Finance and Planning Financial Services Accounting for Conditional Asset Retirement Obligations FIN 47 Table of Contents 01. Policy Statement ........................................................................................................................ 2 02. Reason for Policy ...................................................................................................................... 2 03. Who Needs to Know This Policy ............................................................................................... 2 04. Legal Obligations ....................................................................................................................... 2 05. Process Summary ..................................................................................................................... 3 06. Who Needs to Know This Procedure ........................................................................................ 3 07. Initial Adoption ........................................................................................................................... 3 08. Guidance on Changes in Estimates for and Applying Payments to Asset Retirement Obligations ........................................................................................................................................ 4 09. Changes in ARO Due to Passage of Time or Amount (Statement 143, paragraph 15) ........... 4 10. Revisions to a previously recorded asset obligation (Statement 143 paragraphs A26 and A27) .................................................................................................................................................. 4 11. Changes in Accounting Estimate (Statement 154, paragraph 19) ............................................ 5 12. Annual Review and Reporting ................................................................................................... 5 13. Explanation of Woodard & Curran Costs .................................................................................. 5 14. Example of ARO accounting with $1 million Asbestos Remediation Payment ......................... 6 Last Changed: August 17, 2010 Page 1 1 of 7 Toby R. Winer Finance and Planning Financial Services 01. Policy Statement In 2006 the University recorded conditional asset retirement obligations for the estimated costs associated with asbestos removal for its relevant properties. The University will timely identify and record new conditional asset retirement obligations as they arise, depreciate and continue to accrete the interest on the ARO, and reevaluate the estimates used in the calulations for appropriateness. 02. Reason for Policy In 2001, FASB issued SFAS 143 requiring entities, including Universities, to record liabilities for tangible long-lived assets that must be retired or disposed of in a specified way by law or contract. Such liabilities are known as Asset Retirement Obligations (ARO’s). An ARO is an unconditional legal obligation associated with the retirement (settling) of a tangible long-lived asset and must be recognized even if the timing and/or method of the settlement of that obligation is conditioned on a future event, provided that the liability’s fair value can be reasonably estimated (www.fasb.org.) Due to diversity in practice and implementation, FASB issued Interpretation 47 (FIN 47) in March 2005. The obligation to perform the asset retirement activity is unconditional even though uncertainty exists around the timing and/or method of settlement. The effective date for implementation is fiscal year 2006. 03. Who Needs to Know This Policy Multi-discipline teams comprised of members from finance, physical plant, purchasing, and general counsel. 04. Legal Obligations FASB 143 Accounting for Asset Retirement Obligations (2001) • Requires entities to record liabilities for tangible, long-lived assets (e.g., buildings containing asbestos) that must be retired or disposed in a specified way by law or contract. • Such liabilities are Asset Retirement Obligations (AROs) FIN 47 Accounting for Conditional Asset Retirement Obligations (2005) • Clarifies that FASB 143 applies to all entities with legal obligations to retire long-lived assets. Last Changed: August 17, 2010 Page 2 2 of 7 Toby R. Winer Finance and Planning Financial Services 05. Process Summary In 2006 the University recorded conditional asset retirement obligations for the estimated costs associated with asbestos removal for its relevant properties. The University will timely identify and record new conditional asset retirement obligations as they arise, depreciate and continue to accrete the interest on the ARO, and reevaluate the estimates used in the caluculations for appropriateness. 06. Who Needs to Know This Procedure The Vice President Finance, Executive Director for Financial Reporting, Controller, and Vice President for Facilities are responsible for quantifying the obligations and recognizing the applicable depreciation and interest accretion. Legal Counsel and other persons knowledgeable about buildings or specialized equipment may be consulted with final review and approval by the Executive Director for Financial Reporting and Analysis and the Vice President for Finance. 07. Initial Adoption The asset retirement cost is measured as of the date the asset retirement obligation is incurred, and then rolled forward (by accreting the discount of the liability and depreciating the capitalized retirement costs) to the date of the adoption of the interpretation. The amounts should be measured using current information, current assumptions, and current interest rates. Assumptions used by Pace at adoption: Inflation: 3 % Discount rate: 6.5% Liability inception date: 1987 Estimated life of buildings: 90 years Settlement dates of ARO: Various The initial accounting of the adoption of this impacts balance sheet (assets and liabilities) and statement of activities (cumulative effect of change in accounting) A liability for any existing asset retirement obligation(s) adjusted for cumulative accretion of the discount to the date of adoption of the interpretation An asset retirement cost capitalized as an increase to the carrying amount of the associated long-lived asset Accumulated depreciation on the capitalized asset retirement cost The following information was disclosed in the initial year of adoption of Interpretation 47: The effect of adopting the interpretation on change in net assets before extraordinary items and on changes in net assets for the period of adoption. The income before extraordinary items and net income computed on a pro forma basis for all the periods presented, as if the interpretation had been applied during all the periods affected. The disclosure must appear on the face of the statement of activities. Last Changed: August 17, 2010 Page 3 3 of 7 Toby R. Winer Finance and Planning Financial Services The amount of the liability for asset retirement obligations for the beginning of the earliest year presented and the end of each year presented, as if the interpretation had been applied during all the periods affected. The pro forma amount of the liability for the asset retirement obligation(s) for each yearend presented and for the beginning of the earliest year presented. 08. Guidance on Changes in Estimates for and Applying Payments to Asset Retirement Obligations FIN 47, paragraph 7: Statement 143 provides guidance for adjusting the liability for revisions to either the timing or the amount of the original estimate of undiscounted cash flows. 09. Changes in ARO Due to Passage of Time or Amount (Statement 143, paragraph 15) Changes resulting from revisions to the timing or the amount of the original estimate of undiscounted cash flows shall be recognized as an increase or a decrease in (a) the carrying amount of the liability for an asset retirement obligation and (b) the related asset retirement cost capitalized as part of the carrying amount of the related long-lived asset. Upward revisions in the amount of undiscounted estimated cash flows shall be discounted using the current creditadjusted risk-free rate. Downward revisions in the amount of undiscounted estimated cash flows shall be discounted using the credit-adjusted risk-free rate that existed when the original liability was recognized. If an entity cannot identify the prior period to which the downward revision relates, it may use a weighted-average credit-adjusted risk-free rate to discount the downward revision to estimated future cash flows. When asset retirement costs change as a result of a revision to estimated cash flows, an entity shall adjust the amount of asset retirement cost allocated to expense in the period of change if the change affects that period only or in the period of change and future periods if the change affects more than one period as required by FASB Statement No. 154, Accounting Changes and Error Corrections, (paragraphs 19-22), for a change in estimate 10. Revisions to a previously recorded asset obligation (Statement 143 paragraphs A26 and A27) Revisions to a previously recorded asset retirement obligation will result from changes in the assumptions used to estimate the expected cash flows required to settle the asset retirement obligation, including changes in estimated probabilities, amounts, and timing of the settlement of the asset retirement obligation, as well as changes in the legal requirements of an obligation. Any changes that result in upward revisions to the expected cash flows shall be treated as a new liability and discounted at the current rate. Any downward revisions to the expected cash flows will result in a reduction of the asset retirement obligation. For downward revisions, the amount of the liability to be removed from the existing accrual shall be discounted at the credit-adjusted riskfree rate that was used at the time the obligation to which the downward revision relates was originally recorded (or the historical weighted-average rate if the year(s) to which the downward revision applies cannot be determined). Revisions to the asset retirement obligation result in adjustments of capitalized asset retirement costs and will affect subsequent depreciation of the related asset. Such adjustments are depreciated on a prospective basis. Last Changed: August 17, 2010 Page 4 4 of 7 Toby R. Winer Finance and Planning Financial Services 11. Changes in Accounting Estimate (Statement 154, paragraph 19) A change in accounting estimate shall be accounted for in (a) the period of change if the change affects that period only or (b) the period of change and future periods if the change affects both. A change in accounting estimate shall not be accounted for by restating or retrospectively adjusting amounts reported in financial statements of prior periods or by reporting pro forma amounts for prior periods. 12. Annual Review and Reporting Management will review their estimates on an annual basis. The following actions will be taken: 1. Finance will ask Facilities Management to identify possible asset requirements obligations that may be relevant for buildings and property. 2. Modify the data in the ARO excel spreadsheets. See example of ARO excel spreadsheet below: a. For subsequent years, depreciate the ARO and continue to accrete the interest on the ARO b. A new long-lived asset with legal obligations based on environmental issues (underground tanks, lab equipment, chemical storage, etc.) is put into place. c. Remediation is performed. Asset is removed using the same methodology employed by Woodard and Curran. Cost estimates by category will be used to remove the obligation. The liability is adjusted by the payment and the asset continues to be depreciated until year of settlement. d. There is a significant change in the market or in the unit rates. The spreadsheets are maintained in the Controller2 Folder. 13. Explanation of Woodard & Curran Costs Woodard & Curran was retained by Pace in October 2006 to assist in quantifying its asset retirement obligations. Woodard & Curran relied on information in the Hall Kimbrell Asbestos Assessment Report prepared February 1988. Last Changed: August 17, 2010 Page 5 5 of 7 Toby R. Winer Finance and Planning Financial Services 14. Example of ARO accounting with $1 million Asbestos Remediation Payment Last Changed: August 17, 2010 Page 6 6 of 7 Toby R. Winer Finance and Planning Financial Services Last Changed: August 17, 2010 Page 7 7 of 7 Toby R. Winer