Questions & Answers  

About Brownfields

 Information supplied by Marsh, Inc.

 The United State ’s Environmental Protection Agency (EPA) defines Brownfields as abandoned, idled, or underutilized industrial and commercial facilities where expansion or redevelopment is complicated by real or perceived contamination.  It is estimated that there are 450,000 of these properties across the United States .

 In order to facilitate the cleanup and reuse of Brownfield properties, the EPA first launched the Brownfields Economic Redevelopment Initiative in 1994 and later the Brownfields National Partnership Action Agenda in 1997.  These initiatives represent the combined efforts of various federal agencies and non-governmental organizations to expedite the redevelopment of Brownfield properties.

Q:        Why are Brownfield properties important?

A:         In the United States , real property is a valuable asset.  While most real estate is put to productive use, many Brownfields remain unused or under-utilized because of real or perceived contamination and its associated liabilities.  The main purpose of the Brownfields Action Agenda is to clean up and reuse Brownfields to produce environmental, public health, and economic gains.

Q:        What are the environmental concerns associated with Brownfields?

A:         There are generally two major concerns associated with a Brownfield property.  First, under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA – or “Superfund”), the current owner of a contaminated property may be held liable and responsible for the cost to clean up the location.  This also becomes a concern for a potential buyer because his/her usual strategy is to purchase a Brownfield inexpensively, clean up the property, redevelop the location, and ultimately sell the property for a profit.  For this reason the cost of the cleanup is a crucial variable in the investment decision and has a major impact on the projected profitability of the real estate venture.  In addition, when the redeveloper becomes the seller of the property he/she often must provide the prospective buyer with assurance that the property is no longer contaminated.  Often these issues can become critical during the real estate transaction.

The second concern is the third party’s environmental liability resulting from ownership of a property or the operation of a facility. These potential exposures can also become issues in the real estate transaction and often require assurances by the seller that no third party claims exist.  

Q:        Does the environmental insurance market have solutions available that may help facilitate Brownfield Redevelopment?

A:         Yes.  The environmental insurance industry has several types of insurance products that can assist with the redevelopment of contaminated property; policies that respond to all phases from the original testing and planning through final construction.  However, the two most often used solutions are generally known as “Cleanup Cost Cap (CCC)” and “Pollution Legal Liability (PLL)” policies.  A CCC policy acts as a financial tool that allows a company to limit the costs related to the cleanup of “known issues” on a contaminated property.  A PLL policy is intended to protect the owner/developer from “unknown” liability issues that may arise during the cleanup and construction phases of a project.

Q:        Why would environmental cleanups exceed original cost estimates?

A:         Environmental cleanups have a history of exceeding projected cost estimates.  Cost overruns can occur due to several reasons, which include, but are not limited to, the unforeseen performance failure of the selected technology, the identification of additional contamination, the increase of cleanup requirements by regulators, and the underestimation of time for project completion. 

Q:        How does the CCC Program work?

A:         A typical cleanup requires a Remedial Action Plan (RAP) that details the delineation of the contamination (as provided in a Phase II Report) being remediated, the methods to be used to complete the cleanup, and the cost estimates for the project.  The remediation contractor that oversees the project provides a RAP.  The actual cost detailed in the RAP is a known liability, and therefore must be retained by the insured.  The risk transfer layer provided by the CCC policy responds to cost overruns in excess of the known liability and a negotiated buffer layer.  This buffer layer is often 10% of the total cleanup cost.  In addition, a finite risk mechanism can be incorporated into the program to fund for known third party liabilities.  

Q:        What are the benefits of a CCC?

A:         A CCC can eliminate future unexpected expenses associated with cost overruns from cleanups of contaminated properties.  This benefits real estate investors and developers by allowing them to develop firm cost estimates for cleanups.  This, in turn, helps them to more accurately evaluate their total investment costs and ultimately their expected profitability.

Q:        Can a CCC cover multiple locations?

A:         Aggregate coverage can be crafted for a single site or multiple sites under one policy form.

Q:        What limits of liability are available in the environmental insurance marketplace?

A:         Marsh has structured CCC programs with $800,000,000 in limits for a single site, and over $800,000,000 in limits for multiple site cleanups.

Q:        What is the maximum policy term available in the marketplace?

A:         The maximum policy term (duration) available in the marketplace is 30 years. However, these policies are generally purchased with 5- to 10-year terms.

Q:        How much do these programs generally cost?

A:         The typical cost of a CCC is between 5 – 8% of the estimated cleanup cost for a limit of insurance equal to the estimated cleanup cost. The program usually includes a 5 - 10% buffer (deductible).

Q:        What types of coverages are available in a PLL?

A:         The primary intent of a PLL is to respond to claims for third party bodily injury & property damage resulting from pollution conditions, or first party environmental cleanup costs and legal defense expenses that result from pollution conditions that are “unknown” and “unexpected” at the beginning of a project. A PLL policy can also incorporate coverages for the transportation and disposal of waste, first party business interruption, and diminution of value.   

Q:        What are the benefits of a PLL?

A:         During a remediation project, a PLL policy can protect against “unknown” issues that become “known” after the project has started. After a remediation project is complete, a PLL can protect a property owner from future environmental liabilities resulting from historic or on-going operations.  For this reason, a PLL can often help facilitate the closing of a real estate transaction because the policy offers assurance to the potential buyer from the seller that environmental liabilities have been addressed. 

Q:        Can a PLL cover multiple locations?

A:         Aggregate coverage can be crafted for a single site or multiple sites under one policy form.

Q:        What limits are available in the environmental insurance marketplace?

A:         Marsh has structured PLL programs with limits as high as $800,000,000 per occurrence or $800,000,000 aggregate.

Q:        How much do these programs generally cost?

A:         The cost for a PLL program varies based upon the number of locations, the nature of the potential exposures, the limits, and deductibles.  However, premiums have decreased over the past several years.

Q:        Can a CCC and a PLL program be combined?

A:         Yes, it is quite common to combine the CCC and PLL programs into one manuscripted coverage form to provide coverage for the “known” and “unknown” issues associated with a site or multiple sites.

Q:        Who are the major insurance carriers?

 A:         AIG Environmental, Kemper Environmental, Zurich American, and Environmental Compliance Services, Inc (ECS).

 Brownfield issues can be complicated because state and local government programs vary.  Issues, such as tax incentives, development assistance grants, liability protection, and zoning concessions, will be very important to the developer or the investor.  It is important to understand the environmental issues that may affect the results of Brownfield Redevelopment. It is also important to understand the environmental solutions that can help protect investments.

 Please contact your local Marsh representative to discuss these issues in greater detail.