ENVIRONMENTAL LIABILITY RESERVE ESTIMATION
Metropolitan
provides an independent review and assessment of current environmental
liability reserves. In validating this
information, Metropolitan conducts interviews with project managers,
environmental division management, and other key site / portfolio stakeholders.
Reserve
Analysis
Objective:
Since 1975, generally accepted accounting principles have obligated US
corporations to identify, quantify, and disclose environmental remediation
liabilities. Since then, environmental laws and GAAP have grown both in number
and complexity. What has happened to environmental reserves since then?
METROPOLITAN researched the environmental reserves of five large companies to
see if a trend exists, to learn if reserve adjustments are becoming routine,
and to discover how long cleanup reserves will remain on balance sheets.
No one questions the rigor, materiality, and perpetuity of employee pensions,
another type of contingent liability. But are environmental reserves here to
stay? METROPOLITAN compiled the following results.
Process:
METROPOLITAN examined SEC filings over the past eighteen years and assembled
the environmental and exploration and production (E&P) reserves for the
five largest energy companies, along with their acquisitions. We did not adjust
for inflation or discount rates, or bring the numbers to 2009 dollars. We
simply collected the reserves as stated in the 10-K and 20-F reports,
correcting for any subsequent adjustments. Wherever possible, we excluded costs
which were capitalized (as part of an investment) or expensed (as part of an operating
facility).
We chose the five largest energy companies by market capitalization
(ExxonMobil, Chevron, BP, Shell, and ConocoPhillips) because they are all in
the same industry and have grown through acquisitions in the past twenty years.
They also have comparable waste streams, historic waste disposal practices,
capital stewardship efficiency, financial sophistication, consumer brand
awareness, and large geographic footprints.
Analysis: End of
Year Environmental Reserve Balances
Environmental reserve balances from 2008 are generally higher than they were in
1998. We believe this trend is based on a combination of factors:
·
increased
awareness of environmental liabilities
·
new
environmental regulations
·
more
aggressive enforcement of environmental regulations
·
increased
sophistication among external and internal auditors
·
increased
sophistication of environmental consulting professionals
·
asset
divestitures
·
bankruptcy
of smaller potentially responsible parties / acquirers of divested assets
·
improved
compliance with accounting procedures
·
accounting
standardization following mergers
To the extent the
data is available, METROPOLITAN assembled the environmental reserve balances
reported for each company, along with any legacy company reports. For example,
BP acquired Amoco (1998) and ARCO (2000); the three entities' historic data is
combined as if they were one company.
ExxonMobil has periodically found that their environmental liabilities are not
material, so reporting is sporadic.
Analysis: Exploration
& Production Restoration Balances
E&P Restoration is the obligation or liability for dismantlement,
abandonment, and restoration costs of oil and gas producing properties. All of
the Big Five oil companies have seen a significant increase in E&P
Restoration balances since 2000. This is attributed to the issuance of
Statement of Financial Accounting Standards No. 143, Accounting for Asset
Retirement Obligations in 2001 and Financial Accounting Standards Board (FASB)
Interpretation No. 47, Accounting for Conditional Asset Retirement Obligations
in 2005. Before 2001, the guidance was simpler and narrower in SFAS 19; for
example, dismantlement costs were often recognized as a contra-asset, instead
of a liability.
Analysis: End of
Year Environmental Reserve to Environmental Spend Ratio
This chart displays the ratio of a year-ending environmental reserve balance to
that year's spending off of that reserve. This ratio implies a useful life of
the current reserve at the current spend rate. (Note: no spend data was found
for ConocoPhillips).
METROPOLITAN looked at this ratio to identify a competitive range, or
benchmark, to see if any one company has a pattern of over- or under-reserving,
relative to this peer group.
ExxonMobil maintains the least number of years in their environmental reserves,
while BP generally maintains the most. METROPOLITAN noted that BP's ratio of
environmental reserve balance to spend dropped significantly between 2007 and
2008 due to both an increase in reserve spending and a decrease in reserve
additions during that period. While there is no standard for the number of
years of the environmental reserve balance, there seems to be a competitive
range of 2 to 7 years.
Key Takeaways:
METROPOLITAN encourages you to take a look at your own company's environmental
reserves (and if relevant, E&P restoration balance) and environmental
expenditure rate, to see how they compare to the Big Five.
Ask yourself the following questions:
·
Is
your company consistently accounting for and disclosing your environmental
liabilities and reserves?
·
Is
your company properly accounting for and disclosing your Exploration and
Production balances?
·
Does
your company have a pattern of fluctuating spend and reserve balances that are
not in sync with the project needs?
·
Do
environmental cleanup projects close and reopen?
·
Where
do new environmental liabilities come from?
·
Is
your environmental reserve going down only to be replenished with another year
of the same or more expected spending?
If any of the above
questions trigger discussion and analysis among your management teams, you are
likely moving in a good direction. Environmental liability analysis and
management requires time and attention and the involvement of a range of
stakeholders. While comparing your own company to peers can be a useful
expertise, consistent, repeatable policies and procedures need to be
developed from within.
Metropolitan Risk Management Services (MRMS)
Metropolitan Risk Management
Services (MRMS) is a professional service firm that specializes in outsourced
risk management and advisory services.
Based in the East Coast, the firm has several offices in the Northeast
and Midwest, with clients throughout the United States, Canada, Europe and
Latin America. While our clients are
diverse businesses and organizations, each share a common approach - - a
genuine desire to prevent and mitigate losses.
Invariably, our clients value high quality professional advice, whether
that advice is from safety consultant, engineers, attorneys, CPAs, or risk
management and insurance advisors. Their goal is to obtain the best assistance
available, fully recognizing the cost of identifying and confronting problems
before they develop is always less expensive than addressing an issue after it
is out of control.
Risk Management Services at
Metropolitan
·
Serve as
an integral part of the business management team as an outsourced risk manager
·
Overview
current loss prevention and loss mitigation processes
·
Provide
project management services to ensure critical processes are completed in a
timely manner and consistent with overall needs
·
Provide
an objective and independent expert evaluation of the current risk program,
including a written report containing specific findings and recommendations
·
Identify
and assess your current and potential risk of loss
·
Develop
alternate (non-insurance) methods of risk financing
·
Assist in
strategic planning to achieve long range risk management objectives
·
Develop
risk management education coursework for specific needs
·
Provide
guidance during merger, acquisition and divestiture activities
·
Provide
expert witness and litigation support
Metropolitan Engineering, Consulting &
Forensics (MECF)
Providing Competent, Expert and Objective Investigative Engineering and
Consulting Services
P.O. Box 520
Tenafly, NJ 07670-0520
Tel.: (973) 897-8162
Fax: (973) 810-0440
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account. Please make sure to follow us at @MetropForensics or
@metroforensics1
Metropolitan appreciates your business.
Feel free to recommend our services to your friends and colleagues.
