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All Appropriate Inquiries (AAI)

AAI is the process of evaluating a property's environmental conditions and assessing potential liability for contamination, referenced by EPA in relation to Phase I environmental site assessments and CERCLA liability protections. EPA states that ASTM E1527-21 and E2247-23 are consistent with AAI rule requirements (40 CFR Part 312) and may be used to satisfy statutory AAI requirements for certain liability protections.

Where it applies
Federal
When it comes up
Due diligence; acquisition underwriting
Property types
All acquisitions; especially redevelopment and brownfield-adjacent

In practice

Operators should treat AAI timing requirements and reliance letters as transaction-critical components of environmental diligence packages.

Related terms

Phase I ESAEnvironmental ProfessionalCERCLABona Fide Prospective Purchaser