In one of the country’s most active commercial real estate markets, environmental due diligence is not a formality — it is a financial safeguard. Every year, property buyers in Palm Beach and Broward Counties discover contamination after closing: petroleum plumes from long-forgotten underground storage tanks, chlorinated solvents from a dry cleaner that operated on the property two decades ago, or arsenic levels in the soil from legacy pesticide applications on what is now a retail center.
Two South Florida environmental experts — Nicholas Moran, P.G., Licensed Professional Geologist and founder of Moran Rocks LLC, and Brett Brunsvold, President of Full Spectrum Environmental — sat down to walk through the Phase I and Phase II ESA process from the ground up: what these assessments involve, what they protect against, and what property owners and investors need to know before entering any commercial transaction in South Florida.
Understanding Phase I: The Foundation of Environmental Due Diligence
A Phase I Environmental Site Assessment is the standard first step in evaluating any commercial property’s environmental history and present-day condition. Governed by the ASTM E1527-21 standard and aligned with the EPA’s All Appropriate Inquiries (AAI) Rule, a Phase I ESA does not involve any physical sampling. Instead, it relies on four core components: a thorough review of historical records and regulatory databases, interviews with current and past property owners, a visual site reconnaissance, and a formal written report identifying any Recognized Environmental Conditions (RECs).
“A Phase I ESA is detective work. We’re tracing the environmental history of a piece of land — sometimes going back 80 or 100 years. Aerial photographs, Sanborn fire insurance maps, regulatory database queries, historical city directories — all of it builds a picture of what has happened on and around a property. The goal is to identify anything that raises a reasonable suspicion of contamination before a single dollar changes hands.”
— Nicholas Moran, P.G., Licensed Professional Geologist | Moran Rocks LLC | moran.rocks | 786-263-9185
Moran Rocks LLC, headquartered in Boca Raton, has conducted Phase I ESAs on properties ranging from small commercial lots to multi-tenant shopping plazas, gas stations, film sets, and large-scale development parcels across Palm Beach, Broward, and Miami-Dade Counties. Nicholas Moran brings more than 17 years of environmental consulting experience — including significant work with Fortune 10 companies, county and state governments, schools, and environmental regulators.
The output of a Phase I ESA is a detailed written report that identifies any RECs — defined as the presence or likely presence of hazardous substances or petroleum products that could have a material impact on the property. RECs are classified as current, historical, or potential, and each carries different implications for the transaction.
When Phase I Finds Something: The Role of Phase II ESAs
When a Phase I ESA identifies a REC — a potential contamination concern that cannot be resolved through records review and visual inspection alone — the next step is a Phase II Environmental Site Assessment. Unlike Phase I, Phase II involves direct physical investigation: drilling, sampling, and laboratory analysis to confirm or refute the presence of contamination and, if present, to characterize its nature and extent.
Moran Rocks LLC describes the Phase II as “zeroing in on pollution unknowns.” The firm’s Phase II investigations typically include:
- Soil sampling — Direct-push drilling to collect soil samples at multiple depths for laboratory analysis targeting petroleum hydrocarbons, chlorinated solvents, heavy metals, pesticides, and other site-specific contaminants.
- Groundwater sampling — Installation of temporary or permanent monitoring wells to collect groundwater samples, tested for dissolved-phase contaminants including volatile organic compounds (VOCs) and fuel-range organics.
- Soil gas sampling — In some cases, sampling of soil vapor to assess the potential for vapor intrusion into overlying structures.
- Laboratory analysis — All samples are analyzed by certified laboratories, with results compared against FDEP Soil and Groundwater Cleanup Target Levels.
“The Phase II is where we stop speculating and start knowing. We’ve had transactions in Broward County where the Phase I looked relatively benign — maybe a historical dry cleaner in the area — and the Phase II sampling confirmed PCE concentrations in the soil twenty times the FDEP cleanup target level. Without that data, the buyer would have acquired that liability completely blind. With it, they were able to renegotiate the purchase price, require remediation as a condition of closing, or walk away. Knowledge is leverage.”
— Nicholas Moran, P.G., Moran Rocks LLC | Phase II ESA Services: moran.rocks/phase-2-environmental-site-assessment
The Indoor Dimension: Why Air and Water Testing Completes the Picture
A Phase I or Phase II ESA addresses what is happening in the soil and groundwater beneath a property. But Brett Brunsvold of Full Spectrum Environmental emphasizes that for commercial property owners and operators, the environmental story doesn’t end at the soil surface.
“When you have subsurface contamination near a commercial building, you have to ask what’s getting inside,” says Brunsvold. “Vapor intrusion — where VOCs from contaminated soil or groundwater migrate through the slab and accumulate in indoor air — is a real and underappreciated exposure pathway. We’ve tested commercial buildings in Palm Beach County where the Phase II showed elevated VOCs in the groundwater, and our indoor air testing confirmed those compounds were present inside the building at levels that warranted action.”
“A Phase I or Phase II tells you what’s in the ground. But if you want to know what your tenants, employees, or customers are actually breathing — you need indoor air quality and water testing too. These are not competing services; they are complementary layers of the same picture. A comprehensive environmental assessment in South Florida really should address both the indoor environment and the subsurface.”
— Brett Brunsvold, President, Full Spectrum Environmental | fullspecenviro.com/commercial-services | (561) 206-2573
Full Spectrum Environmental’s commercial testing services include indoor air quality assessments, VOC and vapor intrusion screening, water quality testing, mold investigations, and industrial hygiene evaluations — services that are increasingly being paired with Phase I and Phase II ESAs to give commercial property owners the most complete environmental picture possible.
How Phase I and Phase II ESAs Protect Buyers, Lenders, and Developers
The legal framework underlying Phase I ESAs is worth understanding. Under CERCLA (the federal Superfund law), parties who purchase contaminated property can be held liable for cleanup costs even if they did not cause the contamination — unless they can demonstrate they conducted All Appropriate Inquiries (AAI) before closing. A Phase I ESA that meets the ASTM E1527-21 standard, completed by a qualified environmental professional, satisfies the AAI requirement and provides the buyer with the “innocent landowner” defense.
For lenders, the calculus is straightforward: contaminated collateral loses value and can become a direct liability if the lender forecloses. Most institutional lenders require Phase I ESAs on any commercial mortgage transaction, and many are now requiring updated ESAs at refinancing for properties with prior industrial or commercial use.
For developers, the stakes are even higher. Discovering contamination mid-construction can halt a project for months or years. Proactive Phase I and Phase II assessments in the pre-development phase allow developers to account for environmental risk in their acquisition price, budget, and timeline — rather than absorbing it as an unexpected cost after breaking ground.
Choosing Your Environmental Team in Palm Beach and Broward County
For property owners and investors operating in South Florida’s competitive real estate market, having a trusted, locally experienced environmental team is a strategic asset. Moran Rocks LLC (Phase I ESA services | Phase II ESA services) brings 17+ years of regulatory and subsurface expertise, deep familiarity with FDEP requirements, and a track record across every type of commercial property in the region. Full Spectrum Environmental (commercial environmental testing services) completes that picture with best-in-class indoor testing, building science expertise, and industrial hygiene capabilities.
Together, they represent the comprehensive environmental due diligence capability that South Florida’s most active commercial markets demand.
Nicholas Moran, P.G. is a Licensed Professional Geologist and founder of Moran Rocks LLC, a boutique environmental consulting firm based in Boca Raton, FL. With over 17 years of experience, he specializes in Phase I & II ESAs, petroleum contamination cleanup, NPDES permitting, and stormwater management across Palm Beach, Broward, and Miami-Dade Counties. Contact: 786-263-9185 | moran.rocks
Brett Brunsvold is the President of Full Spectrum Environmental, South Florida’s leading environmental consulting and testing firm. Full Spectrum Environmental provides mold assessments, indoor air quality evaluations, water quality testing, VOC analysis, building forensics, maritime services, and industrial hygiene to residential and commercial clients throughout Florida. Contact: (561) 206-2573 | fullspecenviro.com
