Authors: Joshua Morris, Mike Kurinsky & Jess Bonilla | Décembre 21, 2022
More than a year following the publishing of the new ASTM E1527-21 Phase I Environmental Site Assessment (Phase I ESA) standard by ASTM International, prospective purchasers, financial institutions and consultants received word that the USEPA published a Final Rule to amend the All Appropriate Inquiries (AAI) rule on December 15, 2022. The rule will go into effect on February 13, 2023, making the ASTM E1527-21 Phase I ESA standard AAI compliant.
EPA Actions
Earlier this year, the USEPA completed their review of the new standard and proposed amending the Standards and Practices for AAI to allow for the new ASTM E1527-21 Phase I ESA standard to be referenced and used. Comments were due by April 13, 2022 and the rule was expected to go into effect on May 13, 2022.
On May 2, 2022, the USEPA withdrew its proposed Final Rule following the submission of adverse comments primarily related to the continued recognition of the historical ASTM E1527-13 Phase I ESA standard as AAI compliant. In the recently passed Final Rule, the USEPA acknowledges the potential confusions associated with the recognition of a historical standard that is no longer considered current by ASTM International. Therefore, the USEPA has decided that ASTM E1527-13 will “sunset” on February 13, 2024 to allow for ongoing projects to be completed.
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What’s Changed
As discussed in TRC’s January 25, 2022 article “New Phase I ESA Standard will Affect Environmental Due Diligence”, the Phase I ESA standard helps to identify the standards and practices of environmental due diligence, helping to ensure that prospective purchasers of commercial or industrial properties can obtain legal protection under the Comprehensive Environmental Response, Compensation & Liability Act (CERCLA). In addition, TRC outlined changes that would be recognized and implemented upon approval of the updated standard, including: clarifying definitions of a Recognized Environmental Condition (REC), Controlled REC (CREC), and Historical REC (HREC); when to consider emerging contaminants as a Business Environmental Risk (BER); how to properly review applicable historical research resources such as topographic and fire insurance maps, aerial photographs, and city directories for on- and off-site properties; and more. These revisions were intended to increase consistency of future reports industry-wide.
TRC’s Recommendation
TRC recommends becoming familiar with the new ASTM E1527-21 Phase I ESA standard and to plan for Phase I ESA reports finalized on or after February 13, 2023 to be in compliance with the new standard. However, Phase I ESA reports completed in accordance with ASTM E1527-13 will be acceptable until February 13, 2024. TRC’s Due Diligence CORE team continuously monitors ASTM E1527 news and updates and will share additional information as it becomes available.
Our CORE team works together to ensure the experience and expertise across TRC can be accessed to meet challenges and provide the best service to help protect our clients. Contact Our Experts Below To Learn More.
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juillet 25, 2023
Key considerations for leveraging ASTM E2247 vs. E1527
The Rise of Agrivoltaics
juillet 18, 2023
This article explores the tensions between traditional agriculture and solar development, as well as the financial benefits for farmers who lease their land for solar projects.
Changes to EPA’s Risk Management Program (RMP) Regulations Are Coming
avril 14, 2023
Changes to the Risk Management Program (RMP) regulations were signed into a final rule on February 27, 2024, by EPA Administrator Michael S. Regan.
Routinely Evaluating the Health & Effectiveness of Integrated Systems to Manage EHS/ESG Risks – Part 2
mars 15, 2023
Systematic monitoring and continuous improvement is important to achieve an effective EHS/ESG management system within an organization.
Deadline Approaching for Utilities to Report SF₆ Emissions to EPA
mars 8, 2023
The EPA regulates greenhouse gas (GHG) emissions under the Greenhouse Gas Reporting Program (GHGRP) and has recently decided to place renewed emphasis on sulfur hexafluoride (SF₆).
Recognizing, Identifying, Prioritizing and Addressing EHS & ESG Risks
mars 3, 2023
A clear view and understanding of the environmental, health and safety (EHS) risks created by a business is paramount to its success and longevity.
Routinely Evaluating the Health & Effectiveness of Integrated Systems to Manage EHS/ESG Risks – Part I
mars 1, 2023
Once established, an EHS/ESG management system must be routinely evaluated to ensure it remains effective to identify and control risks, as well as accommodate and adjust for changes that occur to/within the organization.
ASTM Phase I Environmental Site Assessment Updates
février 1, 2023
Environmental due diligence is the first step in identifying potential environmental liabilities prior to the acquisition of real estate or business transfers.
Phase I ESA ASTM Standard Update: The Wait is Over
Décembre 21, 2022
The USEPA published a Final Rule making the ASTM E1527-21 Phase I ESA standard AAI compliant.
Optimizing EHS/ESG Information Management and Reporting Systems by Leveraging Innovative Digital Technology Solutions
août 10, 2022
A single, integrated enterprise wide EHS/ESG IMS can significantly improve performance and communicate progress towards organizational requirements and goals.
Regulatory Compliance Items to Consider as Part of Transactional Due Diligence
juillet 19, 2022
Performing a limited environmental regulatory review can identify potential deficiencies with the environmental management of an acquisition.
Support an Integrated EHS/ESG Management System
juin 10, 2022
While a Phase I Environmental Site Assessment (ESA) is a common method for identifying environmental liabilities during transactional due diligence, the ASTM International standard for Phase I ESAs (E1527-13, with proposed E1527-21 awaiting adoption) omits regulatory compliance from its scope. For properties containing operations that may be applicable to environmental compliance regulations, performing a limited environmental regulatory review can identify potential deficiencies with the environmental management of the facility. A limited environmental compliance review typically evaluates the presence of material findings that may exist in a facility’s management of its environmental compliance requirements. Material findings are defined as a condition of non-compliance that could necessitate expenditures, not including attorney fees or regulatory agency penalties, in excess of a specified dollar amount or materiality threshold. The materiality threshold is based on the client’s risk tolerance and is often in the range of $50,000. However, this amount is arbitrary and can be revised as appropriate. Non-material deficiencies, those identified below the materiality threshold, would still require action but are within the client’s risk tolerance.
How to Use an Integrated Approach To Manage EHS and ESG Risks
avril 20, 2022
While a Phase I Environmental Site Assessment (ESA) is a common method for identifying environmental liabilities during transactional due diligence, the ASTM International standard for Phase I ESAs (E1527-13, with proposed E1527-21 awaiting adoption) omits regulatory compliance from its scope. For properties containing operations that may be applicable to environmental compliance regulations, performing a limited environmental regulatory review can identify potential deficiencies with the environmental management of the facility. A limited environmental compliance review typically evaluates the presence of material findings that may exist in a facility’s management of its environmental compliance requirements. Material findings are defined as a condition of non-compliance that could necessitate expenditures, not including attorney fees or regulatory agency penalties, in excess of a specified dollar amount or materiality threshold. The materiality threshold is based on the client’s risk tolerance and is often in the range of $50,000. However, this amount is arbitrary and can be revised as appropriate. Non-material deficiencies, those identified below the materiality threshold, would still require action but are within the client’s risk tolerance.
New Phase I ESA Standard Will Affect Environmental Due Diligence
janvier 25, 2022
After years of review, revisions and discussions, the new ASTM E1527 Phase I Environmental Site Assessment (Phase I ESA) standard has been published. The new standard includes updates to definitions, clarifications on processes and requirements, and guidance for emerging contaminants.
Managing EHS & ESG Risks Through Integrated Systems Today and Beyond
juillet 22, 2021
It has been more than 50 years since the development and establishment of the federal Environmental Protection Agency (EPA) and the federal Occupational Safety & Health Administration (OSHA) which were formed to protect our environment and workplaces across the United States. Significant laws, policies and regulations followed to establish the “regulatory programs” that all applicable businesses and entities must address and meet to ensure these compliance-driven legislative programs would create a foundation to protect our society.
Impacts environnementaux de la transition vers les énergies renouvelables
mai 15, 2021
La transition vers les sources d’énergie renouvelables aura des répercussions environnementales et économiques notables. Pour comprendre les implications possibles, vous aurez besoin d’une connaissance de base de la façon dont les combustibles fossiles affectent l’environnement.
Controlling volatile organic emissions from RCRA hazardous waste activities
mai 14, 2021
EPA identifies National Compliance Initiative FY2020-2023 for reducing hazardous air emissions from hazardous waste facilities.
PFAS Sampling Advisory on Aqueous Samples
avril 1, 2021
Advisory on collecting aqueous samples (e.g., groundwater, wastewater, stormwater, etc.) for PFAS analysis.
Interim Guidance on Destruction and Disposal of PFAS & Materials Containing PFAS
février 19, 2021
Interim Guidance from EPA identifies 6 materials that use or manufacture PFAS and approaches for disposal.
EPA Issues PFAS Air Emissions Draft Test Method OTM-45
février 5, 2021
First Air Emissions Draft Test for the Measurement of Selected Per- and Polyfluorinated Alkyl Substances from Stationary Sources
TRC Companies Inc. Expands Environmental and Renewable Energy Capabilities with the Acquisition of Shoener Environmental
Décembre 2, 2020
Today TRC Companies, announces the expansion of its environmental and renewable energy capabilities with the acquisition of Shoener Environmental.
TRC Talks – Renewable Energy
novembre 24, 2020
Our experts discuss TRC’s integrated approach to renewable energy development.
TRC Companies Inc. Acquires 1Source Safety and Health
novembre 11, 2020
TRC Companies (« TRC”), a leading technology-driven provider of end-to-end engineering, consulting and construction management solutions, has acquired 1Source Safety and Health, a firm that provides management consulting services in areas such as indoor air quality, asbestos management, industrial hygiene and safety management systems.
Michael Kurinsky
Mike Kurinsky is a TRC Project Manager who specializes in transactional due diligence. He has over 17 years of experience and is based in Cleveland, Ohio. He and his team assist clients with environmental due diligence and compliance evaluations for domestic and international projects. He regularly assists with projects performed through Ohio’s Voluntary Action Program (VAP). Contact Mike at mkurinsky@trccompanies.com.
Joshua Morris
Josh Morris is a TRC Project Manager and Due Diligence and ISRA Specialist with 11 years of experience based in Northern New Jersey. He and his team assist clients with environmental due diligence (i.e., Phase I Environmental Site Assessments and Preliminary Assessments), transaction advisory services and compliance with New Jersey’s Industrial Site Recovery Act (ISRA) and Site Remediation Program. Contact Josh at jmorris@trccompanies.com.
Jess Bonilla
Jessica Bonilla is a TRC Environmental Intern based in TRC’s New Providence, New Jersey office. Jess will be graduating from William Paterson University at the end of the year and joining TRC full-time. She has assisted with the preparation of Phase I Environmental Site Assessments and Preliminary Assessments, and Spill Prevention, Control and Countermeasure (SPCC) plans. Contact Jess at jbonilla@trccompanies.com.