All Appropriate Inquiries Rule:
Reporting Requirements Checklist for Assessment
and Multipurpose Grant Recipients
WHAT IS "ALL APPROPRIATE INQUIRIES?"
"All appropriate inquiries," or AAI, is a process of evaluating a property's environmental conditions and
assessing the likelihood of any contamination. Every Phase I environmental assessment conducted with EPA
Brownfields Assessment Grant funds must be conducted in compliance with the AAI Final Rule at 40 CFR
Part 312. The AAI Final Rule provides that the ASTM E1527-21 "Standard Practice for Environmental Site
Assessments: Phase I Environmental Site Assessment Process" and ASTM E2247-23 "Standard Practice for
Environmental Site Assessments: Phase I Environmental Site Assessment Process for Forestland or Rural
Property" are consistent with the requirements of the final rule and may be used to comply with the provisions
of the rule. In addition, AAI must be conducted in compliance with the Final Rule or the ASTM standard to
obtain certain protections from liability under the federal Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) as an innocent landowner, contiguous property owner, or bona
fide prospective purchaser.
WHAT ARE THE DOCUMENTATION REQUIREMENTS FOR ALL APPROPRIATE INQUIRIES?
The final rule requires that the results of an AAI investigation be documented in a written report. The
specific reporting requirements are provided in 40 CFR §312.21 and §312.31 of the final rule and ASTM
E1521-21 and E2247-23 standards. All AAI final reports nuist, at a minimum, include the following:
1. An opinion as to whether the inquiry identified conditions indicative of releases or threatened releases
of hazardous substances, and as applicable, pollutants and contaminants, petroleum or petroleum
products, or controlled substances, on, at, in, or to the subject property.
2. An identification of "significant" data gaps (as defined in §312.10 of AAI final rule and §12.5 of
ASTM El 527-21), if any, in the information collected for the inquiry. Significant
data gaps include missing or unattainable information that affects the ability of the environmental
professional to identify conditions indicative of releases or threatened releases of hazardous substances,
and as applicable, pollutants and contaminants, petroleum or petroleum products, or controlled
substances, on, at, in, or to the subject property. The documentation of significant data gaps must
include information regarding the significance of these data gaps.
3. Qualifications and signature of the environmental professional(s). The environmental professional
must place the following statements in the document and sign the document:
• "[I, We] declare that to the best of [my, our] professional knowledge and belief [I, we] meet the
definition of Environmental Professional as defined in §312.10 of this part. "
• "[I, We] have the specific qualifications based on education, training, and experience to assess a property of
the nature, history, and setting of the subject property. [I, We] have developed and performed the all
appropriate inquiries in conformance with the standards and practices set forth in 40 CFR Part 312. "
Note: Please use either "I" or "We."
4. In compliance with §312.31(b) ofthe AAI final rule and §12.6 of ASTM E1527-21,
the environmental professional must include in the final report an opinion regarding additional
appropriate investigation, if the environmental professional has such an opinion.
For each Phase I Environmental Site Assessment, or AAI, conducted using EPA Brownfields Grant funds, the
grant recipient must complete, sign, date, and submit the following checklist with any AAI reports submitted
to EPA.
Also see U.S. EPA's website at www.ena.
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Checklist for Phase I Site Assessments Conducted using EPA Brownfields
Assessment Grant Funds
Contact Information
Grant Recipient Name:
Grant Number:
ACRES Property ID:
Program Manager Name:
(Point of Contact)
Contact Phone Number:
Name I Address of Property Assessed:
Checklist
Please indicate that each of the following All Appropriate Inquiries documentation requirements were
met for the Phase I assessment conducted at the above listed property:
~ An opinion as to whether the inquiry has identified conditions indicative of releases or threatened
releases of hazardous substances, and as applicable, pollutants and contaminants, petroleum or
petroleum products, or controlled substances, on, at, in, or to the subject property.
An identification of "significant" data gaps as defined in §312.10 of AAI final rule and §12.5 of
ASTM El 527-21), if any, in the information collected for the inquiry, as well as comments
regarding the significance of these data gaps. Significant data gaps including missing and
unattainable information that affects the ability of the environmental professional to identify
conditions indicative of releases or threatened releases of hazardous substances, and as
applicable, pollutants and contaminants, petroleum or petroleum products, or controlled
substances, on, at, in, or to the subject property.
Qualifications and signature of the environmental professional(s). The environmental
professional must place the following statements in the document and sign the document:
"[I, We] declare that to the best of[my, our]professional knowledge and belief [1, we] meet the definition of
Environmental Professional asdefmed in §312.10 of this part. "
"[I, We] have the specific qualifications based on education, training, and experience to assess a property
of the nature, history, and setting of the subject property. [I, We] have developed and performed the all
appropriate inquiries in conformance with the standards and practices set forth in 40 CFR Part 312. "
Note: Please use either "F' or "We."
In compliance with §312. 31 b) of the AAI final rule and §12.6 of ASTM El 527-21, the
environmental professional must include in the final report an opinion regarding additional
appropriate investigation, if the environmental professional has such an opinion.
Signature of Program Manager Date
Brownfields Fact Sheet Office of Land and EPA 560-F23-017
AAI: Reporting Requirements and Emergency April 2023
Grant Recipient Checklist Management (5105) winv.epa.gov/brmvnfields
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