EPA released guidance entitled Enforcement Discretion Guidance Regarding Statutory Criteria for Those who May Qualify as CERCLA Bona Fide Prospective Purchasers, Contiguous Property Owners, or Innocent Landowners (referred to as the “Common Elements” Guide).  The 2019 Common Elements Guide supersedes the 2003 Interim Guide and lists certain steps that a prospective property owner must establish to qualify for the defenses.  Read more