C

  In our interpretation of the requirement that a release 'cause[] the incurrence of response costs,' we are notably entering unexplored territory. As with many of CERCLA's provisions, the legislative history is bereft of discussion about the causal nexus between releases and response costs. Additionally, courts have not been faced with a scenario suggesting that a plaintiff's action was not justified by the hazard posed. Several courts have interpreted the causation requirement in a different context -- for determining the standard of proof necessary to show a defendant is responsible for the hazard that resulted in response costs. For that purpose, ...