Federal, state, tribal and local regulatory records for the property and for adjoining and nearby properties within the 40 CFR 312.26 and ASTM search distances
ASTM E1527-21 / EPA All Appropriate Inquiries (40 CFR 312)
Phase I Environmental Site Assessment
$1,495Flat price / standard scope
5business days
Lender-ready Phase I in 5 business days for $1,495 flat, nationwide. Signed by an Environmental Professional who meets 40 CFR 312.10. SBA reliance letter included.
Scope and deliverables
Know exactly what’s included.
A Phase I Environmental Site Assessment uses regulatory and historical records, a site visit and interviews to identify Recognized Environmental Conditions: hazardous substances or petroleum present or likely present because of a release, or present under conditions that pose a material threat of a future release. It does not sample soil or water. Performed to ASTM E1527-21, which EPA recognizes under the All Appropriate Inquiries rule, and combined with your own inquiries, it satisfies one of the requirements for CERCLA’s landowner liability protections. Lenders set their own rules for when they require one; SBA loans require one when a current or known prior use matches an environmentally sensitive NAICS code (lenders may skip that check for a unit in a non-industrial building of 4 or more units), an RSRA is not rated low risk, a Transaction Screen finds further investigation warranted, or the property has current or past on-site dry cleaning, which also requires a Phase II.
Historical sources back to 1940 or first developed use, whichever is earlier: aerial photographs, fire insurance maps, city directories, topographic maps
Site reconnaissance with photographs by a qualified local professional under the Environmental Professional’s supervision, including views of adjoining properties
Interviews with the owner, occupants and local agencies; review of your User Questionnaire
Findings and opinion: RECs, CRECs, HRECs, de minimis conditions, significant data gaps and whether further investigation is warranted
Consideration of potential vapor migration as part of the ASTM E1527-21 assessment
SBA SOP 50 10 8.1 Appendix 5 reliance letter on SBA loans; reliance for your lender on other loans
Report signed by an Environmental Professional who meets 40 CFR 312.10, with the 312.21(d) declarations and the dates of the interviews, records review, site visit and declaration
Outside this report
- Sampling of soil, groundwater, soil vapor or indoor air (Phase II)
- Asbestos, lead-based paint, lead in drinking water or radon surveys, unless ordered separately
- Mold surveys, and wetlands, endangered species, cultural resources or NEPA reviews
- ASTM E2600 vapor encroachment screening, which is a separate scope
- Environmental lien and activity and use limitation searches, a user responsibility under ASTM E1527-21 (send us the results)
- Regulatory compliance audits, and substances that are neither CERCLA hazardous substances nor petroleum products, such as PFAS other than PFOA and PFOS
Best for
- Commercial real estate purchases and loans
- SBA 7(a) and 504 loans where a current or known prior use matches an Appendix 6 NAICS code (for example auto repair or a car dealership with service bays; on-site dry cleaning also requires a Phase II), an RSRA is not rated low risk, or a Transaction Screen finds further investigation warranted
- Buyers who want CERCLA’s bona fide prospective purchaser defense (the Phase I and your own inquiries meet its all appropriate inquiries requirement)
Read before you order
Guides, updates and rush delivery.
Locations
Phase I ESA by state.
Phase I ESA, in depth
What a Phase I environmental site assessment does, and how we deliver yours.
Short answer: A Phase 1 ESA carries the Environmental Professional’s share of all appropriate inquiries, one requirement for a buyer’s landowner liability protections under CERCLA, and gives a lender or the SBA a signed opinion on whether the collateral shows evidence of contamination. Ours follows ASTM E1527-21, costs $1,495 flat for standard-scope properties and is delivered in 5 business days from authorization and confirmed site access.
Who needs a Phase I, and what it does for them
Buyers. CERCLA, the federal Superfund law, can make the current owner of a contaminated property liable for cleanup without regard to fault (EPA’s brownfields and CERCLA liability fact sheet, page 1). For most buyers the relevant protection is the bona fide prospective purchaser (BFPP) defense (42 U.S.C. 9601(40) and 9607(r)).
Unlike the innocent landowner defense, the BFPP defense can apply even when the buyer knew of contamination before closing (EPA enforcement guidance, page 5). One of its requirements is “all appropriate inquiries” (AAI) under 40 CFR Part 312: the Phase I covers the part done by the Environmental Professional (EP), and some inquiries fall to you (see below).
The inquiry must be finished on or before the day you take title, and the defense also depends on continuing obligations after closing, such as required notices, reasonable steps to limit a release and compliance with land use restrictions (EPA lender fact sheet, page 2). An environmental attorney can tell you how these apply to your deal.
Lenders. A lender’s own CERCLA protection, the secured creditor exemption, does not depend on AAI, though EPA notes that a bank may require the borrower to qualify for the landowner protections (EPA lender fact sheet, page 3). The exemption does not protect the lender from a fall in collateral value caused by contamination, or the borrower from cleanup costs that can impair repayment. For that reason, the examiner handbook of the Office of the Comptroller of the Currency (OCC) expects the banks it supervises to evaluate the property before funding and to set risk thresholds, by property type, use and loan amount, for deciding when environmental due diligence is needed and what kind (OCC Comptroller’s Handbook, pages 66-67).
SBA loans. For U.S. Small Business Administration (SBA) 7(a) and 504 loans, SOP 50 10 8.1 requires a Phase I at any loan amount when a current or known prior use matches an environmentally sensitive North American Industry Classification System (NAICS) code in Appendix 6; a unit in a non-industrial building of 4 or more units may skip the NAICS step (Section A, Chapter 5, Paragraph E.4.a). It also requires one after a Records Search with Risk Assessment (RSRA) that is not rated low risk, or a Transaction Screen whose EP finds further investigation warranted (Paragraphs E.4.c.ii and E.4.d.ii).
How our Phase I works, from order to delivery
- Request. Send the address, report type and closing date. We confirm the scope, a fixed price and a delivery date within 1 business hour.
- Authorize. The 5-business-day clock starts at authorization and confirmed site access. That day, records collection begins and we book a qualified local professional for the site visit.
- Research. We review regulatory records for the property and for adjoining and nearby properties within the 40 CFR 312.26 search distances (up to 1 mile, which the EP may adjust), and historical sources back to 1940 or first developed use, whichever is earlier.
- Site visit and interviews with the owner, occupants and local agencies.
- Signature. An Environmental Professional who meets 40 CFR 312.10 forms the opinion and signs the required declarations.
- Delivery on the committed date, or in 3 business days with a rush Phase I (+$400), with reliance for your lender and, for SBA loans, the Appendix 5 reliance letter.
What you need to give us
AAI assigns some inquiries to you, the “user” (40 CFR 312.22). If you leave them out, the EP should consider what the missing information means (EPA’s comparison of AAI and ASTM E1527-21, page 9). Most of it goes on the User Questionnaire.
| What we need | Why | Rule |
|---|---|---|
| Access, a contact who knows the property, and the owner’s and occupants’ names | The site visit is required, and a seller’s refusal does not excuse it. The EP must interview the owner and occupants. | 40 CFR 312.27(c), 312.23(b) |
| What you know, or what is commonly known, about past uses and conditions | AAI is not complete without your specialized knowledge. ASTM asks you to share it, and commonly known information, before the site visit. | 40 CFR 312.28, 312.30; ASTM E1527-21 (EPA comparison, pages 11-12) |
| Environmental lien and activity and use limitation (AUL) search results | Searching land title and judicial records for liens and AULs is your job unless you engage the EP to do it. The lien search date is one of the five 180-day dates. | 40 CFR 312.25, 312.20(b); ASTM E1527-21, Sections 4.6.1 and 6.2 (EPA comparison, pages 8 and 10) |
| Whether the price is below market value, and why | You must consider whether contamination explains it. You need not tell us the price. | 40 CFR 312.29; ASTM E1527-21, Section 6.5 (EPA comparison, page 11) |
| Prior reports, and any tank records or permits | A prior report can be reused once reviewed and updated; if it was prepared for someone else, you still owe your own inquiries. Tank records and permits help the records review. | 40 CFR 312.20(c)-(d), 312.26(b)(2) |
| For SBA loans, the lender’s name | The Appendix 5 letter names the lender and the SBA. | SOP 50 10 8.1, Appendix 5 |
Who visits the property, and what they look at
A qualified local professional performs the visit under the EP’s supervision, which 40 CFR 312.10 allows and the SBA accepts when an Environmental Professional reviews and signs the report (SOP 50 10 8.1, Appendix 4).
The visit covers the property, its buildings and the areas where hazardous substances may be or may have been used, stored, treated, handled or disposed of, plus adjoining properties viewed from the property line or public rights of way (40 CFR 312.27). ASTM E1527-21 adds petroleum products to that scope. An area that cannot be entered is a data gap, and a significant one if it limits the EP’s ability to identify a recognized environmental condition (REC).
What the Phase I report finds, and what happens next
The report’s conclusions list every REC, including controlled RECs (CRECs), and any significant data gaps. Our guide to RECs, CRECs, HRECs and de minimis conditions defines each.
| The report finds | What it means | Usual next step |
|---|---|---|
| No RECs | The inquiry found no evidence of a REC. No Phase I removes all uncertainty (ASTM E1527-21, Section 4.5.1). | Proceed, and keep the report’s component dates. |
| Only historical RECs (HRECs) or de minimis conditions | A past release closed to unrestricted-use criteria, or a release-related condition that generally poses no threat to health or the environment and would generally not draw enforcement. Neither is a REC. | Usually none. |
| A CREC | A REC closed by the regulator with contamination left in place under controls, such as a deed restriction. | Confirm the controls. Complying with them becomes a continuing obligation. |
| A REC | Hazardous substances or petroleum present or likely present because of a release, or present under conditions that pose a material threat of a future release. | Weigh the EP’s opinion on further investigation, often a Phase II. SBA loans have a stricter rule (below). |
| A significant data gap | Missing information affects the EP’s ability to identify RECs. | Close it before closing if you can, or weigh it with your lender. |
On SBA loans, if the Phase I finds further investigation warranted, a lender that still wants to make the loan must follow the EP’s recommendations, including housekeeping items such as sealing floor drains, or request an exception (SOP 50 10 8.1, Section A, Chapter 5, Paragraph E.4.e). In EDR’s 2018 survey of environmental consultants, respondents estimated that close to a quarter of Phase I reports lead to a Phase II. When one is needed, we scope it and obtain fixed bids from licensed partners.
What a standard Phase I does not cover
The exclusions are listed under “Outside this report” above. AAI does not require sampling (EPA enforcement guidance, page 6, note 22), so a Phase I does not sample soil, groundwater, soil vapor or indoor air; that work is a Phase II. Three points need more explanation:
- Most PFAS. PFOA and PFOS, two per- and polyfluoroalkyl substances (PFAS), have been CERCLA hazardous substances since July 8, 2024 (40 CFR 302.4); the D.C. Circuit denied challenges to the designation on August 18, 2026 (Chamber of Commerce v. EPA). A Phase I considers them like any other hazardous substance, without sampling. Other PFAS stay outside the ASTM scope until designated (EPA comparison, page 3).
- Radius reports. If your lender requires a commercial data vendor, an EDR, ERIS or Environsite radius report is a $200 add-on.
- SBA gas station and dry cleaner loans. Gas station loans add Appendix 7 requirements, such as an independent EP and tank and equipment testing documentation. Current or past on-site dry cleaning that used, or likely used, chlorinated or petroleum-based solvents requires a Phase II after the Phase I (SOP 50 10 8.1, Section A, Chapter 5, Paragraph E.6.b). Tell us at order.
The full checklist is in what is included in a Phase I.
Why it costs $1,495 and takes 5 business days
LightBox’s 2023 survey of environmental professionals, the latest we found, put the average AAI-compliant Phase I on a conventional property with no non-scope issues at $3,083 and 16 business days. When we checked firms’ websites in October 2026, most Phase I prices and ranges they published ran about $1,800 to $5,000; the Phase I cost guide names the firms and dates.
The difference is in the desk work, not the standard. In the same survey, report writing was the most time-consuming step, at 6.8 hours on average. We built proprietary internal technology that collects and organizes the regulatory and historical records the day an order is authorized, so the EP reviews an organized record instead of assembling one. The site visit, interviews, scope and signature do not change; how long a Phase I takes walks through the timing.
How long the report stays usable
Under 40 CFR 312.20, the interviews, lien search, government records review, site visit and EP declaration must be conducted or updated within 180 days before you acquire the property, and the rest of the inquiry within one year. Both clocks run from the dates of that work, not from the report date (ASTM E1527-21, Sections 4.6.1-4.6.3).
For SBA loans, every environmental report must be dated within one year of the date the SBA loan number is issued (SOP 50 10 8.1, Section A, Chapter 5, Paragraph E.3). Notwithstanding the 180-day rule, the SBA will accept for review an otherwise AAI-compliant Phase I dated within that year, but notes that parties may still want to meet EPA’s timeframes to avoid jeopardizing legal protections (Appendix 4). A buyer relying on the BFPP defense still needs the 180-day dates. Check yours with the Phase I validity calculator; updating our own report costs $595, and we quote another firm’s report after reviewing it.
Sources
- 40 CFR Part 312, Innocent Landowners, Standards for Conducting All Appropriate Inquiries, Electronic Code of Federal Regulations, accessed October 2026
- 42 U.S.C. 9601, Definitions (CERCLA), U.S. Code 2024 edition, U.S. Government Publishing Office (govinfo), accessed October 2026
- 42 U.S.C. 9607, Liability (CERCLA), U.S. Code 2024 edition, U.S. Government Publishing Office (govinfo), accessed October 2026
- ASTM E1527-21, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process, ASTM International, accessed October 2026
- Comparison of All Appropriate Inquiries Regulation, the ASTM E1527-13 Phase I Environmental Site Assessment Process, and ASTM E1527-21 Phase I Environmental Site Assessment Process, U.S. Environmental Protection Agency (docket EPA-HQ-OLEM-2021-0946), copy hosted by the Wisconsin Department of Natural Resources, accessed October 2026
- EPA Brownfields Grants, CERCLA Liability, and All Appropriate Inquiries (EPA 560-F-23-003), U.S. Environmental Protection Agency, accessed October 2026
- Lender Liability and Applicability of All Appropriate Inquiries (EPA-560-F-23-006), U.S. Environmental Protection Agency, accessed October 2026
- Enforcement Discretion Guidance Regarding Statutory Criteria for Those Who May Qualify as CERCLA Bona Fide Prospective Purchasers, Contiguous Property Owners, or Innocent Landowners (“Common Elements”), July 29, 2019, U.S. Environmental Protection Agency, accessed October 2026
- Comptroller’s Handbook: Commercial Real Estate Lending, Version 2.0, Office of the Comptroller of the Currency, accessed October 2026
- SOP 50 10 8.1, Lender and Development Company Loan Programs with Technical Policy Updates, effective October 1, 2026 (Word document), U.S. Small Business Administration, accessed October 2026
- 40 CFR 302.4, Hazardous substances and reportable quantities, Electronic Code of Federal Regulations, accessed October 2026
- Chamber of Commerce of the United States v. EPA, No. 24-1193 (D.C. Cir. August 18, 2026), U.S. Court of Appeals for the District of Columbia Circuit, accessed October 2026
- 2023 Benchmark Survey of Environmental Professionals, LightBox, accessed October 2026
- EDR’s 2018 Benchmark Survey of Environmental Consultants: Summary of Results, EDR, accessed October 2026
Clear commitments.
Before work begins.
On-time guarantee
Miss the delivery date we commit to for a reason within our control, and we take $250 off, or refund the full fee if it is under $250.
Acceptance guarantee
For reports ordered to ASTM E1527-21, ASTM E1528-22 or SBA SOP 50 10 8.1, we correct the report at no charge if noncompliance causes lender or SBA rejection. If we cannot correct it, we refund that report’s fee. The engagement terms explain the exclusions.
How it works
A clear path from address to answer.
- Start here
Tell us about the property
Address, report type and timeline. Start your request online, with no payment required.
- 1 business hour
Confirm your scope, price and date
A project manager reviews the request and sends your fixed proposal. Work begins after you authorize.
- Records + site
Research, site visit and review
Records research starts when you authorize, and the site visit follows on the confirmed schedule. An Environmental Professional who meets 40 CFR 312.10 reviews the findings and signs the report.
- 5 business days
Your report, ready for the next step
Receive your report and supporting documentation. We stay available for questions from you and your lender.
Compare reports
Which report do you need?
Start with the scope your transaction requires. The full fee of a desktop screen, RSRA or Transaction Screen is credited toward a Phase I on the same property ordered within 30 days.
| Report | Desktop Screen$199 flatNext business day | SBA RSRA$695 flat2 business days | Transaction Screen$795 flat4 business days | Phase I ESA$1,495 flat5 business days |
|---|---|---|---|---|
| Standard | Database + historical review, EP opinion | SBA SOP 50 10 8.1 | ASTM E1528-22 | ASTM E1527-21 / AAI |
| Site visit | No | No | Yes | Yes |
| Signed by an Environmental Professional | Yes | Yes | Yes | Yes |
| Accepted by the SBA | No | Yes | Yes | Yes |
| Performed to EPA’s AAI rule (one requirement for CERCLA landowner protections) | No | No | No | Yes |
| Best for | First look before spending on a Phase I; buyers, brokers, low-risk conventional loans | SBA loans over $250,000 with no Appendix 6 NAICS match | SBA loans when the current owner or operator will not sign the Environmental Questionnaire; car-wash-only sites | Commercial purchases and loans; SBA loans with an Appendix 6 NAICS match (gas station loans add Appendix 7 requirements); buyers seeking CERCLA landowner protections |
| Request report | Order report for Desktop Screen | Order report for SBA RSRA | Order report for Transaction Screen | Order report for Phase I ESA |
Desktop Screen$199 flat
- Price
- $199 flat
- Turnaround
- Next business day
- Standard
- Database + historical review, EP opinion
- Site visit
- No
- Signed by an Environmental Professional
- Yes
- Accepted by the SBA
- No
- Performed to EPA’s AAI rule (one requirement for CERCLA landowner protections)
- No
- Best for
- First look before spending on a Phase I; buyers, brokers, low-risk conventional loans
SBA RSRA$695 flat
- Price
- $695 flat
- Turnaround
- 2 business days
- Standard
- SBA SOP 50 10 8.1
- Site visit
- No
- Signed by an Environmental Professional
- Yes
- Accepted by the SBA
- Yes
- Performed to EPA’s AAI rule (one requirement for CERCLA landowner protections)
- No
- Best for
- SBA loans over $250,000 with no Appendix 6 NAICS match
Transaction Screen$795 flat
- Price
- $795 flat
- Turnaround
- 4 business days
- Standard
- ASTM E1528-22
- Site visit
- Yes
- Signed by an Environmental Professional
- Yes
- Accepted by the SBA
- Yes
- Performed to EPA’s AAI rule (one requirement for CERCLA landowner protections)
- No
- Best for
- SBA loans when the current owner or operator will not sign the Environmental Questionnaire; car-wash-only sites
Phase I ESA$1,495 flat
- Price
- $1,495 flat
- Turnaround
- 5 business days
- Standard
- ASTM E1527-21 / AAI
- Site visit
- Yes
- Signed by an Environmental Professional
- Yes
- Accepted by the SBA
- Yes
- Performed to EPA’s AAI rule (one requirement for CERCLA landowner protections)
- Yes
- Best for
- Commercial purchases and loans; SBA loans with an Appendix 6 NAICS match (gas station loans add Appendix 7 requirements); buyers seeking CERCLA landowner protections
Your questions
Questions about the Phase I ESA.
Have a question about your property or transaction? Talk to our team.
What does the $1,495 flat price include?
Everything on the Environmental Professional’s side of an ASTM E1527-21 Phase I: regulatory and historical records, site visit, interviews, consideration of potential vapor migration, signed report and lender reliance, including the SBA Appendix 5 letter. Your own lien and activity and use limitation search is not included. It covers one parcel up to 5 acres, up to 3 buildings and 50,000 square feet in total, with a current use other than heavy industrial or manufacturing. Other properties, including multiple parcels, get a fixed quote before you authorize.
Does a Phase I include soil or groundwater testing?
No. A Phase I is a review of records and property history, a site visit and interviews, and EPA’s All Appropriate Inquiries rule does not require sampling. If the Environmental Professional identifies a recognized environmental condition and further investigation is warranted, sampling of soil, groundwater or soil vapor is a Phase II, scoped separately. Asbestos, lead-based paint, lead in drinking water and radon surveys are also separate from a Phase I, and you can order them from us.
Who performs the Phase I, and who visits my property?
An Environmental Professional who meets 40 CFR 312.10 forms the opinion, signs the report and makes the required declarations. A qualified local professional, booked when you authorize, performs the site visit under the Environmental Professional’s supervision, which 40 CFR 312.10 allows and the SBA accepts when the Environmental Professional reviews and signs the report. That is how we cover standard-scope properties nationwide at one flat price.
Will my lender or the SBA accept the report?
The report is written to ASTM E1527-21 and EPA’s All Appropriate Inquiries rule, signed by an Environmental Professional who meets 40 CFR 312.10, and delivered with the SOP 50 10 8.1 Appendix 5 reliance letter that SBA loans require. If your lender requires an approved data vendor, we attach an EDR, ERIS or Environsite radius report for $200. If noncompliance causes a lender or SBA rejection, we correct the report at no charge or, if we cannot, refund its fee; our engagement terms list the exclusions.
What happens if the Phase I finds a recognized environmental condition?
The report explains the finding and gives the Environmental Professional’s opinion on whether further investigation is warranted, often a Phase II that samples soil, groundwater or soil vapor where the concern is. On SBA loans, the lender must follow the Environmental Professional’s recommendations, including housekeeping items, or request an exception (SOP 50 10 8.1, Section A, Chapter 5, Paragraph E.4.e). We scope the Phase II and obtain fixed bids from licensed partners, so you keep one point of contact.
How long is a Phase I valid?
Under 40 CFR 312.20, five components must be conducted or updated within 180 days before acquisition: interviews, lien search, government records review, site visit and the Environmental Professional’s declaration. Everything else must be within one year. Both clocks run from the dates of the work, not the report date. The SBA will accept for review a Phase I dated within one year of the SBA loan number’s issue date, but notes that parties may want to meet EPA’s timeframes to protect their legal position. Updating our own report costs $595.
Move your transaction forward.
Scope, price and delivery date confirmed before you authorize. No payment online.