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Environment, Energy, & Resources
Amy L. Edwards and Meaghan A. Colligan
In July 2019, the U.S. EPA released its long-awaited Enforcement Discretion Guidance Regarding Statutory Criteria for Those Who May Qualify as CERCLA Bona Fide Prospective Purchasers, Contiguous Property Owners, or Innocent Landowners. The 2019 Guide supersedes EPA’s 2003 interim guidance on this topic and provides significant clarifications on several key elements of the landowner limitations on CERCLA liability.