Response to Comment Document, All Appropriate Inquiries Regulation, Part 3

SECTION 4: Comments on the Economic Impact Analysis Commenter Organization Name: Lourie Consultants Comment Number: 0353 Excerpt Number: 3 Excerpt Text: It's my opinion that cost for complying with the proposed AAI rule will not be significantly different from the cost of performing a thorough, well-conducted ESA according to current ASTM E 1527 guidelines. Response: EPA thanks the commenter for the stated position on the burden under the rule. EPA agrees that the cost of complying with the AAI rule will not be significantly different from the cost of complying with the ASTM E1527-2000. Commenter Organization Name: Dismukes, James Comment Number: 0416 Excerpt Number: 5 Excerpt Text: The cost analysis does not state the average cost range that was used in estimating the economic impact but the document states that in addition to commercial data the EPA used the cost for Phase I's performed on Brownfield sites. These cost are extremely high compared to the commercial property transaction Phase I costs. In our areas of operations, Phase I's average costs are between $900 to $1600 for a standard ASTM Phase I. Response: EPA thanks the commenter for stating his position regarding the potential burden of the rule. In the Economic Impact Analysis (EIA) for the proposed rule, EPA developed a range of unit costs for performing a Phase I ESA under the ASTM E1527-2000, where the range was based on the distribution of properties by size and type. In ...