Since 1994, environmental‐insurance coverage cases in New Jersey have been framed by the New Jersey Supreme Court's landmark decision inOwens‐Illinois.That case, however, failed to clarify with appropriate precision a number of basic insurance issues. In 1998, the court revisited its earlier decision. InCarter‐Wallace,the court explicitly addressed allocation between layers of coverage, rejecting, in the process, the two alternative allocation methodologies proposed by the plaintiff and defendant. As part of the court's analysis, it adopted an allocation methodology that endorses the stacking of triggered policy limits to respond to progressive indivisible damage. The stacking issue is a critical allocation question. Advocates of no‐stacking believe the issue is so central to the allocation question itself that it should dictate the allocation methodology. Even afterCarter‐Wallace,no‐stacking advocates continue to press their case. Professor Neil Doherty, a no‐stacking advocate, recently articulated his views as a special master in thePrinceton Gamma Techcase. Professor Doherty—a professor of insurance at the University of Pennsylvania, and not a lawyer—attempted to convince the trial court that the stacking question had not been answered by the New Jersey Supreme Court in eitherOwens‐IllinoisorCarter‐Wallace.He ignored the court's pronouncement inCarter‐Wallacethat the model adopted therein should be the presumptive model except when extraordinary circumstances are present. Instead, Professor Doherty opined that the open question on stacking dictated a new and novel allocation methodology—one different from that provided by theCarter‐Wallacecourt. Indeed, the very model advanced by Professor Doherty in thePrinceton Gamma Techcase had been unequivocally rejected by the court inCarter‐Wallace.In our view, the stacking question is not open for academic debate; it has already been answered two times by the New Jersey Supreme Court. It is clear that the New Jersey Supreme Court has developed an allocation methodology that explicitly adopts the stacking of policy limits.