By Ellen Radow Sadat, Esq.  &  Joseph Schmidt, Esq. 

The New Jersey Department of Environmental Protection (”DEP”) is taking another weapon out of its abundant arsenal, which may make it harder to implement reasonable remedial actions and delay cleanups.  Under draft guidance, titled “Requirements for Remedial Actions Rendering Properties Unusable,” issued on October 5, 2009, DEP plans to implement a seemingly innocuous provision of the Site Remediation Reform Act (“SRRA”): » Read the rest of this entry «