Environmental

The 'innocent landowner' defense requires, among other things, that the buyer conducted 'all appropriate inquiry.' For most commercial transactions, this means performing at minimum a:

APhase II ESA with soil samples
BPhase I Environmental Site Assessment✓ Correct
CCERCLA-compliant remediation plan
DCalifornia Hazardous Waste Permit application

Explanation

To qualify for the innocent landowner defense under CERCLA, a buyer must conduct all appropriate inquiry prior to purchase. For most commercial transactions, performing a Phase I ESA that meets ASTM standards satisfies this requirement. If RECs are found, a Phase II ESA may be warranted.

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