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Fne <br /> 1 of your Department's SSCR Requirement Checklist, Mr. Escotto states that the date <br /> iew with the current property owner and the name of the person conducting this <br /> r "required." In Section 2.1 of the SSCR Requirement Checklist, I see no reference <br /> quired that the date of the interview with the current property owner and the name ofpnducting the interview must be stated in the SSCR. It is obvious that the interview had <br /> to have taken place around the date of the report, and it is very obvious that my Environmental <br /> Questionnaire found in Appendix "C" of the report, dated January 23. 2004 also serves as interview <br /> documentation of the property owner on this date. If a significant amount of time had passed <br /> (> 6 months) since the date of a report, any competent environmental professional would have re- <br /> interviewed the property owner for changes the owner may have made to the property. By simple <br /> inference, it was I who conducted the interview. It makes no difference who conducts the <br /> interview, I have signed and stamped the document; therefore, I am responsible for its contents. <br /> Mr. Escotto's second comment is "if it is all feasible (?), contact with the previous owner should be <br /> attempted. All pertinent information related to this report,which may be garnered from this <br /> contact, is to be submitted in the requested addendum." First of all, it was well-documented in my <br /> report that there was one and possibly two previous land uses of the property. The first land use <br /> was that it may have been part of gravel pit mine conducted by the neighbor to the north. What <br /> environmental information is to be garnered from an interview with a neighbor who conducted a <br /> well-known operation? I highly doubt they are going to admit to doing something that may have <br /> caused environmental damage. The second obvious land use of the property was as a chicken layer <br /> ranch, in which barn still remains. Again, what benefit would be derived from an interview with the <br /> operator of this ranch? I clearly explained that the interior of the building has concrete flooring. I <br /> have yet to hear anyone admit to anything that they have done, that may have caused significant <br /> environmental damage. <br /> This issue of either determining who previously owned a property under examination, and/or <br /> conducting an interview with past owner(s) originates from Section 7 of the ASTM document. <br /> Trying to determine adverse environmental impact from previous property owners is absurd 95%of <br /> the time, unless it can be proven the property was used as a gas station, wrecking yard, metal <br /> plating shop, etc. Even then, if it was proven that environmental damage occurred from a previous <br /> landowner-even if the environmental consultant did not discuss the possibility -the current <br /> landowner would in all probability fall under the "innocent landowner defense." All types of <br /> companies that may cause environmental degradation, such as oil and chemical companies, buy and <br /> sell property all over the United States without conducting any type business on these properties. <br /> For Section 3.1 of the SSCR Checklist, Mr. Escotto writes "A review of EHD information for sites <br /> within one-quarter mile of the subject property was not indicated in the report." "Additionally, an <br /> actual physical review of EHD data for contamination site listings should always be undertaken." <br /> First of all, where does it say in Section 3.1 of the Checklist that EHD information must be checked <br /> for sites within one-quarter mile? Please correct me if I'm wrong, but I believe there are three <br /> different sources of EHD information that are accessible to the public. The first is the microfiche <br /> files, which I did review in reference to the exterior bathroom at the NEC of the layer house. The <br /> second is the UST List, and the third is the Site Mitigation List(SML). The SW lists tanks by <br /> address, which is fairly easy to determine if a mitigation site is "nearby." The closest SML address <br /> Page 2 of 3 <br /> Chesnq Consulting <br />