If you landed here, there’s a decent chance you’re under contract on a property, a lender just told you they need a Phase I, and you typed something like “who does phase 1 environmental site assessment near me” into Google. Welcome. You’re in the right place, and we’ll make this quick.
Here’s the short version: a Phase I Environmental Site Assessment (often written “Phase 1 ESA”) has to be performed by an Environmental Professional, a role defined in the EPA’s All Appropriate Inquiries rule at 40 CFR Part 312. In Texas, the firm that EP works for generally needs current state registration to offer that work to the public. Beyond those baselines, the quality of what you get back varies a lot more than most buyers expect. Before you hire anyone, ask these five questions:
- Who will actually sign the report, and is the firm registered in Texas?
- Which ASTM standard will the report be prepared under?
- Will the report come with a reliance letter, and can it name my lender?
- Does the firm work with the agencies that actually have jurisdiction over this property?
- What’s the turnaround, and what happens if something turns up?
Now the longer version, and why each one matters.
Who does a Phase 1 environmental site assessment?
Phase 1 ESAs are performed by environmental consulting firms, and specifically by an Environmental Professional working under that firm. In Texas that firm generally needs current state registration to offer the work publicly. There’s no licensing board that issues a “Phase 1 inspector” credential, which is exactly why the questions below matter.
And what does “near me” actually get you?
We’re going to be honest about something that isn’t exactly in our interest as a Texas firm with an office in Rosenberg: for a Phase I, physical proximity matters less than you’d think.
Most of a Phase I is records work. Historical aerial photography, fire insurance maps, title and chain-of-title review, state and federal environmental databases, agency files, interviews. None of that cares whether the consultant’s office is twenty minutes away or two hours away.
Where proximity genuinely helps is the site visit, the turnaround, and what happens afterward if the report recommends further investigation. A firm that can get someone out next Tuesday instead of next month is worth something real when you have an option period running.
But here’s the thing that matters more than distance: whether the firm knows the Texas agencies that have jurisdiction over your specific property. A national vendor with a call center can produce a report. Whether that report reflects how TCEQ or the Railroad Commission actually handles a file in this state is a different question.
So when you search “near me,” what you probably mean is “licensed in Texas and fluent in Texas.” Those aren’t the same thing, and only one of them shows up on a map.
Question 1: Who will actually sign the report, and is the firm registered in Texas?
The Environmental Professional isn’t a job title
“Environmental Professional” sounds like something anyone in the industry could call themselves. It isn’t. The AAI rule sets out specific education, licensing and experience requirements for who qualifies to render the opinions in a Phase I. The EP is the person putting their name on the conclusions.
So ask who that person is. Not the salesperson, not the project coordinator. The EP.
Texas adds a layer
Under the Texas Geoscience Practice Act, a firm offering non-exempt public geoscience services in Texas needs to be registered with the Texas Board of Professional Geoscientists. A firm licensed through the Texas Board of Professional Engineers can also offer or perform that work where a licensed engineer is in responsible charge.
What this means practically: ask for the firm registration number. A legitimate firm will give it to you without a pause, and you can verify it.
Red flag: the firm can’t tell you who will sign the report, or gets vague about registration.
Question 2: Which ASTM standard will the report be prepared under?
This one catches people, and it’s the easiest to check.
The current standard practice for commercial and industrial property is ASTM E1527-21. The EPA recognizes it as satisfying All Appropriate Inquiries. The previous version, E1527-13, stopped satisfying AAI in February 2024. If a firm is still running a 2013-era template, that’s a problem you’d rather find now than at closing.
If your property is rural, agricultural or forestland, there’s a separate standard written for exactly that situation: ASTM E2247-23, which the EPA recognized effective August 2024. It’s built around how large rural tracts actually work, including heavier reliance on historical aerial review. Most firms don’t mention it. If you’re buying acreage, ask.
One honest clarification, because you’ll hear this stated wrong: the AAI regulation itself does not require you to use the ASTM standard. ASTM isn’t an EPA regulation. But lenders, attorneys and institutional buyers expect it, so in practice it’s the standard of care.
What a good answer sounds like: the firm names the standard immediately and explains why that one fits your property type.
Question 3: Will the report come with a reliance letter, and can it name my lender?
Of all five questions, this is the one that most often turns into a late-stage headache, and almost nobody asks it up front.
A reliance letter is the document that entitles a party to rely on the report. If your lender isn’t named as an entitled user, they may not accept it. SBA environmental policy, for instance, requires a reliance letter accompany the assessment.
Picture a situation that comes up more than it should: a buyer orders a Phase I early, feeling organized and ahead of schedule. Three weeks later the lender’s environmental reviewer looks at it and says the report doesn’t name them. Now you’re asking the original consultant to issue a letter, which they may or may not do quickly, or you’re paying for work twice with a closing date approaching.
Ten seconds of asking at the start prevents all of it.
What a good answer sounds like: reliance letters are routine, and the firm asks you who needs to be named before the work starts.
Question 4: Does the firm know which agency has jurisdiction here?
This is where Texas-specific knowledge earns its keep, and where generic vendors tend to stumble.
TCEQ handles most commercial and industrial sites
The Texas Commission on Environmental Quality runs the programs most buyers encounter: the Voluntary Cleanup Program, which can provide a release of liability from the state once a cleanup is certified and which carries forward to future owners, and the Innocent Owner/Operator Program, which issues a certificate when contamination came from an off-site source. Worth knowing: unlike the VCP release, an innocent owner certificate does not transfer to future owners.
Oil and gas is the Railroad Commission, not TCEQ
This surprises people constantly. Oil and gas waste in Texas falls under the Railroad Commission of Texas, which runs its own voluntary cleanup program issuing its own certificates of completion. Different agency, different file, different path.
If you’re buying a tract with production history and your consultant starts talking about TCEQ for the oilfield portion, that’s a signal.
What a good answer sounds like: the firm can tell you which agency your property falls under before you’ve finished describing it.
Question 5: What’s the turnaround, and what happens if something turns up?
Tie the schedule to your deadline, not to a generic number
Don’t ask “how long does this take.” Ask “can you deliver before my option period ends on the 14th.” Those are different questions and only one of them is useful.
Reports have a shelf life
Two timing rules worth knowing. Under the ASTM standard, an assessment generally needs to have been completed within 180 days of the acquisition date to stay viable. And SBA expects environmental reports to be dated within one year of the issuance of the loan number. A report that was perfectly good in the spring can be useless at a fall closing.
This is also why the seller’s old report often doesn’t solve your problem. A prior assessment can be useful background, but it can’t be relied on as representative of current conditions.
Be clear about what a Phase I is and isn’t
A Phase I identifies recognized environmental conditions and states whether further investigation is warranted. It does not include sampling. No soil, no groundwater, no lab work. That’s a Phase II.
If a recognized environmental condition shows up, that isn’t automatically a dead deal. Plenty of transactions close with known conditions, and federal law specifically accommodates this: bona fide prospective purchaser status allows a buyer to acquire a property knowing it’s contaminated and still be protected, provided All Appropriate Inquiries was completed beforehand and the continuing obligations are met.
The thing that kills deals isn’t a finding. It’s a finding nobody saw coming two days before closing.
And the deadline that doesn’t move
All Appropriate Inquiries has to be completed before you acquire the property. It can’t be performed afterward. That’s the one rule with no workaround, and it’s the real reason to start early rather than treating the Phase I as a box to check in the final week.
Four red flags when you’re comparing quotes
- A quote that doesn’t name the standard. If it doesn’t say E1527-21 or E2247-23 anywhere, ask why.
- No mention of a reliance letter, or one that appears as a surprise line item later.
- A turnaround with no date attached. “Two to three weeks” is not a commitment.
- A price well below everyone else with no scope to explain it. Sometimes that’s efficiency. Sometimes it’s a desktop review wearing a Phase I’s clothes.
Working with CRG Texas
We’re based in Rosenberg and we work throughout Texas, from the Houston and Dallas-Fort Worth metros to rural tracts and energy properties where the file is more complicated than the acreage suggests. We handle Phase 1 and Phase 2 assessments, environmental due diligence, and the agency work that follows. [Firm registration no. XXXXX]
If you’ve got a property under contract, send us three things: the county, the property type, and your closing timeline. We’ll come back with scope and pricing.
Frequently asked questions
Who does a Phase 1 environmental site assessment near me?
Environmental consulting firms perform Phase 1 ESAs, through a qualified Environmental Professional. In Texas, check that the firm holds current state registration and ask who will sign the report. CRG Texas performs Phase 1 and Phase 2 assessments statewide from our office in Rosenberg.
Is a Phase I ESA required by law?
Not exactly. The AAI rule doesn’t compel you to order one. But completing All Appropriate Inquiries is the condition for the CERCLA landowner liability protections, and most commercial lenders require an assessment as a condition of financing. So in practice, for most transactions, yes.
Can I just use the seller’s Phase I report?
Usually not on its own. A prior assessment may be used as guidance, but it cannot be relied on as representative of current conditions, and it likely doesn’t name you or your lender as entitled users.
What’s the difference between a Phase I and a Phase II?
A Phase I is records review, a site visit and interviews, resulting in an opinion about recognized environmental conditions. A Phase II is the investigation that follows when a Phase I says more work is warranted, and it does involve sampling.
Does a Phase I include soil or groundwater testing?
No. A Phase I is non-intrusive. If testing is needed, that’s a Phase II.