EPA Enables Confusing 2-Tier System

Law360, New York (September 13, 2013, 12:49 PM EDT) -- In a direct final rule and proposed rule published in the Aug. 15 issue of the Federal Register[1], the U.S. Environmental Protection Agency announced that parties seeking to comply with the “all appropriate inquiries”[2] (AAI) rule may use a forthcoming version of the ASTM standard practice for performing phase I environmental site assessments (known as E1527-13)[3].

Owners and operators of property who seek to qualify for various liability protections under the federal Comprehensive Environmental Response, Compensation and Liability Act[5] are required to comply with AAI prior...
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