Who can perform a Phase I?

The AAI rule and ASTM E1527-21 require that a Phase I be performed by, or under the supervision or responsible charge of, an environmental professional (EP). That is a defined term, not a self-designation. A person qualifies through one of these routes:

• A current Professional Engineer or Professional Geologist license plus 3 years of relevant full-time experience;
• Another government-issued license or certification to perform environmental inquiries plus 3 years of relevant full-time experience;
• A bachelor's degree or higher in science or engineering plus 5 years of relevant full-time experience; or
• 10 years of relevant full-time experience.

Relevant experience means participation in all appropriate inquiries, environmental site assessments, or other site investigations involving environmental analyses, investigations, and remediation, work that builds judgment about surface and subsurface conditions. The EP signs a declaration in the report stating that they meet the definition and that the inquiry was conducted in conformance with the standard.

What buyers and lenders should actually check: not just that a firm is large or insured, but who is in responsible charge of the report, whether that person meets the definition, and whether the report contains the required declaration and the EP's qualifications. The Phase I's value is the judgment of the professional standing behind it. The signature block tells you whose judgment that is.