Phase I ESA report sections, drafted from your file for your environmental professional to finish and sign.

A Phase I file fills up over a week or two: the engagement letter and the user's answers, a regulatory database report, aerial photographs, fire insurance maps and city directories, notes from calls with the owner and occupants, and a reconnaissance with photos and a field checklist. Then someone writes it all up in your firm's template, section by section, before the environmental professional reviews it and writes the opinion.

For the test, AI reads copies of finished files and drafts the sections that describe what was found: site and setting, user-provided information, the records review by database and distance, historical use period by period, the reconnaissance and the interviews, with the date of each component. Findings, opinions, conclusions and the declaration stay empty. Your reviewer reads each draft beside the signed report that went to the client.

Five dates matter more than the report date. Under 40 CFR 312.20, the inquiry must be done within one year before the client takes title, and five parts must be done or updated within 180 days before it: the interviews, the search for recorded environmental cleanup liens, the review of government records, the visual inspection and the environmental professional's declaration. ASTM E1527-21 asks for the date of each of those parts in the report, adds the lien search date when your firm ran the search, and warns that the report date generally is not the date any of them was done. The draft takes each date from the document in the file that shows it and flags any part it can't date.

The records review has set distances. Section 312.26 lists what to search around the property: NPL sites and RCRA facilities under corrective action within a mile; state and tribal cleanup and brownfields sites, leaking underground storage tanks, delisted NPL sites, engineering control registries, former CERCLIS sites with no further remedial action, and landfills within half a mile; RCRA small and large quantity generators and registered storage tanks on adjoining properties. The environmental professional may change a distance for reasons such as groundwater flow direction or how densely the area is built, and must write down why. The draft reports each listing at the distance your report used and never moves one.

A database report leaves work for the reader. LightBox describes its EDR Radius Map Report with GeoCheck as listing mapped records with a map ID, distance, direction and relative elevation, a separate orphan summary of records that can't be plotted because the address is incomplete, and GeoCheck's physical setting data on topography, hydrology, hydrogeology, wetlands, flood zones, soils and geology. An orphan can still be the subject property under an old address or a former tenant's name. The draft checks every orphan's street and name against the subject and adjoining addresses in your field notes and lists each possible match for the EP.

History, interviews and the visit each have a minimum. Historical records must reach back to when the property first had structures or was first put to residential, agricultural, commercial, industrial or governmental use; the rule names aerial photographs, fire insurance maps, building department records, chain of title documents and land use records. Interviews must include the current owner and occupant, and on a multi-tenant property the major occupants and any likely to handle hazardous substances. Every physical limit on the visual inspection must be noted, and the rule says a voluntary seller's refusal of access alone doesn't excuse an on-site visit. The draft shows the years each source covers and lists every gap in coverage, missing interview and noted limitation, for the EP to judge as a data gap or not.

Opinions belong to the environmental professional. The written report must give the EP's opinion on whether the inquiry found conditions indicative of releases, the data gaps and their significance, and the EP's qualifications, and the EP signs two declarations set out word for word in 312.21(d). E1527-21 defines a recognized environmental condition in three parts: a release, a likely release, or a material threat of a future one, and says a de minimis condition is not one. Since July 8, 2024, PFOA and PFOS, with their salts and structural isomers, have been listed as CERCLA hazardous substances in 40 CFR 302.4, so a records hit or interview note about them goes to the EP like any other. Your reviewer will check every date, distance, listing, source year and interview against the issued report, and confirm the draft offered no opinion of its own.

Once your reviewer says yes, new Phase I files get the same drafting for about 30 days.

Each draft goes to your environmental professional to correct, complete and sign. Findings, opinions, conclusions and any recommendations are theirs to write, and your firm sends the report to the client as it does today.

Your reviewer keeps comparing drafts with what the EP would have written. Nothing else joins the work until those 30 days end.