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Wisconsin

Voluntary Party Liability Exemption (VPLE)

Agency Wisconsin Department of Natural Resources
ASTM search distance 0.5 mile

Wisconsin's voluntary cleanup program is the Voluntary Party Liability Exemption (VPLE), run by the Wisconsin Department of Natural Resources (DNR) under Wis. Stat. § 292.15, which the Legislature enacted in 1994. A voluntary party investigates the whole property and cleans it up as far as practicable under DNR oversight, and in return DNR issues a certificate of completion (COC) that limits the party's future liability for the property's historical contamination. DNR says anyone who applies and pays all the required fees counts as a voluntary party, whether the company that owned and ran the facility or a new buyer.

In a Phase I ESA

VPLE sites are the Wisconsin form of the state voluntary cleanup records that ASTM E1527-21 lists as a standard source. The general reading of a voluntary cleanup listing is on the VCP page. Four Wisconsin details shape how to read one.

  • Entering is not finishing. DNR keeps one list of properties now in the process and another of properties that have received a COC. Check which list a property is on. In BRRTS, VPLE activities carry the prefix 06.
  • The certificate type matters. DNR chooses among five kinds of COC under § 292.15(2): a general certificate, which needs an approved investigation of the whole property, sampling for every likely discharge, and cleanup to the extent practicable, with natural attenuation not chosen as a groundwater remedy; a natural attenuation certificate, where groundwater above an enforcement standard is left to attenuate and the party must buy insurance under the state's master policy; a contaminated sediment certificate; a certificate for a property also affected by a discharge from another property; and a partial cleanup certificate, whose protection may reach only the substances sampled for or only certain areas of the property. Read which kind was issued and, for a partial one, what it covers.
  • The file covers the whole property. DNR says a VPLE property must complete a comprehensive investigation of the entire property before cleanup. Ask whether the file holds that investigation; it can describe more of the property than a single release case would.
  • Some properties cannot enter. Under § 292.15(7), the program is closed to property on, or proposed for, the Superfund National Priorities List; to approved solid waste facilities as § 289.01(3) defines them, which DNR says are typically larger landfills; to certain hazardous waste treatment, storage or disposal facilities, depending on when they operated relative to the voluntary party's purchase; and to hazardous waste disposal facilities licensed for long-term care after closure. DNR adds that a property with a waste site, such as a landfill, must be able to reach closure without relying on an active remedial system.

What the program costs

An application (Form 4400-178) carries a $250 fee. Within 30 days of DNR's eligibility letter the party pays an advance deposit toward DNR's oversight: $2,000 for a property under one acre and $4,000 for one acre or more. Oversight is billed by the hour; DNR gives the rate as $130 an hour for the state's 2027 fiscal year, which runs from July 1, 2026 through June 30, 2027. The insurance for a natural attenuation certificate has its own fees, set for certificates issued from May 16, 2024 to May 15, 2027 and varying with the property's former use and size. Beside the statute, DNR lists chapters NR 750 and NR 754, Wis. Adm. Code, as the program's rules.

Where to look a site up

Getting the file

DNR's VPLE page points to its RR program specialists for paying fees, and to its brownfields staff for the insurance categories; both are on the RR Program staff contacts page. The pages read give no separate route for a VPLE file. For a records request, DNR prefers email to DNRRecordsResponse@wisconsin.gov; see Public Records Request.

Sources

Wisconsin Department of Natural Resources pages, read October 13, 2026, no modified date shown:

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