Estimating and Disclosing Environmental Liabilities

© 2014 Environmental Risk Communications, Inc.
Contact:
John Rosengard
(415) 336-5085
www.erci.com
Estimating and Disclosing Environmental
Liabilities
February 2015
Call: (914) 339-0033
Code: 443-350-915

Today’s Webinar Outline
Speaker Background
GAAP Framework
- ASC 410, GASB 49
Fair Value Measurement
Non-Performance Risk of Counterparty Default
Best Practices
Q&A

Speaker Background: John Rosengard
21 years at ERCI; founder/creator of Defender
software suite
 14 US corporate remediation teams [>60 audits]
 3000 unique liabilities
 200 decision analysis projects
 4 US port authority remediation teams [>10 audits]
 Counterparty credit tracking system
MBA, Northwestern; BS, Georgetown
…not an attorney or an engineer or a CPA

Elevator Speech
 Environmental liabilities are significant and growing
 Legacy and ongoing releases to soil, GW, sediments
 More GAAP standards than ever
 More environmental regulations than ever
 More raw data than ever
 Counterparties defaulting regularly
 Reliably stating environmental liabilities is a challenge
 Fair value is the trend
 Legacy behaviors brought deferral, not extinguishment
We decided long ago that the dangers of excessive and unwarranted concealment of pertinent facts
far outweighed the dangers which are cited to justify it. – John F. Kennedy, April 27, 1961

Legacy Behaviors: Liabilities not at Fair Value
Date Event
12-31-2008 GM environmental reserve: $297 million
6-01-2009 GM files Chapter 11
6-30-2009 GM updates their reserve to $536 million
10-20-2010 $773 million for first six settlements
12-14-2010 +$25.0 million settlement = $798.0 million
11 settlements = 3.2x reserve, three years
Source: USEPA press releases

$0.0
$0.1
$0.2
$0.3
$0.4
$0.5
$0.6
$0.7
$0.8
$0.9
$1.0 1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
Legacy Behaviors: Deferral v. Extinguishment
Source: Honeywell 10-K Reports
Spending = $3.3 billion over 18 years

FASB Conceptual Framework
Source: FASB Statement of Financial Accounting Concepts No. 8, September 2010
Enhancing
Qualitative
Characteristics
Fundamental Qualitative
Characteristics
Objective of
Financial
Reporting
Information
Useful to
Decisions
Relevant
Predictive value
Confirmatory
value
Faithful
Representation
Complete
Neutral
Free from error
Elements of
Financial
Statements
Comparability
Verifiability
Timeliness
Understandability
Recognition
Measurement
Presentation
Disclosure
Cost Constraint
Materiality Constraint

High Level View of Environmental Liabilities
Obligations
ASC 410
Commitments
ASC 440
Contingencies
ASC 450
Guarantees
ASC 460
Liabilities
Consent order to study
and remediate a site
Promise to study and/or
buy back a site if
contamination is found
Settlement to share
past costs at a closed
landfill
Financial assurance
instrument (LOC) to
regulator for
performance of RCRA
monitoring
Asset retirement
obligations

Key GAAP Sources
 FASB: ASC 410, 440, 450, 460, 820
 GASB: GASB Statements 18 & 49; draft on Fair Value
 IASB: IAS 37, IFRS 13
 SEC Regulation S-K (17 CFR 210 to 230)
 Sarbanes-Oxley Act (2002)
 Dodd-Frank Act (2010): Title IX, Subtitle I
 PCAOB AU 336 (2011+)
 PCAOB Audit Standards 5, 12, 15 (2011+)
 ASTM E2137-06 Standard Guide for Estimating Monetary Costs and
Liabilities for Environmental Matters (2002, updated 2011)
 ASTM E2173-07 Standard Guide for Disclosure of Environmental
Liabilities (2002, updated 2011)
There is no substitute for reading these yourself
9

High Level View of GAAP
Domain FASB GASB IASB
For… US Corporations Government
Agencies
Non-US
Corporations
Environmental
Obligations
ASC 410
Oct1996
GASB 49
Nov2006
GASB 18
Aug 1993
IAS 37
Sep1998
IFRIC 1
Fair Value ASC 820 -
Sep2006
GASB 72
Feb 2015
IFRS 13 –
May2011
Commitments ASC 440 Note disclosure IAS 16
Contingencies ASC 450 GASB 10 IAS 37
Guarantees ASC 460 GASB 70 IAS 39
Nonperformance
risk of
counterparty
default
ASC 820-10-
35-17 and
ASC 410-30-
30-7
GASB 72
¶ 62
IFRS 13:42

ASC 410 Environmental Obligations & AROs
July 2009 Codification of GAAP
AICPA SOP 96-1 Environmental Remediation Liabilities
FAS 143, FIN 47 Asset Retirement Obligations
…and others
Obligations are distinct from commitments, contingencies
and guarantees
Recognition benchmarks (3 for ARO, 6 for EO)
Preference for “expected value” basis
 Weighting different outcomes (such as technology)
 Factoring in remedy failure
 Adding in corporate overhead, working capital
 Including nonperformance risk of counterparty default
 …and a risk transfer premium

GASB 49 Pollution Remediation Obligations
Issued November 2006
Obligations are distinct from contingencies and
guarantees
Recognize based on five “recognition benchmarks”
Update valuation based on five “obligating events”
Current value: no inflation, no discounting
Preference for “expected value” basis
 Weighting different outcomes (such as technology)
 Factoring in remedy failure
 Adding in overhead, working capital
 Including nonperformance risk of counterparty default
 …but normally no risk transfer premium

ASC 820 Fair Value Measurement
FASB 157 issued September 2006, ASC 820 in July 2009
Fair Value = “current market price” between similar
owners, in an “orderly market”
Level 1 (preferred): quoted price, active market, identical
liabilities
Landfill space for Class C waste is $84.50/ton
Level 2: some observable inputs, less-active market,
similar liabilities
Operating a 20-gallon/minute groundwater extraction system has an annual utility cost
of $8K to $10K
Level 3: unobservable inputs, little (if any) market,
unique liabilities
Regulatory approval of the remediation plan may take four years; during that delay, the
groundwater plume may expand 0%-25%, depending on rainfall

Fair Value Fluctuation
six
months
Fair value of
environmental
restoration cost
Fair value of
operating asset
Fair value of
environmental
restoration cost
Fair value of
operating asset
@ $100/barrel
@ $50/barrel
Takeaway: an asset that is operating
profitably in 2013 can justify a small
(present value) cost for restoration:
-Indefinite “date of settlement”
-Unknown future cleanup levels
-Unknown future source (soil, GW)
Decommission or sell off an
unprofitable asset in 2015, the
environmental costs are:
-Settled now
-Based on current cleanup regulations
-Based on today’s source knowledge
$5MM ($.5MM) $2MM ($3MM)

Fair Value Reserve Calculation Example
$0.0
$0.5
$1.0
$1.5
$2.0
$2.5
$3.0
$3.5
$4.0
Vendor
Quote
Remedy
Failure
Project
Management
Counterparty
Default
Fair Value
Vendor Quote
Groundwater P&T System
$2M install, $3 M O&M
Less 50% in cost sharing
= $2.5M
Remedy Failure
80% status quo OK
20% expand remedy (+$4M, less 50%)
= [(80% x 0) +(20% x $2M)]
= $0.4M
Project Mgmt
10% add-on
= $0.3M
Counterparty
60% no defaults
25% one PRP default, +$1M
15% two PRP defaults, +$2M
= [(60% x 0) + (25% x $1M) + (15% x $2M)]
= $0.6M
$2.5
$3.8
+$0.4
+$0.3
+$0.6

No two EO/ARO/PRO liabilities are alike
$0.0
$0.5
$1.0
$1.5
$2.0
$2.5
$3.0
$3.5
$4.0
$0.0
$1.0
$2.0
$3.0
$4.0
1 2 3 4 5
$0.0
$1.0
$2.0
$3.0
$4.0
1 2 3 4 5
Implementation Risk Counterparty Risk Reopener Risk
Conditions: typical
cleanup on owned site
Conditions: counterparty
default triggers liability
reversion to us
Conditions: remedy goals
redefined by regulator,
while counterparty fails
VendorQuote
RemedyFailure
ProjMgmt
Counterparty
FairValue
VendorQuote
RemedyFailure
ProjMgmt
Counterparty
FairValue
VendorQuote
RemedyFailure
ProjMgmt
Counterparty
FairValue

Non-Performance Risk of Counterparty Default
 ASC 410-30-30-1(b)
 Assess the likelihood that other potential responsible parties will pay their
full allocable share of the joint and several remediation liability.
 ASC 410-30-30-7
 An entity should assess the likelihood that each potentially responsible
party will pay its allocable share of the joint and several remediation
liability. That assessment should be based primarily on the financial
condition of the participating potentially responsible party. This assessment
requires the entity to gain an understanding of the financial condition of the
other participating potentially responsible parties and to update and
monitor this information as the remediation progresses. The entity shall
include in its liability its share of amounts related to the site that will not be
paid by other potentially responsible parties or the government.
Key Takeaways: this is not new
applies beyond CERCLA; ASC 410-30-30-7 is the exact same language
as SOP 96-1, ¶ 6.20 (1996)
17

 FASB: ASC 820-10-35-17
 The fair value of a liability reflects the effect of nonperformance risk.
Nonperformance risk includes, but may not be limited to, a reporting
entity’s own credit risk. (continues)
 FASB: ASC 820-10-35-18
 When measuring the fair value of a liability, a reporting entity shall take
into account the effect of its credit risk (credit standing) and any other
factors that might influence the likelihood that the obligation will or will not
be fulfilled. (continues)
 GASB: GASB 72 ¶62
 The fair value of a liability reflects the effect of nonperformance risk.
Nonperformance risk includes, but may not be limited to, a government’s
own credit risk. Nonperformance risk is assumed to be the same before and
after the transfer of the liability. When measuring the fair value of a
liability, a government should take into account the effect of its credit risk
(credit standing) and any other factors that might influence the likelihood
that the obligation will or will not be fulfilled. (continues)
GAAP on Non-Performance Risk
5

Who Are Counterparties?
 Any party who retained some or all of an environmental liability (EO,
ARO, PRO) related to one of your assets
 Successor property owners or tenants
 Predecessor property owners or tenants
 Joint venture partners; working interests
 PRPs on a multiparty site cleanup; their insurers
 State or Federal agencies funding “orphan share” allocations
 Landfills accepting new waste from your current projects
 Landfills which accepted wastes from your projects in the past
 Any multiparty sites where you are the PRP group “banker” and
contracting agent
 Contractors on fixed-price contracts
 Sureties providing financial assurance bonds
 Banks issuing financial assurance letters of credit
 Insurers backing your remediation contractors with cost cap
insurance, workmen’s comp, commercial/general and automotive
liability coverage

How to Measure Nonperformance Risk
Dun & Bradstreet and Standard & Poors each provide several scores to
convey short-term and long-term “ability to pay”. Not all large
companies are scored alike (June 2014 scores):
0 10 20 30 40 50 60 70 80 90 100
1FSS Class 2FSS Class 3FSS Class 45

Nonperformance Risk Calculation
 Five PRPs, all have 20% share
 $10 million in future costs over ten years
 Random mix of credit ratings, ours is FSS Class 1 (best)
 Recalculation of reserve:
+$2,000,000 cash calls
+$1,744,273 EV of default by the other four parties (range $0 - $8M)
- $ 152,993 EV of our own default (range $0 - $2M)
=$3,591,280 [80% higher than original $2M]
$1,744,273 ($152,993)
21

What Mitigation Steps Can You Take?
Identify Your Counterparties
Know when insurance, purchase/sale terms & conditions expire
Revisit full list every three years, add new transactions
Don’t assume everyone knows
Track the Counterparties
Perform a credit check every 90 days, supplement with a review of
stock prices, GoogleAlerts, your company’s credit limit with this
counterparty, anything and everything
80% of business exits are non-bankruptcy “dissolution”
Know which entity is your counterparty; don’t assume your Fortune 500
counterparty has retained liabilities in-house and/or perpetually
Act on What You Learn
Document successors/assigns changes
Negotiate cash-out or cash-in to unwind the relationship
Reward and recognize liability prevention internally

Takeaways on Nonperformance Risk
 The rich get richer…while the poor get poorer
 PRPs in top quartile of creditworthiness tend to remain there
 PRPs in other credit classes tend to last 10 years or less
 Time is money
 Delays create nonperformance risk (“musical chairs”)
 Delays come from negotiation of allocation, lack of regulatory
enforcement, rescoping of remedial investigations
 Consequence is material: 50% of a typical PRP group is gone in
7.5 years
 Risk is concentrated in smaller PRP groups (2-5 parties)
 Any group can lose a any PRP any year
 You can’t have it both ways
 If your reserve is zero because of a counterparty, your reserve
value of $0 depends on them not defaulting
23

Coming Soon to Environmental Liabilities?
Language from recent FASB and IASB drafts on
credit losses
Estimates of lifetime losses must consider:
 all relevant, reasonable, and supportable
information,
 a range of possible outcomes, and
 the time value of money.
Source: FASB Proposed Accounting Standards Update: Financial
Instruments (Topic 825-15) – Credit Losses, released for comment
May 2013

Reminders: Questions Auditors Can Ask
 About the forecasts…
 Independent of stakeholders (P&L unit, vendors)?
 Peer reviewed?
 Bracketed w/consistent confidence intervals (p10 to p90)?
 About the weighting of scenarios…
 Pro/con documented; based on similar liabilities?
 Confidence of success and backup plan
 Do users understand the procedures and tools?
 About the sites…
 Are any estimates more than 12 months old?
 Would a buyer’s due diligence would show unreserved
investigation or remediation costs >$1 million?
 Does “lack of enforcement” alone bring reserve to $0?

PCAOB Audit Standard 15: Audit Evidence
 15.4 to 15.6 – is there sufficient audit evidence
 15.8 – is audit evidence reliable
 15.10 – is company’s data sufficient and
appropriate
 15.11 to 15.12 – five categories of assertions;
are there misstatements:
 Existence or occurrence
 Completeness
 Valuation or allocation
 Rights and obligations
 Presentation and disclosure
Effective for fiscal years after 12/15/2010

PCAOB AU 336: Using the Work of a Specialist
 336.08 – auditor should evaluate specialist’s
qualifications
 336.11 – auditor should determine if the
specialist’s objectivity is impaired, act
accordingly
 336.13 – auditor should determine if the
financial statements and specialists’ statements
line up, act accordingly
Originally stated in SAS 73, effective 12/15/1994
AU 336 applicable after 12/15/2010

Reminders on Enforcement/Compliance
 Overstating assets or understating liabilities
is a crime
 Negligence, malfeasance
 Securities fraud
 Sarbanes-Oxley (2002)
 SEC prosecuted Waste Management (2002)
 Complaint 02C 2180 alleged $1.7B in inflated earnings
1992-97
 The company “established inflated environmental reserves
(liabilities) in connection with acquisitions so that the
excess reserves could be used to avoid recording
unrelated environmental and other expenses.”

Reminders on Enforcement/Compliance
 SEC prosecuted Ashland Chemical (2006)
 Three employees filled out “code of conduct” questionnaire
 Admin Proceeding 3-12487 found $26M+ in improper
environmental reserve reductions in 1999-2001
 SEC decided company and the remediation manager
personally violated Securities Exchange Act of 1934
 Section 13(a) Reporting Violations
 Section 12(b)(2)(A) Recordkeeping and Internal Control
Violations
 IRS prosecutes based on false statements
 If your organization issues financial
statements to investors, bondholders and/or
the IRS, you must comply with GAAP

Best Practices
A. Recognition
Recognition Benchmarks
B. Measurement
Fair Value Measurement
Nonperformance Risk of Counterparty Default
C. Presentation
Reserve Display
Watch List
D. Disclosure
Elements of
Financial
Statements
Recognition
Measurement
Presentation
Disclosure

Recognition Benchmark Review
ASC 410-30-25-15
Identification and verification of an entity as a potentially responsible party.
Receipt of unilateral administrative order.
Participation, as a potentially responsible party, in the RI/FS.
Completion of feasibility study.
Issuance of record of decision
Remedial design through O&M, including postremediation monitoring.
FASB
(sixitems)
GASB
(fiveitems)

Fair Value Term Sheet (Reserve = A through F)
Variable Level 1/2/3 inputs: site-specific
conditions, KPIs, unit costs
FVM
Level
Income Impact
A. Lifecycle cost projection 12 years pump & treat, 10 gpm from 5
wells, three pore volumes of 19 acres
2 -$5.5 million
B. Contingencies for changes to
scope, schedule and vendor
25% cost increase for fourth pore volume,
doubling well count (to 10) in years 8-12
2 -$1.2 million
C. Premium for full/partial
strategy failure
Additional ten years pump & treat for fifth
and sixth pore volume
3 -$3.8 million
D. Premium for project
management
12 years oversight, legal, contracting, cost
recovery work
2 -$2.8 million
E. Premium/discount for
counterparty risk
Successor owner has diesel generator
onsite; credit rating 620
1 -$1.5 million
F. Premium/discount for your
company’s own ability to pay
Fortune 200, credit rating 1085 1 +$0.5 million
G. Income for brownfield Ground lease $500K/yr to 2025 2 +$5.0 million
H. Recovery of current & future
spending
•Asserted claims
•Unasserted claims
50% recoverable under Federal contract
20% recoverable from legacy owner
2
+$7.4 million
+$3.0 million
I. Income for sunk cost recovery
•Asserted claims
•Unasserted claims
50% recoverable under Federal contract
20% recoverable from legacy owner
1
+$0.5 million
+$3.0 million
J. Value of deferred tax assets 30% of items A through F 1 +$4.3 million
Fair Value Components Total Outflows
Inflows
Net
-$14.8 million
+$23.7 million
+$8.9 million

Best Practices in Lifecycle Cost Measurement
Point estimates
Expected values
from modeling
sheet
User selects
subtasks from
drop-down menus
Common WBS
Takeaway: WBS separates costs for study, remediation, O&M, overhead and
legal costs; recovery rates (%) apply to one or more PRPs and insurers
33

Best Practices in Measurement, Display
 Common work breakdown structure for all sites in the portfolio
 Study, design, implementation, OM&M, legal, project mgmt
 For costs >$100K, pinpoint Level 1 and 2 inputs
 “Four years OM&M after excavation concludes”
 “Groundwater P&T system based on two pore volumes; five-
year term, single flood event to reach 50gpm design
requirement”
 “25,000 cubic yards of soil, bulking factor of 1.25 due to high
sand ratio, 83 miles to approved disposal facility”
 Justification for revising the scenario weighting
 “Completed decision analysis exercise in June 2016”
 “Reweighted the three scenarios after the community advisory
board meeting in August and email exchange with regulator in
September 2016”
 “Operating plant asked that closure construction be
synchronized with turnaround project X, now scheduled for Q4-
2017”

Capitalizing Liability Spending
 If spending has no current operations or
assets, skip this analysis
 Capitalize where spending:
 Increases the asset base
 Extends the useful life of an asset
 Decreases the OPEX of an asset
 Test: is there a “return” on the incremental
spending on the company-owned asset?
 Preparing an asset for sale requires
professional judgment

Why Capitalize Environmental Spending?
 Investment tax credit eligibility
 Loan/grants eligibility
 Offset to regulated/mandated spending
 Complies with GAAP
 Matching principle
 Matches spending to benefits of the
mitigation work

Best Practices: Reserve Display
Environmental Reserve 2014 2013 2012
Opening Reserve Balance [Liability] 700 800 800
+ Reserve Increases [New Sites] 0 50 100
+/- Updated Estimates [Existing Sites] 0 50 100
- Spending (200) (200) (200)
= End of Year Reserve 500 700 800
Loss Contingencies [see next page] 1250 1400 1500
Opening Recoveries Balance [Contra Liability] 200 200 200
+ Recoveries Recognized 100 100 100
- Recoveries Received (100) (100) (100)
= End of Year Recoveries 200 200 200
Recoveries Contingencies 100 200 300
Clear Trend
Correlation is
clear
Correlation is
clear
Good downward trend
Good downward
trend
 ASC 820-10-50-2 makes disclosure of this data mandatory.
37

Best Practices: Watch List Display
 Reserves are the visible
portion of
environmental
liabilities
 The “watch list” is the
portion below the
waterline
 The waterline is set
through consultation
with auditors, board
members and senior
management
 Reserve + watch list =
full liability
38

Site Recognition Trigger Prob Low
Value
Expected
Value
High
Value
Timing
Site 1 CAMU size and installation year 100% 28 40 60 3/31/2014
Site 2 Remedy selection: SVE for 10 years 100% 7 10 15 2014-2015
Site 3 √ Insurer denies coverage 50% 49 70 105 1/1/2015
Site 3 30% design of soil removal 20,000 MT (lead) 50% 35 50 75 2016-2018
Site 4 Scope of investigation 100% 3.5 5 7.5 1/1/2014
Site 5 NRDA claim/damages 80% 7 10 15 2015-2018
Site 5 √ 25% PRP defaults 33% 21 30 45 7/1/2016
Site 5 Remedy selection for 195,000 MT (solvents) 100% 28 40 60 7/1/2016
Site 6 Spill excavation, pipeline areas A-1 to C-10 100% 14 20 30 2015-2016
… Others… … 975 … …
Sum of Loss Contingencies 1250
Best Practices: Watch List v1
Takeaways
 It displays “reasonably possible” reserve changes
 Site-specific
 Clear “recognition benchmark” or “obligating event” for tracking
 Range of costs, range of timing
 This table is described in ASC 410-30-50-9 as “disclosures that are
encouraged but not required”
39

Best Practices: Watch List Display
Watch List v2
Recognition Trigger Amount prob% Date
Change order for excavation $ 100,000 99% 10/1/2014
Remedy fails, new remedy $ 4,000,000 50% 10/1/2015
Counterparty defaults on new
remedy
$ 4,000,000 20% 10/1/2015
GW P&T add'l 5 years $ 1,000,000 80% 7/1/2015
GW P&T add'l 5 years $ 1,250,000 75% 7/1/2020
GW P&T add'l 5 years $ 1,500,000 70% 7/1/2025
20% counterparty fails by 2020 $ 1,000,000 20% 7/1/2020
OU-2 final remedy $ 5,000,000 90% 12/31/2016
OU-2 remedy @5 ppb PCBs $ 15,000,000 50% 12/31/2016
35% counterparty fails $ 5,000,000 40% 1/1/2016
Deminimis not pursued $ 1,000,000 80% 4/30/2015
Remedy fails, new remedy $ 2,000,000 33% 10/1/2015
Insurer denies coverage $ 6,000,000 15% 10/1/2015
JV partner fails, four sites revert,
RCRA closures
$ 12,500,000 35% 10/1/2020
Insurer for JV denies coverage $ 12,500,000 50% 12/1/2020
Landfill operator CH11, 11 NPL sites $ 20,000,000 35% 9/1/2018
Counterparty pool shrinks $ 10,000,000 60% 9/1/2018
Low-profile strategy fails $ 2,500,000 33% 9/1/2017
Non-performance on 10 AROs for
asbestos, enforcement action
$ 10,000,000 60% 1/1/2020
 Apply ASC 820 – Fair Value
Measurement: “would your
biggest competitor agree?”
 Go beyond time constraints
of reserve horizon
 Factor in counterparty risk
of default ( )
 Show everything a peer
would include as a
premium
 Success metric: every
future reserve increase will
come from this list

Summing Up
GAAP
 GAAP is comprehensive, evolving
 Your reserve policy, tools and training might not apply “fair value” or
“counterparty risk” yet
Recognition and Measurement
 Use Fair Value Measurement
 Avoid “probable” & ”reasonably estimable”: works against “relevant”
and “faithful representation”
 Know your counterparties; treat nonperformance risk like any other
environmental risk
Presentation and Disclosure
 Rethink reserve policies and procedures, tools, training
 Develop and display a Watch List
Remember GM, Honeywell case studies
 is your reserve at fair value today?

Next Steps
 Website: www.erci.com
 LinkedIn Group, Facebook page, YouTube page
 Email john@erci.com
 Link to on-demand webinars @ YouTube (audio + video)
 PDF of this presentation (original PPTX format on request)
 Where to find ASC 410, GASB49, ASTM, IAS37
 February 2015 webinars on
 Fair Value Measurement
 Estimating and Disclosing Environmental Liabilities
 Auditors Tough Questions on Environmental Liabilities
 March 2015 webinars on
 Managing Nonperformance Risk of Environmental Counterparties
 Obstacles to Recognizing and Measuring Environmental Liabilities
42

Estimating and Disclosing Environmental Liabilities

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