IEc’s team of consultants are experienced, technically capable, responsive, and well-respected in the area of
financial assurance. The depth of institutional knowledge across myriad financial assurance frameworks is necessary
to ensure that compliance recommendations fall within requisite statutory, regulatory, and legal parameters.
For more than 20 years, IEc has supported the U.S. Department of Justice, U.S. Environmental Protection Agency (EPA),
Department of Energy, Department of the Interior, regional offices and numerous state agencies providing
expert analyses related to environmental financial assurance. This support includes participating in more than
20 financial assurance program reviews, involving 40 states, ten EPA Regions, more than 1,500 financial assurance
instruments, and approximately 1,000 corporate entities. These reviews demonstrate IEc's in-depth knowledge and
practical understanding of the RCRA, CERCLA, SDWA-UIC Program, and TSCA regulatory requirements.
Since the early 1980s, EPA has integrated financial and
economic considerations in its assessments. For example, in January 1981, EPA amended its RCRA regulations
to include financial requirements for owners and operators of treatment, storage, and disposal facilities.
In recent years, the Agency has extended this need to address owner and operator obligations with respect to
CERCLA, municipal solid waste landfills (RCRA Subtitle D), and RCRA corrective action.
IEc consultants provide a range of services with respect to financial assurance.
For example, IEc consultants have developed economic benefit and financial analyses on enforcement
actions involving respondents, ranging from small privately-held firms to large publicly-traded multinationals
to governmental entities. This support includes structural analysis of corporate histories; assessing financial
trends using tax return and SEC data; and analyzing trends in compliance with the Corporate Financial Test,
use of Captive insurance products, surety bonds, and letters of credit.
IEc has also provided assistance to EPA on the development of numerous enforcement policies, including
but not limited to, a strategy for capturing the economic benefits from noncompliance derived through an
"Illegal Competitive Advantage;" development of guidance on piercing the corporate veil and analyzing
corporate structures; and revision of EPA's Ability-to-Pay financial policy. IEc consultants have been
called as experts to opine in workshops hosted by the EPA’s Environmental Finance Advisory Board,
as well as to speak at numerous ASTSWMO meetings on financial analysis, economics, and financial assurance.