In 1993 the U.S. Environmental Protection Agency (EPA) responded to the brownfields issue with its Brownfields Economic Redevelopment Initiative. The intent of this initiative was to empower states, localities, and other agents of economic redevelopment to work together in a timely manner to prevent, assess, safely clean up, and sustainably reuse brownfields. At the heart of this initiative were a number of pilot projects (Cleveland, OH; Richmond, VA; and Bridgeport, CT) aimed at developing effective approaches to cleaning up and redeveloping abandoned industrial sites.

On January 25, 1995, EPA Administrator Carol Browner announced the Brownfields Action Agenda which outlined EPA’s activities and future plans to help realize the benefits of the Brownfields Initiative. The efforts outlined in the Brownfields Action Agenda can be grouped into four broad and overlapping categories. In the first category there was a significant expansion of the Brownfields Pilot Project
program - up to 50 additional communities by the end of 1996. By July 1995, EPA had already announced the addition of 15 new pilot projects.

Environmental due diligence is on the brink of change. Some subtle. Others more substantive. The changes stem from EPA's mandate pursuant to the January 2002 Small Business Liability
Relief and Revitalization Act (the Federal Brownfields Law) to write the nation's first federal standards for conducting "All Appropriate Inquiries,” the process by which a property's potential for environmental contamination is investigated prior to purchase. Congress laid out a 10-step framework
for what constitutes AAI, and gave EPA two years to write the regulation (by January 11, 2004).
In April 2003, EPA tasked a broad-based 25-member stakeholder committee to write the rule using
a regulatory-negotiation (reg-neg) process under the Federal Advisory Committee Act (FACA).
On November 14, 2003, after more than 100 hours of discussion and debate, the reg-neg committee
reached consensus on a draft rule for the first federal standards and processes for conducting AAI. The final consensus draft rule__to be eventually codified in federal regulation, "Part 312 - Standards
for Conducting All Appropriate Inquiries"__follows the ASTM E 1527-00 standard in many areas, but it does add certain new levels of investigation. This article covers 10 key facts about the draft AAI rule (see
sidebar), including its applicability, requirements for Phase I professionals, and its most notable differences with current industry practice.