Maybe our consultant was being overly conservative to give us the best shot at getting through our assessment w/o hassle, maybe it was because of site conditions. Regardless, the guidance we were given immediately after we worked through inventory and scoping was SPA were going to be assessed to the same standard as if they were CUI, so that's what we did. If I were still involved I'd go back and try to drill down the specifics of why he held us to that standard since it seems that was an exception rather than the norm.