Appendix 6D: Criteria for Combined ESA and GEPA Evaluations
Board of Regents Criteria for Combined Environmental Site Assessments (ESA) and Georgia Environmental Policy Act (GEPA) Evaluations
Combined ESA/GEPA Evaluation Criteria:
This procedure shall be used for Board of Regents projects where it is necessary to complete both the environmental site assessment (ESA) and the Georgia Environmental Policy Act (GEPA) evaluation at the same time. Typically, the ESA should be completed during the preliminary planning or programming phase of the project and the GEPA evaluation should be completed during the schematic design phase. However, due to individual project circumstances it may become necessary to combine these evaluations. A Board of Regents (BOR) ESA and GEPA Evaluation has two goals. First, the ESA segment of the evaluation shall identify any recognized environmental conditions which previously existed or currently exist at the subject property which may cause the BOR concern and/or which may preclude development of the site. Second, the GEPA segment of the evaluation shall consider potential adverse impacts associated with the planned development/construction activities for the site (this includes pre-existing conditions as well as the conditions anticipated during site development or construction.). Consultants are cautioned to be aware that this criteria exceeds the basic requirements of most "standard" ESAs and that it may be necessary to visit the subject property or to discuss site-specific issues with knowledgeable personnel prior to submitting a proposal.
Scope of Required Services / Consultant Requirements:
- The selected environmental consulting/engineering firm (Consultant) shall have demonstrated experience in completing similar-scope assessments and shall have at least one principle, with project oversight and report review (sign-off) responsibilities, who is certified and/or registered in one of the following disciplines:
- Professional Engineer (PE)
- Certified Industrial Hygienist (CIH)
- Professional Geologist (PG)
- The ESA segment of the combined evaluation shall, at a minimum, meet the requirements of the American Society for Testing and Materials (ASTM) standard E1527-94 "Standard Practice for Environmental Site Assessments."
- In addition to the minimum requirements referenced in ASTM E1527-94, the ESA segment of the combined evaluation shall also include detailed assessment of other potential environmental/property conditions as outlined below:
- Asbestos-Containing Materials,
- Lead-Based Paint (or other lead contamination),
- Soil and/or Groundwater Contamination
- Solid Waste (buried waste/landfills).
- Archaeological Sites/Artifacts
- The ESA segment of the combined evaluation shall also include abatement recommendations and cost estimates for hazardous materials such as asbestos or other hazardous materials or for remediation of soil or groundwater contamination (if there is compelling or obvious evidence that such contaminants may exist at the site). Any such abatement/remediation recommendations and cost estimates shall be based on the collection and analysis of a scientifically and legally defensible number of samples from the subject property. NOTE: All proposed sampling plans shall be approved by the BOR Director of Environmental Affairs and/or the Institution's designated representative prior to proposal acceptance. Building material and soil and groundwater samples shall not be collected if there is no compelling or obvious reason to believe such concerns exist at the site. If a sampling plan is approved for the project, the price for the collection and laboratory analysis of any planned samples must be included in the Consultant's lump-sum, not-to-exceed proposal. Broad consultant disclaimers regarding characterization of building materials, soil or groundwater contamination and remediation cost estimates shall not be acceptable for BOR combined ESA/GEPA evaluations.
- The ESA segment of the combined evaluation shall identify whether abandoned (or recently active) solid waste disposal sites exist on (or are buried beneath) the subject property. The consultant shall obtain this information through personnel interviews, site inspection, aerial photos or regulatory permits/applications. It test pits are necessary to determine the possible existence of solid waste at the site, the consultant shall either arrange for the institution to provide suitable excavation equipment (track-hoe, hand-auger, etc.) or shall include the cost for equipment rental in their lump-sum, not-to-exceed proposal.
- Archaeological site and historical resource information shall be obtained through review of the Georgia Archaeological Site Files at the UGA library in Athens, GA (706) 542-8737, through consultation with the State Department of Natural Resources Historic Preservation Office (404) 656-2840, review of previously published reports and/or interviews with archaeologists and historic preservationists involved in research in the general area. The Consultant shall also be responsible for identifying and clearly delineating any human burial sites that may be present of the subject property. In addition, where potential sites of archaeological significance or human burial may be present, more detailed site investigation and/or testing may be necessary. In such cases, the Consultant shall include a cost proposal for such an investigation in the final combined report.
- The Consultant shall be required to determine whether any potential wetlands exist on the subject property. If wetlands exist, the Consultant shall be required to provide a site map clearly delineating the boundaries of the wetland(s) and shall recommend an appropriate strategy based on the proposed plans for development of the site.
- The GEPA segment of the combined evaluation shall consider the history and the current status of the subject property as it relates to the BOR proposed plans for site development and/or construction. Therefore, it will be necessary to discuss proposed plans with the designated BOR program manager, the project designer, and the appropriate representative(s) of the institution. At a minimum, the GEPA segment of the combined evaluation shall address and report on potential environmental impacts regarding the following issues:*
- Floodplain/River Corridors
- Water Supply
- Water Resources
- Groundwater Recharge Areas
- Stormwater Runoff
- Wastewater Discharge
- Air Quality
- Solid Wastes (buried waste/landfills)
- Soil Stability / Erodibility
- Protected Mountains
- Protected Species
- Critical Habitats
- Historical Property
- Archaeological Sites / Artifacts
- Parks / Recreation Areas
- Energy Supplies
- Ocean Beaches (Ga. Coastal Zone)
- Dunes (Ga. Coastal Zone)
- Shoreline (Ga. Coastal Zone)
- Marshlands (Ga. Coastal Zone)
- Forest Land,
- Barrier Islands (Ga. Coastal Zone)
- Aquatic Life / Trout Streams
* For more information and further definition of the appropriate level of inquiry for each of these issues, please see Appendix 6 E, "Environmental Checklist Georgia Area/Category Information".
- In addition to providing brief narratives concerning each of the issues contained in paragraph 8 above, the GEPA segment of the combined evaluation, shall also include a completed BOR "Project Initial GEPA Evaluation Form" and a completed "GEPA Checklist"(both attached). The Consultant shall also state their opinion as to whether the proposed project may result in any adverse environmental effects. If adverse effects are anticipated, the Consultant shall sign the Project Initial GEPA Evaluation Form and recommend the preparation of an Environmental Effects Report (EER). In addition, the consultant shall also include a lump-sum, not-to-exceed cost proposal for EER preparation as an attachment to their report. If no adverse environmental impacts are anticipated, the Consultant shall sign the Project Initial GEPA Evaluation Form stating such.
- For both the ESA and GEPA segments of the combined evaluation, the appropriate level of inquiry shall be accomplished through site visits, visual observations, historical or regulatory record reviews, site personnel interviews, sample collection (where approved in advance), aerial photograph reviews and other means as necessary to accurately report on all required issues.
- The Consultant shall prepare a final written "Combined ESA/GEPA Evaluation Report" (2 copies) for submission to the BOR Director of Environmental Affairs and/or the institution's designated representative and shall include the following information:
- A report transmittal letter summarizing the findings of the combined ESA/GEPA evaluation, including any recommendations for remediation or further investigation of the site and/or suggested changes to proposed development/construction plans.
- Title Page
- Table of Contents
- Executive Summary:
- ESA Findings: Shall include conclusions and recommendations concerning the environmental status of the property as well as any findings of potential environmental /archaeological concern to the BOR. A recommendation shall also be made as to whether the site is suitable for development in its current state.
- GEPA Findings: Shall include brief narratives of any GEPA concerns, a statement as to whether the BOR proposed project will produce any adverse environmental impacts and whether an EER is recommended.
- Overview of the Subject Property
- Overview of the BOR Proposed Project
- Combined ESA/GEPA Evaluation Methods/Findings
- site reconnaissance
- records reviews
- personnel interviews
- sampling activities / results
- aerial photo reviews
- other methods
- Names, Signatures, and Qualifications of Consultant Personnel
- Including field assessor(s), report preparer(s), report reviewer(s) and firm principle(s)
- completed GEPA Environmental Checklist and Project Initial Evaluation Form
- aerial photos
- USGS quad maps
- site diagrams
- site photos
- historical records
- personnel interview documentation
- laboratory sample analytical reports (where approved)
- other documents as appropriate
Director of Environmental Affairs
Board of Regents of the University System of Georgia
270 Washington Street, SW
Atlanta, GA 30334