ASTM's ESA Standard Now Complies with AAI Rule

The U.S. Environmental Protection Agency has determined that the 2008 revision to an ASTM International standard describing the environmental assessment needs of parties involved in the acquisition of forestland and rural properties is now compliant with the agency's All Appropriate Inquiries Rule (40 CFR Part 312, Standards and Practices for All Appropriate Inquires).

The EPA decision came in a direct final rule amending the All Appropriate Inquiries Regulations (40 CFR 312). According to the ruling, which formally went into effect on March 23, ASTM International standard, ASTM E2247-08, Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process for Forestland or Rural Property, is now compliant with the AAI rule.

ASTM E2247 was first published in 2002 and covers instructions for conducting environmental assessments of undeveloped rural and forestland of 120 acres or greater and for tracts of 120 acres or greater with developed uses limited to managed forestland and/or agriculture. However, following promulgation of EPA's 2005 AAI rule, ASTM E2247 was not recognized as compliant with AAI and therefore could not be used to assist persons in meeting a requirement for claiming landowner liability protections available under the Comprehensive Environmental Response, Compensation and Liability Act.

"The EPA and ASTM task group worked closely through the revision process to ensure a technically sound practice for complying with the AAI rule while meeting the unique needs of those involved in transactions of large acreage forest and rural land," says David Parsonage, vice president, American Geosciences Inc., and chair of the ASTM E2247 task group.

ASTM E2247-08 is under the jurisdiction of Subcommittee E50.02 on Real Estate Assessment and Management, part of ASTM International Committee E50 on Environmental Assessment, Risk Management and Corrective Action.

Revisions made to ASTM E2247 and approved in 2008 allow the standard to clearly address site assessment issues involving property uses and environmental concerns typical of forestland and rural property. Parsonage states "To accommodate the inaccessibility and remoteness of many large forestland and rural properties, the standard provides for the use of remote sensing methods such as aerial photography or flyovers during the site reconnaissance process to identify suspect areas for closer, on-the-ground inspection. This differs from the site inspection methodology used in typical commercial real estate transactions but is necessary to reflect standard industry practice and to preserve the cost- and time-effectiveness of these assessments while meeting the requirements of the AAI rule."

ASTM E2247-08 is used by the forest industry, other natural resources industries, conservation organizations, forest and rural real estate professionals, lenders, resource management agencies, and environmental consultants.

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