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Environmental Law

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Transactional

Thompson Coburn's Environmental practice also works extensively in the transactional arena. We have successfully handled the environmental components of numerous deals, including multistate stock and asset deals and real estate and Brownfield redevelopment deals where environmental concerns were central to the transaction. We routinely represent clients in environmental matters associated with mergers, acquisitions and divestitures, as well as in the buying, selling and developing of commercial/industrial property.

Areas of Transactional Service

  • Coordinating and directing the performance of Phase I/Phase II investigations and reports, compliance audits, work plans, remedial investigations and remediation reports, as well as evaluating the data, conclusions and recommendations presented in such reports.
  • Identifying and assessing potential liability associated with current and past disposal facilities and other “legacy liability” concerns.
  • Identifying and assisting with potential disclosure and reporting requirements under federal and state law.
  • Negotiating and documenting allocations of liability between buyers and sellers with respect to known and unknown environmental liabilities.
  • Obtaining appropriate environmental insurance coverage for environmental liabilities, such as on-site and off-site cleanup liabilities, bodily injuries, property damage and natural resource damages.
  • Evaluating the cost-effectiveness of method of achieving compliance with applicable laws and regulations and obtaining liability protection to the extent feasible.
  • Assisting clients with pre- and post-closing investigation and remediation required under purchase and sale agreements, resolving compliance deficiencies and obtaining environmental permits and/or getting existing permits transferred.
  • Structuring transactions to obtain tax credits, Brownfield funding and other governmental incentives, where available.
  • Negotiating governmental approvals for work plans, cleanup objectives, cleanup strategies and risk assessments.
  • Drafting escrows and holdbacks and other funding arrangements to facilitate the sales and purchases of environmentally impaired properties and businesses.
  • Agrium
  • American Commercial Barge Lines
  • Bemis Company
  • BNSF Railway
  • Bunge North America
  • CKE Restaurants (Hardee's)
  • ConocoPhillips
  • ExxonMobil Coal & Minerals
  • ExxonMobil
  • Insituform Technologies
  • Kansas City Southern Railway
  • Laclede Gas
  • Mallinckrodt
  • Norfolk Southern
  • United Van Lines 
  • WCA Waste Corporation
Transaction Experience

Award-Winning Brownfield Development
Thompson Coburn represented a developer in connection with the purchase of a 153-acre abandoned manufacturing plant and its subsequent transformation into a business park. The negotiation of cleanup cost cap and pollution legal liability insurance policies were integral to the success of the development. In addition, the project received a Community Impact Award from the prestigious Phoenix Award Program in Illinois.
Representation of Multinational Sewer Rehabilitation Company
We represent a publicly held company that manufactures sewer liners and performs sewer rehabilitation projects throughout North America and Western Europe. We often conduct environmental due diligence for the company’s acquisitions and divestitures. Recently, we represented the company in connection with the stock purchase of a corrosion-control engineering and services company with 45 owned and leased facilities throughout the United States as well as in Canada and the United Kingdom. We also recently represented the company in connection with the acquisition of several large facilities located in Louisiana, Texas and California.

Multistate Transactions

Acquisition of Chemical Manufacturing Facilities

Thompson Coburn represented a commercial real estate development company with the acquisition of a portfolio of 13 former chemical manufacturing facilities located in California, Illinois, Indiana, Massachusetts, New Jersey, New Mexico, Pennsylvania and Montreal, Quebec, Canada. After the acquisition, we assisted the client in the cleanup, development and sale of the facilities.
Multistate Purchase of Motor Repair and Service Business
We represented a client in the purchase of approximately forty (40) motor repair and service centers located in Alabama, California, Colorado, Georgia, Illinois, Indiana, Kansas, Louisiana, North Carolina, Nebraska, Ohio, Oregon, Pennsylvania, South Carolina, Tennessee, Texas, Wisconsin and Wyoming.
Sale of Multistate Heat Treatment Business
We represented a client in the sale of five heat treating facilities located in Michigan, Ohio, Illinois, Missouri and California. This representation involved coordination of due diligence activities, negotiation of contract terms and obtaining environmental insurance to back-stop an indemnity from the buyer for remediation liability. In connection with this representation, we gained working knowledge of the significant pre-purchase due diligence responsibilities imposed upon and liability protections potentially available to buyers under Michigan’s Environmental Response Act (MERA).
Multistate Residential and Mixed Use Housing Development
We represent a developer of mixed use and multifamily housing units which are constructed generally in urban areas with significant environmental concerns. The development projects are located in many states, including Tennessee, Florida, Louisiana, Missouri and Pennsylvania. Because of the residential nature of the developments, we are often involved in negotiating Brownfield Agreements with the state agencies to implement cleanups that are both cost effective and protective of the future residents.
Multistate Purchase of Scrap Metal and Battery Recycling Facility
Thompson Coburn represented a client in the purchase of a company with approximately 10 scrap metal/battery recycling facilities in Wisconsin and the purchase of three additional scrap yards in Minnesota, Iowa and Illinois. The due diligence included investigation of current and former facilities, disposal facilities and regulatory compliance audits. The contract negotiations included cleanup commitments by and indemnities from the sellers for conditions identified by the due diligence.
Purchase of Multistate Vehicle Manufacturing Facility
Our attorneys represented a client in connection with the asset purchase of eight emergency vehicle manufacturing facilities located in Florida, New York, Oregon, Pennsylvania, South Carolina and Wyoming. This representation included the coordination of Phase I, Phase II and compliance assessments, negotiation and documentation of liability allocation between the seller and buyer and the post-closing resolution of contamination and compliance issues identified during due diligence.
Sale of Electronics Manufacturing Facility
We represented a client in the sale of a former electronics manufacturing facility located in Connecticut that had been impacted with solvent contamination. This representation involved working through the complex requirements and procedures of the Connecticut Transfer Act, including the use of an Environmental Land Use Restriction.
Brownfield Development of Former Steel Plant
We assisted our client in the purchase and the development of a former steel plant into the then largest open air shopping center in St. Louis. We planned and directed the client’s due diligence investigation, along with the environmental consultants, negotiated and obtained governmental approval of cleanup plans and objectives for distinct areas of the site, presented those plans to and obtained approval from the lenders and bond underwriters that provided the financing for the project, created escrows to fund post-closing cleanup, and assisted the client in its implementation and completion of all cleanup activities.
Hospital and Healthcare Facility Acquisition and Divestitures
We often represent hospitals and other medical care facilities with respect to real property and business acquisitions and divestitures. For example, we represented a buyer in connection with the acquisition of 23 hospitals in nine states. As a result of these transactions, we have developed a comprehensive environmental due diligence checklist for environmental issues specifically related to health care facilities.
Manufactured Gas Plant Site Cleanup/Redevelopment
We are currently representing a client involved in the cleanup and development of a former manufactured gas plant site located adjacent to a major waterway. Portions of the investigations have been funded through Brownfield grants and private contributions. It is contemplated that the remediation will be funded primarily through remediation tax credits.
Cleanup Funded through Remediation Tax Credits
Thompson Coburn represented a major university in its successful efforts to develop and lease a portion of its campus to establish the world headquarters of a major business concern. Necessary remediation work revealed by environmental and geotechnical borings were funded primarily through the generation and sale of Brownfield remediation tax credits.
Retail Petroleum Facilities
For many years, we have represented a land owner who owns the ground under multiple service stations throughout the St. Louis metropolitan area, the largest car wash company in the state of Missouri and one of the country’s most significant gasoline/convenience store chains. We have assisted these clients in numerous matters, including the buying, selling and leasing of property, underground storage tank technical compliance, contaminant investigation and remediation and tank fund reimbursement claims.