“Shifting Ground: How New Part 375 Changes the Brownfield Landscape” Published in Environmental Law in New York
SPR Associate Kevin Rogers and Roux Senior Scientist Rachel Henke recently published their article “Shifting Ground: How New Part 375 Changes the Brownfield Landscape” in the LexisNexis newsletter Environmental Law in New York.
On December 31, 2025, the New York State Department of Environmental Conservation (DEC) adopted long-promised amendments to the Environmental Remediation Program regulations in Part 375 of Title 6 of the New York Codes, Rules and Regulations (Part 375). The amendments implement statutory changes enacted in 2015 and 2022 affecting the Brownfield Cleanup Program (BCP), enhance requirements for the Inactive Hazardous Waste Disposal Site Remedial Program (i.e., State Superfund Program) and the Environmental Restoration Program (ERP), update DEC’s soil cleanup objectives (SCOs), and incorporate practical modifications based on DEC’s years of experience administering these programs.
Kevin and Rachel’s article reviews the regulatory history leading to New Part 375, examines several key changes affecting the BCP, and discusses practical considerations for real estate developers operating under the revised framework.
The full article is available here.
If you are interested in learning more about the Part 375 updates, check out this SPRingBoard podcast, adapted from a joint webinar held by SPR and Bousquet Holstein PLLC.
If you have any questions about the Part 375 updates, please contact Kevin Rogers (krogers@sprlaw.com).
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Reprinted from Environmental Law in New York, Vol. 37, No. 5 with permission. Copyright 2026 LexisNexis. All rights reserved.