Alternative Compliance Path

I am working on a project that at the initial project team meetings and scorecard review it was indicated that the Phase 1 ESA had been done and that there were no significant issues. Now, I have been able to review the document, and it clearly indicates that the study has revealed REC's in connection with the subject property but no Phase 2 ESA was done. The project is now well under construction. On the positive side the issues that were revealed in the Phase 1 ESA have been addressed properly and legally and all of the work can be documented. My question is, is it a reasonable Alternative Compliance Path to submit the Phase 1 ESA Executive Summary and include documentation of the work, permits and activity that took place to address each of the conditions revealed by the Phase 1 ESA or can a follow-up Phase 1 be conducted prior to occupancy?