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9.0 DATA GAPS <br />ASTM Standard Designation E 1527-21 requires the Environmental Professional to comment on <br />significant data gaps that affect their ability to identify RECS.A data gap is a lack of or inability to <br />obtain information required by ASTM despite good faith efforts by the Environmental Professional <br />to gather such information.A data gap raises reasonable concern if it is considered to be significant. <br />ASTM defines Data Failure as occurring when all of the standard and reasonably ascertainable and <br />likely to be useful historical sources have been reviewed but historical research objectives were <br />not met. Data failures are not uncommon when attempting to identify the use of a Site at five <br />year intervals back to the first use or 1940, whichever is earlier.ASTM requires the Environmental <br />Professional to comment on the significance of data failures and whether the data failure affects <br />our ability to identify RECs.A data failure by itself is not inherently significant; it only becomes <br />significant if it raises reasonable concerns. <br />Historical information was reviewed back to 1938.Data gaps greater than five years exist from prior <br />to 1938, from 1938 to 1953, and 1963 to 1970.The interviews, historical maps, city directories, aerial <br />photographs and previous environmental reports provide generally good corroborating information <br />that allows an understanding of historical Property use. <br />The bus maintenance garage is considered a REC since it was locked during the Site reconnaissance <br />and the interior was not observed. <br />Phase I Environmental Site Assessment <br />16330 US Highway 10 NW, Elk River, Minnesota September 4, 2024 <br />Carlson McCain, Inc.Page 22