New Jersey's innovative Environmental Cleanup Responsibility Act (ECRA) has been the subject of much discussion since it became effective on December 31, 1983.¹ The majority of this discussion has focused on who is subject to ECRA and why it takes so long for the New Jersey Department of Environmental Protection to review a case. Harriett Jane Olson's recent Dialogue is an example of what is being said about the above two topics.²

After a review of the historical difficulties that the Department has faced in implementing ECRA, Ms. Olson discusses proposed amendments that could significantly reduce ECRA's coverage.³ Ms. Olson concludes that while the amendments are a step in the right direction, "a more thorough-going revision of ECRA and the Regulations could assist companies in their attempts to comply …."⁴