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The AAPG/Datapages Combined Publications Database
Houston Geological Society Bulletin
Abstract
Abstract: The Federal “All Appropriate Inquiry” Rule:
A New
Phase
in
Phase
I’s
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By
EDR
Houston, Texas
Thursday, August 26, 2004, marked a truly historic moment for
the environmental site assessment industry. On this date, the
US EPA proposed the first federal standard for “all appropriate
inquiries”—the term used for the investigation into a property’s
potential for environmental contamination prior to purchase.
By year-end 2005, the developing federal standard will be
promulgated into federal law, changing the forces that govern the
way environmental due diligence is conducted significantly in
some respects. The AAI law will establish specific regulatory
requirements that a property owner (and the owner’s environmental
consultant) must follow to determine the previous
ownership, uses and environmental conditions of a property
for the purposes of qualifying for certain landowner liability
protections under CERCLA. Within the proposed rule is text that
will not only dictate who can perform Phase
I environmental site
assessments (ESAs) in the future, but also calls for significant
changes in how ESAs can be performed—from historical
research documentation to reviews of local and tribal government
records to documentation of data gaps. As such, it is imperative
for anyone conducting
Phase
I environmental site assessments
to stay up-to-date on this important new ruling as it nears
promulgation. At this workshop, attendees will learn about the
implications of the new federal environmental due diligence
standard so that they can prepare for any necessary changes to
their
Phase
I practices now, rather than later.
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