Unfortunately, no. A Phase I ESA will need to be performed for the site as it is today. Many factors may have changed between assessments; therefore in order to properly document this credit, you will need to conduct a new Phase I ESA. The good news is that if the site has passed the Phase I ESA before, it will likely pass again.
Question
My site has an existing Phase I ESA from several years ago. Can I use this to demonstrate compliance with this prerequisite?
Credits