First Test: Prospective Purchaser Defense Fails

In November of 2006, the earth shook.  At that time, the EPA regulations relating to the Bona Fide Prospective Purchaser Defense (“BFPP”), became effective.  The BFPP Defense, theoretically, allows the purchase of contaminated real estate without stepping into Superfund liability. Though too soon to tell, it looks like it might have just been a minor tremor.

For the first time, a court has interpreted the requirements of the BFPP Defense. In the case of Ashley II of Charleston, LLC v. PCS Nitrogen, Inc. v. Ross Development Corp. et al, the Federal District Court for South Carolina took on the issue. The facts are both complicated and, at times, confusing. The need for an $8 million dollar clean-up was identified at a fertilizer manufacturing plant. The remediation will require the removal of arsenic, lead, PAH contamination and raising the pH of the site. There were multiple parties brought into the action and the allocation made to each party is interesting reading. However, this post will focus on the liability of Ashley II, a limited liability company. Interestingly, the principals of Ashley are Cherokee Investment Partners which is a large investment fund that has dedicated $1 billion dollars to the acquisition of Brownfields properties.

As part of a multi-million dollar project, Ashley retained an environmental engineer.  The project included the purchase of a part of the land that now needs remedial action. A Phase I Environmental Site Assessment was issued and, shortly thereafter, the property was purchased. The Phase I identified some sumps and stained concrete pads as Recognized Environmental Conditions (“RECs”). Ashley did not do any testing around the sumps or the concrete pads to determine if the RECs had, in fact, caused a release.

Some time thereafter, Ashley tore down some buildings on a parcel of the property which had covered sumps that previously contained hazardous substances. No testing was done around the sumps prior to removal of the buildings.

 

THE EIGHT ELEMENTS OF THE BFPP DEFENSE

In analyzing Ashley’s assertion of the BFPP Defense, the Court required Ashley to prove eight elements by a preponderance of the evidence.

I. NO DISPOSAL AFTER ACQUISITION

The BFPP Defense requires that there be no disposal of any hazardous substances after the acquisition of the property. Judge Seymour arrived at an interesting reading of this requirement. The Judge found that Ashley removed the outside structure of the buildings but left in place a number of sumps and pads and did not conduct soil testing under the pads. Testimony showed that, after the removal of the building, the sumps would fill with rain water which would then seep through cracks in the sumps or fill up and overflow onto the site. Based on these findings, the Court determined that disposals "likely" had occurred after the purchase of the property.  More importantly, the burden of proof was held to be on Ashley.  In the words of the Court: "The court concludes that Ashley did not prove that no disposals occurred on the Site after its acquisition of the Site."

II. CONDUCT OF ALL APPROPRIATE INQUIRIES

The Court noted that Ashley had an ASTM-compliant Phase I Environmental Site Assessment conducted prior to purchase. While there were some claims of non-compliance with ASTM standards, the Court found that Ashley acted reasonably and that it “properly conducted AAI.”

III. LEGALLY REQUIRED NOTICES

Next, the Court looked to see if there was a release of any hazardous substance since acquisition of the property that needed to be reported. Oddly, the Court found that Ashley satisfied this requirement because

[t]he record does not establish that any releases occurred on the Site subsequent to Ashley acquiring ownership. The Court finds that Ashley has met its burden of proving that it made all legally required notices.

IV. THE EXERCISE OF APPROPRIATE CARE

To show that it exercised appropriate care, Ashley needed to show that it took reasonable steps to: 1) stop any continuing release; 2) prevent any threatened future release; and 3) prevent or limit human, environmental, or natural resource exposure to any previously released hazardous substance. Again, Ashley fell short.  The Court found that Ashley’s failure to clean out and fill in the sumps, thus leaving them exposed to the elements, resulted in possible releases. Also, Ashley failed to prevent debris from accumulating on the site, did not investigate a debris pile and did not remove the pile for over a year. For these reasons, appropriate care was not shown.

V. FULL COOPERATION, ASSISTANCE IN ACCESS

The Court found that Ashley fully complied with this requirement.

VI. INSTITUTIONAL CONTROLS

The Court did not find any violation that institutional controls were needed and therefore this element was satisfied.

VII. COMPLIANCE WITH REQUESTS AND SUBPOENAS

The Court found full compliance with this requirement.

VIII. NO AFFILIATION

Under this requirement, Ashley needed to show that it was not: 1) a potentially responsible party; 2) affiliated with persons that were potentially liable for response costs at the site through: a) any direct or indirect familial relationships; b) any contractual, corporate or financial relationship; or c) the result of a reorganization of a business entity that was potentially liable. Ashley passed this test.  However, Ashley's indemnification of others at the site, according to the Court, "reveals just the sort of affiliation Congress intended to discourage."  Again, the Court found the BFPP Defense requirements to have been violated.

 CONCLUSION

Once done with the analysis, the Court found that Ashley was, indeed, a PRP because it was the current owner of contaminated property and it did not satisfy the requirements of the BFPP Defense. That is, the Court found that a disposal occurred after Ashley acquired the site. The Court then undertook the difficult job of allocating the costs to the various parties identified in the case. The good news is that Ashley was allocated 5% of the entire costs of clean-up. The bad news is that $400,000 is still a significant amount to pay when Ashley clearly tried to follow the rules set out by EPA.

There appears to be at least three lessons to be learned from Ashley. First, courts are going to carefully scrutinize every aspect of the BFPP Defense -- and there are a lot things that can go wrong.  Second, despite what you may have been told (by EPA officials or others), doing a Phase I ESA is not all that is necessary for the BFPP Defense -- RECs must be investigated and further reporting may be necessary. Finally, as we already knew, what happens after acquisition is important. Getting the defense is one thing, keeping it is another. 

All Appropriate Inquiry: The Limitations Could Eat The Superfund Defense

As many of you know, a new era in purchasing environmentally contaminated (or possibly contaminated) land began in November, 2006. That is when new federal rules relating to All Appropriate Inquiry commenced and allowed new defenses to CERCLA liability for buyers of real estate. Without going into a lot of detail, the rule allows buyers to limit Superfund liability if they conduct a Phase I Environmental Site Assessment, in accordance with the rules, prior to purchasing the real estate. Under these circumstances, an individual or a company theoretically will not be liable for remediation of the property even if it is contaminated. However, in order to maintain the defenses, there are certain continuing obligations that are imposed on the buyer. These include complying with land use restrictions and institutional controls, responding to information requests and administrative subpoenas and providing legally required notices. Most importantly, there is a requirement of taking “reasonable steps” with respect to hazardous substance releases, and therein lies the problem.

The obvious question that is raised is what constitutes reasonable steps? If, for example, reasonable steps requires the removal of the hazardous substance from the ground, then EPA has effectively gutted the defense.

As a general rule, reasonable steps would include stopping any continuing release, preventing any threatened future release, and preventing or limiting human, environmental or natural resource exposure to any hazardous substance released on or from the property. But does it, for example, require a Phase II audit to identify the nature and extent of the suspected contamination? Does it require capping the contaminated soils with clay or asphalt? Does it require some sort of vapor intrusion protection around the basement of a building to avoid gas buildup?

ASTM has organized the Continuing Obligation Task Group to work on a draft continuing obligation standard which will define “reasonable steps.” Currently, it appears that the Group has identified two actions that may be taken to meet the requirement. They are: (a) lower the contaminate levels, also known as remediation; or (b) prevent exposure to the contamination through institutional or engineering controls. Obviously, both of these actions also require a Phase II site assessment and both could be extremely expensive to a purchaser.

I would suggest that if the ASTM Task Group does require these actions or something close to these actions, we will essentially be back to the pre-2006 days of sites having any potential contamination being difficult to market because banks will mandate a Phase II and, if any contaminate is discovered, bank financing will dry up.

I’ll let you know as soon as I hear the edict of the ASTM Task Group.