U.S. Small Business Administration (SBA) has updated its environmental requirements for the 7(a) and 504 loan programs effective January 1, 2018. SBA’s SOP 20 10 5 (J) includes a tiered approach for its environmental review process, depending on the use of the site and loan amount.
Most of these requirements are familiar to those who have been involved with SBA lending the last several years, but there are a few changes to note:
- SBA now specifies that the ‘Records Search with Risk Assessment’ (RSRA) must include historical records back to the property’s first developed use, or back to 1940, whichever is earlier. Previously, SBA did not specify a year for its historic research requirements but left it up to the Environmental Professional’s discretion. In addition, this RSRA must include all supporting documentation.
- All dry cleaners currently in operation at the site require a Phase II Environmental Site Investigation. Previously, the Phase II was only mandatory if a dry cleaner had been in operation at the property at least 5 years.
- SBA specifies that vapor intrusion must now be addressed for dry cleaners, in additional to soil and groundwater contamination.
- Environmental Professionals must review tank and equipment testing compliance documentation for all gas stations and include this documentation in the Phase I ESA appendices.
- SBA added new NAICS codes to its list of “environmentally sensitive industries.”
Gabriel is pleased to be a trusted partner for SBA lenders. Our environmental reports will meet all new requirements in January 2018. If you have any questions about our SBA-compliant reports, contact Natalie Neuman, Group Leader Assessment Services, at nneuman[at]gabenv.com or 773-486-2123.