
Daniel T. McKillop
Partner
201-896-7115 dmckillop@sh-law.comFirm Insights
Author: Daniel T. McKillop
Date: September 23, 2016

Partner
201-896-7115 dmckillop@sh-law.comRuling on an issue of first impression in New Jersey, a New Jersey court has held in Cooper Industries LLC v. Employers Insurance of Wausau A Mutual Co. et al that receiving a General Notice Letter from the Environmental Protection Agency (EPA) pursuant to the Comprehensive Environmental Response Compensation and Liability Act of 1980 (CERCLA) can trigger coverage under a commercial general liability insurance policy.But why does this EPA notice letter matter in the first place?
On March 10, 2010, the EPA issued a General Notice Letter to Cooper Industries LLC, naming Cooper as a “potentially responsible party” (PRP) for pollution remediation of a 17-mile stretch of the Passaic River known as the Lower Passaic River Restoration Project. In the General Notice Letter, the EPA maintained that Cooper was responsible for the cleanup as the successor to the McGraw-Edison Company.
The agency also requested that Cooper become a cooperating party by participating in a Cooperating Parties Group Agreement (CPG Agreement), which is a type of settlement between and among the EPA and other potentially responsible parties. The EPA warned that if Cooper declined to join the cooperating group, the EPA “may apply the CERCLA enforcement process, pursuant to Section 106(a) and 107(a) of CERCLA, 42 U.S.C. §9606(a) and §9607(a) and other laws.”
In May 2011, Cooper notified OneBeacon Insurance Company, whom Cooper contends issued policies to Cooper’s predecessor, McGraw-Edison, of the EPA General Notice Letter and demanded that OneBeacon provide Cooper with a defense to the EPA action. OneBeacon refused to provide a defense to Cooper. As a result, Cooper assumed its own defense and entered into the CPG Agreement.The company subsequently filed a declaratory action against OneBeacon and its other insurance carriers seeking indemnification in connection with the EPA action. Cooper maintains that, as a result of OneBeacon’s failure to provide Cooper with a defense, it has incurred (and is continuing to incur) more than $4.1 million in defense costs. Among other arguments raised, OneBeacon contends that its duty to defend has not been triggered because the EPA’s notice letter to Cooper is not a “suit,” as the term “suit” plainly means some type of court proceeding.
The court held that the General Notice letter did constitute a suit, triggering OneBeacon’s duty to defend Cooper. In reaching his decision, Judge Garry J. Furnari noted that many other jurisdictions have adopted the same position. Judge Furnari also highlighted the fact that the EPA relies on Notice Letters to encourage cooperation, subjecting those who fail to comply to contempt proceedings, fines, and treble damages and barring them from filing a contribution action against settling PRPs. “[G]iven the coercive nature of CERCLA, it would be naive to characterize the EPA letter as a request for voluntary action,” he wrote.“Had Cooper failed to take action, and instead waited for the EPA to file a lawsuit, it would have been subject to strict joint and several liability and other potential damages under CERCLA,” Judge Furnari further explained. “While the reasonableness of Cooper’s settlement with the CPG may very well be at issue later in this case, there is no question that a policy in favor of triggering coverage before a formal complaint is filed serves to enhance the important functions of the Statute. To hold otherwise would discourage prompt and cooperative remediation efforts and the timely cleanup of hazardous waste sites.”
Given Judge Furnari’s decision, insureds who receive a CERCLA General Notice letter from the EPA should immediately notify their carriers and contact their attorneys in order to secure coverage for related costs.
Otherwise, if you have any questions or if you would like to discuss the matter further, please contact me, Dan McKillop, at 201-806-3364.
No Aspect of the advertisement has been approved by the Supreme Court. Results may vary depending on your particular facts and legal circumstances.

New Jersey residential developers with affordable housing obligations should carefully review their existing approvals, development agreements, and proposed deed restrictions in light of the State’s revised UHAC regulations (Uniform Housing Affordability Controls). The regulations, which took effect on November 6, 2025, significantly change the administration and physical requirements for affordable housing units. For developers with […]
Author: Wendy Rubinstein Quiroga

A “no comment” response is sometimes the right call when a legal problem arises. As a blanket policy, however, it lets allegations go unanswered, deadlines pass, evidence disappear, and manageable disputes grow into expensive litigation. The businesses that fare best are usually the ones that say little publicly while acting decisively behind the scenes. When […]
Author: Sean M. Pena

Utility-scale battery energy storage systems (BESS) are becoming an increasingly important component of the electric grid throughout New Jersey, New York, and Pennsylvania. As renewable generation expands, electricity demand increases and grid operators seek greater flexibility, battery storage can help balance supply and demand while providing additional capacity and reliability. For developers, battery storage presents […]
Author: Nicholas Wall

A falling out between partners can be disastrous for any business. In many cases, the partnership will not survive. If you are in an unworkable situation with your partners, it may be time to consult a partnership dispute lawyer experienced in handling partnership breakups and dissolutions before the situation deteriorates any further. It is easy […]
Author: Jay McDaniel

When a company enters Chapter 11 bankruptcy, many assume the process will culminate in a lengthy reorganization plan. However, distressed businesses are increasingly being sold through a different mechanism — a sale under Section 363 of the United States Bankruptcy Code. A Section 363 sale allows a company, as a debtor-in-possession in bankruptcy, to sell […]
Author: John D. Giampolo

Before buying property, it is critical to determine whether local zoning laws may affect your plans. If you plan to redevelop the property, you will want to confirm that local zoning regulations permit development as intended. If acquiring property that is already developed, you must verify that the use is permitted in the underlying zoning […]
Author: Wendy Rubinstein Quiroga
No Aspect of the advertisement has been approved by the Supreme Court. Results may vary depending on your particular facts and legal circumstances.
Consider subscribing to our Firm Insights mailing list by clicking the button below so you can keep up to date with the firm`s latest articles covering various legal topics.
Stay informed and inspired with the latest updates, insights, and events from Scarinci Hollenbeck. Our resource library provides valuable content across a range of categories to keep you connected and ahead of the curve.
Let`s get in touch!
Sign up to get the latest from the Scarinci Hollenbeck, LLC attorneys!