My Article on the New ASTM E1527-21 Phase 1 Standard
My article on the revisions to the ASTM Phase 1 Standard was published in April issue of The Practical Real Estate Lawyer.
all appropriate inquiries
Expect Adverse Comments as EPA Drops Ball on ASTM Recognition
In our prior blog, we announced that the Environmental Protection Agency (“EPA”) would publish a proposed rule and direct final rule proposing to amend and amending the All Appropriate Inquiries rule (“AAI”) to reference the revised ASTM E1527-21 ‘‘Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process’’ (“E1527-21”) and allowing it to …
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Major CMBS Lender Requiring EPs to Perform Site Inspections
We have previously discussed discussed here and in other forums how the All Appropriate Inquiries (AAI) Rule issued by EPA in 2005 is deeply flawed and has directly contributed to a worsening in the quality of phase 1 reports. This is ironic outcome since the reason EPA was instructed in the 2002 amendments to CERCLA to issue …
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