Steven L. Humphreys

Kelley Drye & Warren LLP

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Recently by Steven L. Humphreys

The Vapor Intrusion Rub: EPA’s Adoption Of ASTM’s New Phase I Standard Muddies The Waters Of CERCLA Liability Once Again

Introduction On December 30, 2013, the U.S. Environmental Protection Agency adopted a final rule officially embracing the newly minted ASTM E1527-13 Standard Practice for Phase I Environmental Assessments as an acceptable method for demonstrating compliance with the Agency’s “all...

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EPA Issues General Permit For Stormwater Runoff Control Requirements At Construction Job Sites

Introduction Over the next three years, companies commencing new residential and commercial construction projects will become subject to increasingly stringent stormwater runoff management requirements and likely increased enforcement activity by the U.S. Environmental Protection Agency and its...

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The Continuing Obligations Plan: ASTM'S New Standard For Controlling Environmental Risk In Business Transactions

Introduction To property owners and business managers seeking to take advantage of liability protections afforded to purchasers of contaminated property under the federal Comprehensive Environmental Response, Compensation, and Liability Act (“CERCLA”), 42 U.S.C. § 9601 et seq...

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The Narrowing Safe Harbor Of CERCLA Liability Protection For Prospective Purchasers

Introduction In the nine years following enactment of the Brownfields Revitalization and Environmental Restoration Act ("BRERA"), Public Law 107-118, which amended the Comprehensive Environmental Response, Compensation and Liability Act, 42 U.S.C. § 9601 et seq. ("CERCLA" or "Superfund") to...

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The Push For Climate Change Business Impacts Analysis And Disclosure

Companies that have something to lose or gain from climate change, whether from actual physical consequences of global warming and associated weather events or from increased regulation or liability exposure, are facing increased pressure from different quarters to track and report how those...

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