The executive summary of a Phase I report

The body of the standard does not require an executive summary. One appears only in the suggested report format of a nonmandatory appendix, which says what a summary should and should not do. What the body does require is the Findings, the Opinions, the Conclusions and the environmental professional's statement.

What the standard requires

Nothing in the body. The body of the standard points to the appendix for a suggested report format and names no executive summary of its own (E1527-21, 12.1). The appendix calls its table of contents and format a suggested format only, whose sections may be placed elsewhere in the report at the professional's discretion (E1527-21, X5, introduction). By the standard's own account, its appendixes are there for information and stand outside the procedures it prescribes (E1527-21, 4.10).
What the body requires elsewhere. The report shall have a Findings section, the professional's opinions with their rationale, a Conclusions section, and a closing statement substantially similar to one of the two the standard sets out (E1527-21, 12.5, 12.6, 12.7). It shall also describe the services performed, list limiting conditions and deviations, give references, be signed, and carry the professional's statement and an appendix section (E1527-21, 12.4, 12.11, 12.12, 12.13, 12.14, 12.15).
What the appendix says a summary is. A summary of the assessment process that may include findings, opinions and conclusions, giving a concise and clear view of the main findings. It should give the key evidence behind each recognized environmental condition (REC), controlled REC, historical REC, significant data gap and de minimis condition identified, and behind any recommendations, without repeating the detail in the body. The user should be able to understand the critical information from it (E1527-21, X5.1).
Length and tables. In general it should run to no more than two pages. It may include a summary table of the classes identified, but should not consist solely of a table that leaves the basis of the findings unexplained (E1527-21, X5.1.1).
Plain explanation. It should carry supporting or explanatory language as needed, avoid unnecessary technical detail, and not copy whole sections of the report (E1527-21, X5.1.2).
Nothing new. It should not introduce information, findings, opinions or conclusions that are not elsewhere in the report (E1527-21, X5.1.3).
Recommendations. The practice does not require recommendations (E1527-21, 12.9). Where they are provided at the user's request and the suggested format is followed, the appendix says they should be in the executive summary (E1527-21, X5.1.4). Additional services should be in the report only where the terms of engagement specify them (E1527-21, 12.10).

What the federal rule says

The rule does not mention an executive summary. What it requires of the report is this:

The results of the inquiry by an environmental professional must be documented in a written report that, at a minimum, includes the following:

40 CFR 312.21(c)

The three things that follow are the professional's opinion, an identification of data gaps with comments on their significance, and the professional's qualifications (40 CFR 312.21(c)(1) to (3)). The signed declarations are required separately (40 CFR 312.21(d)).

How it is written

Following the appendix, a summary says in a sentence or two what was done, then gives the main findings, each with its key evidence and the class the professional judges applies, then the significant data gaps, then where the Conclusions are, then any recommendations the user asked for. Each statement in it can be traced to a section of the report. A table may help the reader, with words beside it that give the basis.

Example, with the facts in brackets:

[The firm] assessed [the subject property] for [the user]; the work is described in [the section]. Main findings: [the finding], on [the key evidence], judged [the class the professional judges applies] for the reasons in [the section]. Significant data gaps: [the gaps, or none]. The Conclusions are stated in [the section]. [Recommendations, only if the user asked for them.]

What a reviewer checks

The first four checks rest on what the nonmandatory appendix says a summary should do; none is a requirement of the standard. The last two rest on its body.

Is everything in the summary also found elsewhere in the report (E1527-21, X5.1.3)?
Does the summary give the key evidence for each class and each significant data gap it names (E1527-21, X5.1)?
If it has a summary table, is the basis of the findings explained beside it (E1527-21, X5.1.1)?
Is it, in general, no more than two pages (E1527-21, X5.1.1)?
Does the report still carry its Findings, Opinions and Conclusions sections and the professional's statement (E1527-21, 12.5, 12.6, 12.7, 12.14)?
Does the report show that the terms of engagement specify any recommendations it holds (E1527-21, 12.9, 12.10)?

This page is general reference for environmental professionals. It does not classify any property. ASTM E1527-21 is the standard and is not reproduced here; the judgment of the environmental professional on the facts governs.