|
Delays in Reimbursements Harm Both the Public and Private Sector
When state UST funds cannot reimburse claims in a timely manner it can create cash flow problems for tank owners & consultants, leading to a slowdown in cleanups and increased enviromental risks.
- Small Regulated Tank Owners: Tying up significant amounts of working capital for long periods can materially impair the profitability & balance sheets, depress property values, reduce marketability of properties, and slow job creation.
State Fund Administrators & Political Leaders: Payment delays can cause a breakdown in the marketplace when owner/operators run out of financial capacity to continue clean up's, and environmental consultants are no longer able to wait to receive reimbursement.
- Reduced voluntary cooperation can result in delays in identifying & removing LUSTs, which can result in increased public health risks & higher total clean up costs
- Regulators may spend limited management resources pursuing enforcement actions against financially strapped owner/operators rather than getting clean ups done
- Payment delays can lead to delays in closing real estate transactions or impede refinancings, which can impede the state's economy
- The failure to remove "free product" may be a violation of CFR 280.64
- Payment delays increase the risk that the state tank fund may no longer be deemed viable for meeting EPA's financial responsibility regulations
|