As EPA Touts Benefits, Attorneys Fear EJ Fixes To Model CERCLA Forms

September 20, 2021
Industry attorneys are eyeing whether EPA’s revamped model consent decree for Superfund enforcement agreements will speed negotiations and cleanups, while saying additions EPA made to a related work document requiring more community involvement to support environmental justice (EJ) commitments will add time and money to the process. “While the revisions simplify and reduce redundancies in several sections, including dispute resolution, payment of response costs, and property requirements, we will see if the previously slow negotiations were the result of excess...

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