
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.

The Fort Monmouth redevelopment has entered its execution phase, and it is repositioning the broader Monmouth County real estate market. When Netflix and the Fort Monmouth Economic Revitalization Authority closed on the 292-acre Mega Parcel in December 2025, the transaction did more than hand over a deed. It marked the moment Fort Monmouth stopped being […]
Author: Donald M. Pepe

Owning a residential rental property in New Jersey involves more than finding tenants and collecting rent. Property owners must comply with a combination of state laws, municipal ordinances, building and housing codes, and zoning and land use regulations. These requirements can affect everything from the number of dwelling units permitted at a property to whether […]
Author: Donald M. Pepe

The five most common real estate disputes are breach of contract claims, landlord-tenant conflicts, zoning and land use disagreements, construction claims, and boundary disputes. Understanding why each arises, and taking preventive steps early, can help property owners, tenants, developers, and investors avoid costly litigation. Key Takeaways: Real estate transactions are complex endeavors involving numerous parties […]
Author: Paul Grossman

Once a child turns 18, parents lose the automatic legal authority to make medical and financial decisions on their behalf, even if the child still lives at home or remains on the family’s insurance. Three documents close that gap: a durable power of attorney, a health care proxy or directive, and a HIPAA authorization. For […]
Author: George McGowan

Business mediation is a confidential, voluntary process in which a neutral third party helps companies negotiate a resolution to a commercial dispute without going to trial. Because working with a mediator is very different from litigating in the courtroom, it is important to understand how commercial mediation works, when it makes sense for your dispute, […]
Author: Paul Grossman

The five most common causes of construction defect litigation are design defects, substandard materials, workmanship defects, code violations, and subsurface defects. Because these flaws can compromise a building’s integrity, functionality, or safety, they frequently lead to disputes involving multiple parties and high financial stakes. Key takeaways: What is Construction Defect Litigation? Construction litigation is complex, […]
Author: Paul Grossman
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!