There are unique and competing interests between the United States Bankruptcy Code1 and federal and state environmental laws. One of the primary purposes of the Bankruptcy Code is to allow a debtor to have a "fresh start." On the other hand, environmental laws are intended to require responsible parties to comply with environmental standards for the protection of human health and the environment. As a result of these competing interests, there has been extensive litigation related to the interplay between the bankruptcy and environmental regimes.