![]() ![]() The rule change EPA has now proposed would delete the reference to the 2005 version of E1527. The anomalous result was a Federal rule reference to a standard that the issuing organization viewed as superseded and the EPA itself seemed to disfavor. EPA itself, in the preamble to the December 2013 rule change, “recommended” and “strongly encouraged” use of the revised standard. The differences between E1527-05 and E1527-13, though arguably incremental, are not insignificant. The retention of the reference to the superseded 2005 version of the ASTM standard in the AAI rule was widely criticized as a source of potential confusion. The December 2013 rule change, summarized here, did not delete reference to the 2005 version. In doing so, however, EPA only adopted the revised standard. In December 2013, EPA revised the AAI rule to recognize the new version as an alternative to AAI. In accordance with its practice for periodic review of standards, ASTM revised and republished the Phase I standard in 2013 as E1527-13. The ASTM standard referenced in the rule, revised in parallel with development of the AAI rule, was published the same year as E1527-05. Part 312, EPA recognized ASTM standard practice E1527 as an acceptable alternative means of performing the pre-purchase investigation necessary to qualify for certain landowner liability protections under the Comprehensive Environmental Response, Compensation and Liability Act. In the original AAI rule published in 2005, 40 C.F.R. The Federal Register notice of the proposed action is here. This proposal would resolve a widely-criticized anomaly resulting from a December 2013 revision to the All Appropriate Inquiry (AAI) rule. ![]() On June 17, 2014, the United States Environmental Protection Agency published a proposal to delete reference to the 2005 version of the ASTM Phase I environmental site assessment standard from the federal “all appropriate inquiry” rule. ![]()
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