For the last 40 years, the Connecticut Transfer Act has primarily driven the remediation of contaminated property in Connecticut—this will change early next year.

Currently, the Connecticut Transfer Act (Conn. Gen. Stat. § 22a-134 et seq.) requires site-wide investigation, and potential remediation, upon the “transfer” of an “establishment” as defined by the Transfer Act.

On October 22, 2021, EPA published a proposed rule that would, if adopted, provide a significantly enhanced additional pathway for remediation of sites impacted by polychlorinated biphenyls or PCBs. EPA helpfully included a redline version showing proposed changes to the regulatory text. EPA is receiving comments on the proposed rule until December 21, 2021.

PCBs