Modifying No Further Action Letters

Under the new privatized Site Remediation Program, consultants are confronted with situations where previously issued No Further Action Letters (NFAs) have been issued “conditionally”, with a Deed Notice or Classification Exception Area (CEA).  In certain instances, CEAs can be lifted where contaminants have degraded to acceptable levels and therefore would have warranted an “unconditional NFA” [...]

Clean Bill Of Health, Without The Clean

Under the old framework at NJDEP, a responsible party would typically petition NJDEP for a “No Further Action Letter” (NFA).  As custom would have it, purchasers and lenders in real estate transactions would request an NFA confirming the obvious – that is—that, literally, no further action is required because the property has been remediated to [...]