EPA Moves to Require New All Appropriate Inquiries Standard

July 11, 2014
Bruce S. Katcher
The Legal Intelligencer

As a result of a series of actions initiated by the U.S. Environmental Protection Agency (EPA) last summer to modify and upgrade its Standards and Practices for All Appropriate Inquiries Rule at 40 C.F.R. Part 312 (AAI Rule), prospective property purchasers, lenders and their environmental consultants have been eagerly awaiting greater clarity as to what practices to follow in performing pre-purchase environmental due diligence. On June 17, the EPA proposed a rulemaking intended to bring closure to the upgrading process that instead brought incremental clarity and some continuing confusion.

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