Law360, New York (September 25, 2015, 10:51 AM EDT) -- As of Sept. 1, 2015, there are over 570 hazardous waste and substance sites listed in California alone. Each one of those sites is subject to action by the state under the Comprehensive Environmental Response, Compensation, and Liability Act, 42 U.S.C. § 9601 et seq., as well as state environmental laws. State participation in the enforcement of CERCLA is critical to the statute's success. Niagara Mohawk Power Corp. v. Chevron USA Inc., 596 F.3d 112, 126 (2d Cir. 2010). To encourage potentially responsible parties to assist in the payment of costs for the investigation and cleanup of such sites without extensive litigation, Congress has given the U.S. Environmental Protection Agency and state agencies implementing CERCLA the right to enter into a consent decree that provides protection for the settling PRPs from contribution claims by the nonsettling parties. See 42 U.S.C. § 9613(f)(2). These decrees, however, must be approved by the appropriate federal district court. Id....