a RSRA, Phase I ESA, or another method of assessment) to meet the client’s needs, ensure an efficient due diligence process, and support the overall project timeline.

If you have questions regarding Envirologic’s due diligence services or whether a RSRA could be utilized for your site assessment project, please contact our Manager of Due Diligence Services, Erik Peterson, by phone at (800) 272-7802 or by email.

 

Posted in Blog, Due Diligence

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