We always conduct asbestos surveys (assessments) in accordance with the LRAPA regulations Title 43. LRAPA regulations are similar to CFR chapter 40 part 763 / AHERA regulations, but they don’t have the same requirement for sample quantity. Will a survey / assessment under LARPA be a sufficient substitution for a Phase II ESA (in lieu of documenting compliance with CFR chapter 40 part 76) ?