A Market-Based Analysis of Financial Assurance Issues

0,28
MB Associated with U.S. Natural Resource Damage Liability

60
stron

929
ID Resources for the Future

2000
rok

Table of Contents

1. Introduction

1.1 Financial Assurance in the U.S.

1.2 The Intersection of NRD Law and Financial Assurance Regulations

1.3 Organization of the Report

2. The Conceptual Justification for Financial Assurance Requirements

2.1 Liability and Cost Internalization

2.2 Financial Assurance as a Performance Bond

2.3 Reduced Litigation and Administrative Costs

2.4 The Impact on Firm Decision-Making

3. Natural Resource Damages Law

3.1 NRDs Under Federal Law

3.1.1 The physical, legal, and economic definitions of natural resource damage

3.1.2 The distinction between remediation and restoration

3.1.3 Administrative procedures and authority

3.2 NRDs Under State Law

3.3 NRDs and Citizen Standing to Sue

3.3.1 The common law basis

3.3.2 The federal basis

4. NRD Damage Assessment and Valuation

4.1 The Regulatory Development of Assessment Procedures

4.2 The Current Rules

5. Financial Responsibility for Natural Resource Damages

5.1 Overview of the Rules

5.2 Required Coverage and Liability Limits

5.3 Are the Coverage Limits Appropriate?

5.4 Allowable Mechanisms

5.4.1 Insurance and Surety Bonds

5.4.2 Self-Insurance

5.4.3 Financial Guaranty (Indemnity)

5.5 Financial Assurance for NRDs Associated with Onshore Facilities

5.6 State FR Requirements

6. Insurer & PRP Concerns

6.1 “Direct Action” and Insurer Refusals to Provide Coverage

6.2 Risk, NRD Assessment Methods, and Insurability

6.3 Calls for Legislative Reform

7. The Insurance Market

7.1 Compliance Costs

7.2 Coverage Availability

7.3 The Scale and Frequency of NRD Claims

7.4 Insurance Bias, Adverse Selection, and Moral Hazard

8. Financial Assurance in a Broader Context

8.1 Coverage Rates

8.2 Retroactivity and the Availability of Affordable Coverage

9. Voluntary Provision of Environmental Insurance

10. Conclusion

11. Addendum: Liability for Genetically Modified Organisms