Short answer: SBA environmental requirements under SOP 50 10 8.1 call for an environmental investigation on every 7(a) and 504 loan secured by commercial real estate. A current or known prior use on the Appendix 6 NAICS list requires a Phase I at any loan size. Otherwise, loans up to $250,000 may start with an Environmental Questionnaire; larger loans need at least a Questionnaire plus a Records Search with Risk Assessment (RSRA).
SOP 50 10 8.1 is the standard operating procedure (SOP) the U.S. Small Business Administration (SBA) uses for its 7(a) and 504 loan programs, and Section A, Chapter 5, Paragraph E holds its environmental rules. This page is for lenders, Certified Development Companies (CDCs), brokers and borrowers; each rule is cited to its paragraph and checked against the SOP file SBA posted on October 7, 2026.
When SBA requires an environmental investigation
SBA calls the process an Environmental Investigation. It is required for “all commercial Property upon which a security interest such as a mortgage, deed of trust, or leasehold deed of trust is offered as security for a loan or debenture” (SOP 50 10 8.1, Section A, Chapter 5, Paragraph E.2). The rules apply to all SBA lenders on all 7(a) and 504 programs unless the SOP says otherwise, and for 7(a) loans, failure to comply “may result in a denial of SBA’s guaranty” (Paragraph E).
That covers any commercial real estate pledged as collateral, not only the property being bought. SOP 50 10 7.1 applied the policy only to real estate “acquired, refinanced, or improved by the loan proceeds.” The 2025 SOP dropped that limit, but some guides still repeat it, and some still show a $150,000 threshold instead of $250,000. SBA’s Procedural Notice 5000-866054, which still appears in search results, modified SOP 50 10 7.1 and expired March 1, 2026.
The SOP’s rules are minimums: “Prudent lending practices and internal lending policy may dictate additional Environmental Investigations or safeguards” (Paragraph E.2). That is why two lenders can ask for different reports on the same property: SBA sets the floor, and each lender’s policy can add to it.
SOP 50 10 8.1 was published September 25, 2026 and took effect October 1, 2026. SBA’s September notice, Information Notice 5000-882227, applies it to applications received by SBA on or after that date; the earlier August notice, Information Notice 5000-880695, said loan numbers issued on or after that date. SBA posts the SOP only as a Word (.docx) file, not a PDF.
Applications submitted through September 30, 2026 stay under the 2025 SOP. For environmental purposes the difference rarely matters: our word-by-word comparison found no substantive change to the environmental rules between the two versions (see our SOP 50 10 8.1 environmental explainer).
The SBA environmental requirements, step by step
Paragraph E.4 sets the order. It starts with the North American Industry Classification System (NAICS) codes for the property’s uses, and the lender moves on only when a result calls for more work.
| Step | Situation | Minimum SBA requires | What happens next | SOP 50 10 8.1 |
|---|---|---|---|---|
| 1 | Any commercial property offered as collateral, except a unit in a Multi-Unit Building (which goes to step 3 or 4) | A good-faith check of the NAICS codes for current and known prior uses against Appendix 6 | Match: step 2. No match: step 3 or 4 | Para. E.4.a |
| 2 | NAICS match, at any loan amount | Phase I environmental site assessment (ESA) | A code beginning with 457 also brings in Appendix 7 where it applies | Para. E.4.a.i |
| 3 | No match, or a unit in a Multi-Unit Building, and a loan up to and including $250,000 | Environmental Questionnaire (EQ) | Clean EQ: keep it in the file. EQ shows further investigation is warranted: at least an RSRA | Para. E.4.a.ii.a and E.4.b |
| 4 | No match, or a unit in a Multi-Unit Building, and a loan over $250,000 | EQ plus RSRA | Clean EQ and an RSRA rating of “low risk”: keep both in the file. Any other RSRA rating: Phase I | Para. E.4.a.ii.b and E.4.c |
| 5 | The current owner or operator will not sign the EQ | At least a Transaction Screen (on a loan over $250,000, see the first open question below) | No further investigation warranted: keep it in the file. Otherwise: Phase I. Going straight to a Phase II needs an advance exception from the SBA Environmental Committee | Appendix 4, “Environmental Questionnaire”; Para. E.4.d |
| 6 | The Phase I concludes further investigation is warranted | Do what the Environmental Professional (EP) recommends, typically a Phase II, or ask for an exception | SBA requires every EP recommendation, including “housekeeping measures” such as secondary containment and sealing floor drains | Para. E.4.e |
| 7 | The Phase II finds Contamination and the lender still wants to lend | The EP documents whether levels exceed reportable or actionable levels, whether Remediation is needed, its cost and its completion date | Approval and disbursement only if the risk is minimized under Paragraph E.5 | Para. E.4.f and E.5 |
Three rules sit outside the table: the Appendix 6 fuel footnote, under which a Phase I “should always be obtained” when the business sells, supplies or dispenses fuel; on-site dry cleaning, current or past, that used or likely used chlorinated or petroleum-based solvents, which needs a Phase I followed by a Phase II; and a pre-1978 child-occupied facility, which needs a lead risk assessment and lead-in-water testing on top of whatever the table requires.
Over $250,000, the minimum is a questionnaire plus an RSRA. Summaries that give the minimum as an RSRA or a Transaction Screen do not match the text. The Transaction Screen enters the steps in only two places: when the current owner or operator will not sign the questionnaire, and as the acceptable starting point Appendix 6 allows for a car-wash-only site. To run these steps for one property, use our SBA environmental requirement checker.
How the Appendix 6 NAICS check works
NAICS is the federal code set for types of business. Appendix 6 lists 55 entries. A 3, 4 or 5 digit entry covers every industry whose code begins with those digits; a 6 digit entry covers only that industry. Our SBA NAICS lookup searches all 55 entries and their conditions.
The check covers the property’s current and known prior uses, not only the borrower’s business. A dental office in a former auto repair shop matches through the prior use (8111, automotive repair and maintenance), so a Phase I is required even on a $150,000 loan. Many entries are conditional, such as food manufacturing (311) “if fuel tanks present” and several manufacturing codes “not required if assembly only,” so the lender has to establish the facts, not only the code. Lists that show 447 for gas stations predate 2022 NAICS, which uses 457, Gasoline Stations and Fuel Dealers.
A footnote reaches past the list: “A Phase I should always be obtained if the business sells, supplies or dispenses fuel, gasoline, heating oil, even if the NAICS code for the business is not identified on this list of environmentally sensitive industries” (Appendix 6). SBA wrote “should,” not “must,” so a lender that departs from it should document why.
A unit in a Multi-Unit Building (SBA defines the building as “any non-industrial, multi-unit building that is comprised of four or more individual units,” Appendix 4) does not need the NAICS check: the lender “may proceed directly” to the loan-amount rules in steps 3 and 4 (Paragraph E.4.a). On our reading, nothing in that rule switches off the special use rules, so a condo unit used as a daycare or a dry cleaner still needs those reports.
Daycares, dry cleaners, gas stations and car washes
Paragraph E.6 adds rules for three special use facilities, and Appendix 6 carves out car washes.
Child-occupied facilities built before 1978
A Child-Occupied Facility is a building, or part of one, built before 1978 and “visited regularly by the same child, under 6 years of age,” on at least two days a week, for at least 3 hours a day, 6 hours a week and 60 hours a year, such as a day care center, preschool or kindergarten classroom (Appendix 4, following 40 CFR 745.83).
These properties need a lead risk assessment and testing for lead in drinking water at all indoor and outdoor taps and fountains accessible to children. Both must be done new for each loan, within one year of the date the SBA loan number is issued, and the lead assessment must follow the U.S. Environmental Protection Agency (EPA) lead rules at 40 CFR Part 745 and the U.S. Department of Housing and Urban Development’s Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (Second Edition, July 2012). The loan may not be disbursed until the risk to young children “has been sufficiently minimized” (Paragraph E.6.a). SBA names a risk assessment, so a lead-based paint inspection alone does not meet the rule.
Dry cleaners
Any property with on-site dry cleaning, “whether currently in operation or operated historically at the site,” that used or likely used chlorinated solvents such as tetrachloroethene (PCE) and trichloroethene (TCE) or petroleum-based solvents needs “a Phase I followed by a Phase II.” The Phase II must address soil, groundwater and soil vapor and be performed by an independent EP who holds a current Professional Engineer (PE) or Professional Geologist (PG) license and has the equivalent of 3 years of full-time relevant experience. Deviations go to EnvironmentalAppeals@sba.gov as exception requests (Paragraph E.6.b).
A laundromat is different. Appendix 6 lists laundry and dry cleaning services (8123) only “if dry cleaning operations have ever existed on site.” On our reading, a laundromat or drop-off counter is not a match if no dry cleaning has ever been done on the property. Self-service dry cleaning machines are the exception: NAICS 812310 covers coin-operated drycleaners as well as laundries, and a self-service dry cleaning machine on the premises is on-site dry cleaning.
Gas stations
Paragraph E.4.a says an investigation for a code that begins with 457 “must begin with a Phase I.” The Appendix 6 entry adds “not required for propane or firewood dealers,” but those dealers share code 457210 (Fuel Dealers) with heating oil and coal dealers, so the carve-out can only turn on what the business sells, and a heating oil dealer is not carved out. The SOP does not say whether the carve-out overrides Paragraph E.4.a or the fuel footnote (see the open questions below). Appendix 7 then applies to loans secured by real property or station equipment “currently used to operate a gas station or commercial fueling facility,” but not when the borrower only leases the station and pledges none of it, or when the only collateral is something like inventory. A former gas station now used for something else still matches through its prior use and needs a Phase I.
Where Appendix 7 applies, the investigation must begin with a Phase I by an independent EP. It must also include an analysis of all relevant environmental records for the property and adjoining properties (including the seller’s records on a purchase), support for the EP’s finding on compliance with tank and equipment testing rules, the results of any further investigation the EP recommends and, if there is Contamination, a costed description of the recommended Remediation. Any Phase II must be done by an independent EP with a current PE or PG license and the equivalent of 3 years of full-time relevant experience (Appendix 7, Paragraph A). On tank and equipment testing, “A loan may not be disbursed until full compliance is achieved,” and leaking or defective equipment must be repaired or replaced before disbursement (Paragraph B).
If the EP finds Contamination, the lender can decline the loan or follow Paragraph E.5. In a change of ownership, the seller must then sign the SBA Indemnification Agreement unless the Environmental Committee grants a waiver; “a mere unwillingness” to sign is not enough (Paragraph C.2).
Car washes
Automotive repair and maintenance (8111) is on Appendix 6 “except for ‘car wash only’ facilities, for which a Transaction Screen is an acceptable starting point.” A car wash that also repairs vehicles or sells fuel is no longer car wash only.
The SBA environmental questionnaire
The Environmental Questionnaire is “the questionnaire used by a Lender to determine the likelihood that Contamination may be present” (Appendix 4).
- Who completes it. A lender that has made at least one site visit and a good-faith effort to interview the current owner or operator completes or reviews it. An EP “may, but is not required to,” help with the answers.
- Who signs it. The current owner or operator. If they will not sign, it “cannot be used” and the lender must obtain at least a Transaction Screen.
- What it must ask. The property address and, at a minimum: past and present uses of the property and adjoining properties; hazardous substances and their storage, generation, treatment, emission or disposal; related permits; evidence and potential sources of contamination; what the borrower, seller or lender knows of past contamination and of lawsuits or proceedings; regulatory actions; prior environmental studies, with copies attached; and lead paint, asbestos or polychlorinated biphenyls (PCBs).
- Required warning. A statement that intentionally falsifying or concealing a material fact may lead to prosecution under 18 U.S.C. 1001.
- Age. Dated within one year of the date the SBA loan number is issued.
- Form. The SOP prints no form. It lists the required content and accepts ASTM E1528-22 Questionnaire A, from the Transaction Screen standard, “for all purposes that an EQ is required.” ASTM licenses that form.
What SBA requires in each report, including the Phase I
Appendix 4 defines each report, and several SBA requirements go beyond the ASTM International standards the reports follow. AAI is EPA’s All Appropriate Inquiries rule at 40 CFR Part 312, and a REC is a recognized environmental condition.
| Report | What SBA requires | Prepared by | Site visit | Appendix 5 reliance letter |
|---|---|---|---|---|
| Environmental Questionnaire | The content list above, or ASTM E1528-22 Questionnaire A | Lender (an EP may help); the current owner or operator signs | At least one, by the lender | No |
| RSRA | The government databases in 40 CFR 312.26 plus historical sources that should reach back to first developed use or 1940, whichever is earlier; the EP rates the property “low risk,” “elevated risk” or “high risk”; the report names the EP and attaches every source relied on | EP | Not required | No: it “need not be accompanied by a Reliance Letter” |
| Transaction Screen | ASTM E1528-22: owner or operator interview, site visit, questionnaires A and B, records and history review. SBA adds EP supervision of the site visit, an EP conclusion on further investigation, and the records attached | EP | Yes | Yes |
| Phase I | AAI compliant, to ASTM E1527-21; an opinion on RECs, controlled RECs, historical RECs and Environmental Issues; the SBA conclusion on further investigation (see the list below) | EP reviews and signs; others may assist under an EP’s supervision | Yes | Yes |
| Phase II | ASTM E1903-19 (2020), or another accepted scope able to identify the presence, nature and extent of a release | EP (for dry cleaners and gas stations, an independent EP with a current PE or PG license and 3 years of experience) | Yes, with sampling | Yes |
What an SBA Phase I needs beyond a standard Phase I
A Phase I written only to ASTM E1527-21 can fall short for an SBA loan. Check that the file has these SBA items:
- the EP’s conclusion that the risk is either so minimal that no further investigation is warranted or sufficient to warrant more, with a detailed description of any recommended work (Appendix 4);
- the unmodified Appendix 5 reliance letter, which also states that the EP addressed the 40 CFR 312.22 “additional inquiries,” with evidence of the EP’s errors and omissions (E&O) insurance enclosed (Paragraph E.3; Appendix 5);
- an impartial EP with at least $1,000,000 per claim or occurrence in E&O coverage (Appendix 4);
- a report dated within one year of the date the SBA loan number is issued (Appendix 4);
- for a property currently used as a gas station, an independent EP and the Appendix 7 records and tank-testing work (Appendix 7, Paragraph A).
Three more points are easy to miss. ASTM E1528-22 does not itself require an EP and does not satisfy AAI, so the EP role in an SBA Transaction Screen comes from SBA. The SOP never defines what makes an RSRA “low,” “elevated” or “high” risk; that call is the EP’s, and only “low risk” ends the investigation. And a “desktop screen” is not one of the report types the SOP’s steps use, so a report sold under that name counts only if it meets every element of the RSRA definition above, including the named EP, the attached sources and SBA’s “low risk,” “elevated risk” or “high risk” rating.
For scope, cost and fit side by side, see RSRA vs Transaction Screen vs Phase I.
How old the reports can be
Every Environmental Investigation Report “must be dated within one year of the date of issuance of the SBA loan number” (Paragraph E.3). Appendix 4 repeats it in the definitions of the Questionnaire, the RSRA, the Transaction Screen and the Phase I, and child-occupied lead testing follows it too (Paragraph E.6.a).
For the Phase I, SBA is explicit: “notwithstanding the EPA’s regulations on updating Phase I ESAs after 180 days, SBA will accept for review an otherwise AAI compliant Phase I ESA if it is dated within one year of the date of issuance of the SBA loan number.” It adds a warning: “Parties may still wish to strictly comply with EPA’s regulatory timeframes to avoid jeopardizing legal and regulatory protections” (Appendix 4). The acceptance rule does not apply to liquidations under SOP 50 55 or SOP 50 57.
EPA’s timeframes are in 40 CFR 312.20: the inquiry must be done within one year before acquisition, and five components within 180 days before it (interviews, lien searches, the government records review, the site visit and the EP’s declaration). Under ASTM E1527-21 the clocks run from the dates of the components, not the report date. The 180-day window starts at the oldest of the five; the one-year window starts at the oldest dated work in the whole inquiry.
This matters most to buyers. An AAI-compliant Phase I satisfies one requirement for the landowner liability protections in the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) but does not secure them by itself. For most buyers the relevant protection is the bona fide prospective purchaser (BFPP) defense, defined in 42 U.S.C. 9601(40), which also requires the buyer’s own inquiries under 40 CFR 312.22 and continuing obligations after closing, as EPA’s lender liability fact sheet explains. SBA’s one-year acceptance does not stretch EPA’s windows; your attorney can say how they apply to your deal.
So a report can pass SBA’s test and still be too old for a buyer at closing. A Phase I dated March 10, 2026, whose oldest component, the site visit, was done March 2, 2026, meets SBA’s test for a loan number issued October 15, 2026. EPA’s 180-day window for that site visit closed August 29, 2026, so before a November closing a buyer relying on the BFPP defense would need a Phase I update that redoes the interviews, government records review, site visit and EP declaration, and would bring its own lien search current. Our 180-day rule guide works through the dates in more detail.
The Appendix 5 reliance letter and which reports need it
Transaction Screens, Phase Is and Phase IIs “must be performed by an Environmental Professional and be accompanied by the Reliance Letter in Appendix 5,” even when the report is addressed to the lender (Paragraph E.3). The form has boxes for a Transaction Screen, a Phase I or updated Phase I, and a Phase II. It has none for an RSRA or an Environmental Questionnaire, and the RSRA definition says that report “need not be addressed to the SBA and need not be accompanied by a Reliance Letter.”
The letter’s language “may not be modified” (Appendix 4). Besides certifying at least $1,000,000 per claim or occurrence in E&O coverage, the EP waives liability caps up to $1,000,000 as to the lender and SBA, gives up any right to indemnification from them and certifies independence from the seller and borrower; our SBA reliance letter guide explains each term.
Environmental Professional requirements for SBA loans
SBA adopts EPA’s definition: an EP is “a person who meets the requirements set forth in 40 CFR § 312.10(b)” (Appendix 4). Under 40 CFR 312.10 that takes a current PE or PG license, or a government license or certification to perform environmental inquiries, plus the equivalent of 3 years of full-time relevant experience; a bachelor’s or higher degree in engineering or science plus 5 years; or 10 years of full-time relevant experience.
SBA adds two conditions: the EP must “be impartial and maintain a minimum coverage of one million dollars per claim (or occurrence) in errors and omissions insurance” (Appendix 4). Others may help with a Phase I under the supervision or responsible charge of an EP, provided an EP reviews and signs it.
What the lender does with the results
How results reach SBA depends on the processing method (Paragraph E.3):
- Delegated loans, 7(a) Small Loans, SBA Express and Export Express. No submission through the SBA Loan System; the lender keeps every report in the loan file. Delegated lenders cannot seek SBA approval of the Environmental Investigation (Appendix 12). The one exception is a loan with Contamination that relies solely on Other Factor(s): the lender must send the reports and a memorandum to EnvironmentalAppeals@sba.gov for Environmental Committee clearance (Paragraph E.5.d.ix).
- Non-delegated, no Contamination. The lender certifies in the SBA Loan System that the property meets SBA’s environmental requirements and keeps the reports.
- Non-delegated, Contamination found. The lender uploads all environmental documents to the SBA Loan System, then emails EnvironmentalReviews@sba.gov, without the reports, with the subject line “DISTRICT OFFICE - APPLICATION NUMBER - LOAN NUMBER - LOAN NAME.” Attorneys in SBA’s Office of General Counsel respond, and the lender keeps the approval email.
Any exception request goes to the Environmental Committee “regardless of the method of processing used for the loan.” For SBA Express, Export Express and 7(a) Small Loans, lenders may not even request a loan number for collateral that will not meet SBA’s environmental requirements or that will require a non-standard indemnification agreement (Section B, Chapter 6, Paragraph D.11.c.viii).
When Contamination is known, “Loans may not be approved or disbursed if there is known Contamination or on-going Remediation at the Property unless the risks have been minimized to the satisfaction of SBA” (Paragraph E.5). SBA relies on one or more of nine mitigating factors (Paragraph E.5.d):
| Mitigating factor | What it takes |
|---|---|
| Indemnification | A person with enough resources to complete Remediation, other than the applicant or operating company, signs the unmodifiable Appendix 8 agreement |
| Completed Remediation | Written confirmation from a government agency that active Remediation is complete, a first year of monitoring results, and EP findings of no unacceptable increase and compliance with continuing obligations |
| No further action | A no further action or closure letter, or the state equivalent |
| Minimal Contamination | Contamination and cleanup cost are de minimis relative to the property’s value or the responsible party’s resources, with Remediation projected to be complete within 1 year |
| Clean-up funds | Evidence from a government agency that a fund has approved paying or reimbursing enough to cover Remediation |
| Escrow | At least 150 percent of estimated Remediation cost, with the 7(a) lender or 504 first mortgage holder as trustee, not funded with SBA loan proceeds |
| Contamination from another site | Proof it came from another property, plus a party with enough resources remediating under an approved plan, a state law that protects the owner, or a written assurance from the agency |
| Additional or substitute collateral | Collateral, or an additional equity contribution, enough to cover the potential loss |
| Other factors | Such as environmental insurance already paying cleanup costs, or a brownfields agreement; relying on these alone needs Environmental Committee clearance |
SBA 504 versus 7(a) environmental requirements
SBA loan environmental requirements are the same for both programs: the investigation steps, report types, special use rules and reliance letter apply to 7(a) and 504 alike (Paragraph E), and so does the $250,000 threshold, although the SOP does not say which amount it is measured against on a 504 project (see the open questions below). The differences are procedural.
| Topic | 7(a) | 504 | SOP 50 10 8.1 |
|---|---|---|---|
| Who is the “Lender” for these rules | The 7(a) lender | The CDC; the Third Party Lender is not included | Appendix 4, “Lender” |
| Stated consequence of noncompliance | Possible denial of SBA’s guaranty | Not stated in Paragraph E | Para. E |
| Contamination on a delegated loan | Delegated lenders, including 7(a) Small Loans, SBA Express and Export Express, follow Paragraph E.5 without SBA submission or concurrence, unless relying solely on other factors | The exemption is written for 7(a) loans only | Para. E.5.e |
| SBA Environmental Indemnification Agreement | Submitted to SBA before the lender asks SBA to fund, except Preferred Lenders Program (PLP), 7(a) Small Loans, SBA Express and Export Express | All CDCs, including Premier Certified Lenders Program (PCLP) CDCs, submit it to the Sacramento Loan Processing Center for approval at least 2 weeks before the closing package if they want the loan considered in that closing cycle | Para. E.5.d.i |
| Remediation escrow trustee | The 7(a) lender, which must not control or manage the property | The first mortgage holder (Third Party Lender), under the same limit | Para. E.5.d.vi |
| Waivers of indemnification rights | Anyone holding a right to indemnification from later owners signs the SBA Indemnification Agreement or a recorded waiver and release | The same, plus review by local SBA counsel through the SBA Loan System, PCLP CDCs included | Para. E.7 |
| Gas station waivers and releases | Sent to EnvironmentalReviews@sba.gov by lenders not using delegated authority | Sent by all CDCs, including PCLP CDCs | Appendix 7, Para. D |
Who to ask at SBA about environmental policy
Questions on SBA environmental policy go to “local SBA counsel for the area where the Property is located” (Paragraph E.9). Appendix 12 of the SOP lists three environmental inboxes:
| Inbox | Use it for |
|---|---|
| EnvironmentalQuestions@sba.gov | Reaching SBA District Counsel with environmental questions and for help with the environmental review process |
| EnvironmentalReviews@sba.gov | Telling District Counsel you uploaded documents for a non-delegated loan with Contamination, with the required subject line and no attachments |
| EnvironmentalAppeals@sba.gov | Exceptions to policy, appeals of SBA environmental decisions, and requests to rely solely on other factors; split anything over 15 MB |
Appeals and exceptions are reviewed by the SBA Environmental Committee, made up of Office of General Counsel attorneys appointed by the Associate General Counsel for Litigation, who may consult an environmental engineer. The Associate General Counsel for Litigation can overrule the Committee’s decisions (Paragraph E.9).
Questions the SOP leaves open
Four questions are not settled by the text. Put them to local SBA counsel before relying on an answer.
- A loan over $250,000 where the current owner or operator will not sign the questionnaire. Paragraph E.4 requires at least a questionnaire plus an RSRA; the questionnaire definition says a refusal means at least a Transaction Screen. The SOP does not say whether the Transaction Screen alone meets the over-$250,000 minimum. A Phase I satisfies either reading.
- What “loan amount” means on a 504 project. Paragraph E.4 says only “the loan amount.” Elsewhere the SOP defines an SBA Loan as “the full amount of the 7(a) loan or the Gross Debenture amount of the 504 loan,” which points to the debenture, but Paragraph E.4 does not refer to it.
- Reports dated after the loan number. “Within one year of the date of issuance of the SBA loan number” does not say before or after.
- Propane and firewood dealers. Appendix 6 says the 457 entry is “not required for propane or firewood dealers,” but Paragraph E.4.a says a 457 code “must begin with a Phase I,” and the fuel footnote says a Phase I “should always be obtained” for a business that sells, supplies or dispenses fuel. Get the lender’s position in writing before ordering less than a Phase I.
What each report costs with us
The Environmental Questionnaire is the lender’s own document, so there is no report fee. Our published prices for the other SBA reports, next to prices other firms publish:
| Report | Our price | Standard delivery | Rush | Other firms’ published prices, October 2026 |
|---|---|---|---|---|
| SBA RSRA | $695 | 2 business days | Next business day, $150 more | Kross Inspectors $575 (web rate); A3E $850; Phase Enviro $875 |
| Transaction Screen | $795 | 4 business days | 3 business days, $250 more | Few firms publish one: A3E about $1,950, per its blog; two other firms listed $930 and from $1,200 |
| Phase I ESA | $1,495, standard scope | 5 business days | 3 business days, $400 more | AAI Environmental says these reports typically cost $1,500-$5,000; Phase 1 Environmental Consulting NJ from $1,650; most prices and ranges in our Phase I cost guide about $1,800-$5,000 |
| Phase I update | $595 for a Phase I we wrote; another firm’s report quoted within 1 business hour of seeing it | 4 business days | No rush | None found |
| Lead risk assessment and water testing | Fixed quote; our lead services start at $750 | 5 business days | Confirmed with scope | Not compared |
| Phase II coordination | Quoted, bid to licensed partners | Quoted | Quoted | Not compared |
Delivery days run from authorization and, for reports with a site visit, confirmed site access. Our RSRA is not the lowest published price. Our $1,495 flat Phase I is below most published Phase I prices we found in October 2026, which ran about $1,800 to $5,000, and below the $1,500 low end of AAI Environmental’s typical range; we can charge less because we built proprietary internal technology that collects and organizes the regulatory and historical records the day an order is authorized, so the Environmental Professional reviews an organized record instead of assembling one.
- Scope. The flat Phase I price covers one parcel, up to 5 acres, up to 3 buildings and 50,000 square feet in total, and a current use that is not heavy industrial or manufacturing. Tell us at order about a current gas station or any on-site dry cleaning history, since Appendix 7 and Paragraph E.6.b add work; we confirm scope, price and delivery date within 1 business hour.
- Reliance letters. Transaction Screens, Phase Is and Phase I updates include the Appendix 5 letter at no charge. An RSRA does not need one.
- Escalation. The full RSRA or Transaction Screen fee is credited toward a Phase I on the same property ordered within 30 days.
- Acceptance. If the lender or SBA rejects a report we wrote to ASTM E1527-21, ASTM E1528-22 or SOP 50 10 8.1 because it does not comply, we correct it at no charge, and if we cannot, we refund that report’s fee; the engagement terms list the exclusions.
RSRAs, Transaction Screens and Phase Is are signed by an Environmental Professional who meets 40 CFR 312.10. On our Transaction Screens, the Environmental Professional also supervises the site visit, and the database and historical records the screen relied on are attached, as Appendix 4 requires. Lenders and CDCs ordering 3 or more reports a month can get 10% off and monthly invoicing under a separate master agreement; see our page for SBA lenders.
Sources
- SOP 50 10 8.1, Lender and Development Company Loan Programs with Technical Policy Updates (Section A, Chapter 5, Paragraph E; Appendices 4 to 8 and 12; Section B, Chapter 6, Paragraph D.11.c.viii), U.S. Small Business Administration, accessed October 2026
- SOP 50 10 7.1, Lender and Development Company Loan Programs (effective November 15, 2023; earlier version listed on the same SBA page), U.S. Small Business Administration, accessed October 2026
- Procedural Notice 5000-866054 (effective March 20, 2025; expired March 1, 2026), U.S. Small Business Administration, accessed October 2026
- Information Notice 5000-882227, Issuance of Technical Updates to SOP 50 10 8.1, U.S. Small Business Administration, accessed October 2026
- Information Notice 5000-880695, Issuance of SOP 50 10 8.1, U.S. Small Business Administration, accessed October 2026
- 40 CFR 312.10, Definitions, Electronic Code of Federal Regulations, accessed October 2026
- 40 CFR 312.20, All appropriate inquiries, Electronic Code of Federal Regulations, accessed October 2026
- 40 CFR 312.22, Additional inquiries, Electronic Code of Federal Regulations, accessed October 2026
- 40 CFR 312.26, Reviews of federal, state, tribal, and local government records, Electronic Code of Federal Regulations, accessed October 2026
- 40 CFR 745.83, Definitions, Electronic Code of Federal Regulations, accessed October 2026
- 42 U.S.C. 9601, Definitions (CERCLA section 101), U.S. Government Publishing Office, accessed October 2026
- Lender Liability and Applicability of All Appropriate Inquiries (EPA-560-F-23-006), U.S. Environmental Protection Agency, accessed October 2026
- ASTM E1527-21, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process, ASTM International, accessed October 2026
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