Is a Buyer’s Environmental Due Diligence the Same as the Lender’s?

You would think, yes. But, in many cases it turns out the answer is, no. There are significant differences between a buyer’s environmental due diligence and a what a lender’s environmental due diligence may require.
The phase one environmental site assessment (ESA) for a buyer is the most common (and comprehensive) report available. Adhering to the ASTM E1527-13 standard, the report should advise the buyer of any Recognized Environmental Conditions (RECs) as well as any Historical (HRECs), Controlled  (CRECs) and finally Business Risks. These Business Risks are conditions that do not require regulatory notification but still carry a financial burden for the buyer to correct.
The most common example of a Business Risk for a buyer is urban fill material. There are typically no regulatory requirements to address the material if left undisturbed. However, during a development/redevelopment of a site, fill material may require  special handling, transporting and disposal methods. There may be additional permits required by the local jurisdiction and the facility the material is taken to may have additional charges to accept it.
If a buyer is relying on a lender’s consultant to prepare an ESA to point this out, they may be disappointed. The relationship the lender has with their consultant is designed to protect them…the lender. With secured creditor exemption and other instruments at their disposal, the level of risk management conducted by lenders can be very different from a buyer’s expectations.
Lesser reports such as Transaction Screens and Desktop Reviews are also available to lenders to assist them with risk management but do not meet the All Appropriate Inquiry (AAI) rule established by the federal government. This rule is a key component for buyers so that if a problem arises in the future they can demonstrate that every effort was taken during the preparation of the phase one ESA to uncover a REC. Lenders very often have a different set of parameters to work within.
A buyer may also not have the ability to rely on that report as consultants can be reluctant to issue such a reliance. You should only have one client per project  and advocate towards the goal of that client.
So, no, there are differences between a buyer’s environmental due diligence and a lender’s environmental due diligence. As a buyer, you should understand the parameters of the report being prepared with the consultants you are hiring and insure they are using the ASTM E1527-13 standard. In addition, communicating your intentions for the property after purchasing will help your consultant advise and advocate for you the best way possible.