Final Environmental Approvals: Wait Just a Second — You’ve Been Audited
Let’s face it, when NJDEP was in the business of issuing “No Further Action Letters” (NFA), a developer or party responsible for a cleanup, had some sense of finality and comfort that the NFA signaled the end of the road, and would limit future costs. Under the LSRP program, the consultant, not DEP, will issue [...]
Duty to Remediate: Are You on DEP’s Radar?
The Site Remediation Reform Act (SRRA) confirmed what I have been counseling clients for years. In general, if you are a “responsible party” (RP) for remediation, there are just too many ways the State may enforce your obligation to investigate and remediate a release of hazardous substances. Now, under the LSRP program there is simply [...]
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