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Storage Tank Local Government Bond Rating Test

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Form 62-761.900(3) Part I

Also Needed

  • Form Part P (Certification of Financial Responsibility) must also be completed
    • Period of Coverage: publication date of bond rating to end-of-month, one year later (e.g., 8/7/19 to 8/31/20)
  • Maintain copy of Bond Rating published within the last 12 months by Moody’s or Standard & Poor’s (or both if both issue ratings)  

General Guidance

  • Calculate FR needs, Reference Manuals, EPA link and FAQs
  • DEP forms must be used and filled out completely
  • Verify current version of form part is used ("October 2019" version if signed after 10/13/2019)
  • Verify facility and tanks at site have coverage. The following should match the state registration:
    • Facility identification number (FacID) (for facilities in Florida)
    • Facility name
    • Site address
    • Number of regulated tanks (or list of tank identification numbers)

Bond Rating Test Specific Guidance

  • The “owner or operator” name identified on mechanism needs to match the name on Part P.
  • The Chief Financial Officer (CFO) may have a title different from "CFO", such as Clerk, Comptroller, Treasurer, etc. but the CFO title is unlikely to include the word "assistant". Other individuals may have the authority to sign, but they will be able to produce documentation demonstrating their authorization.
  • Confirm bond rating(s) on copy(ies) of published report(s):
    • Moody's rating of Aaa, Aa, A, or Baa (not including Baa-) or
    • Standard & Poor's (S&P) rating of AAA, AA, A, or BBB (not including BBB-)
    • If rated by both firms, both sets or criteria must be met.  Use the Period of Coverage for the lowest rated bond, or if equal (e.g., Moody's Baa and S&P BBB), the period that starts later.
  • A local government organized to provide general governmental services must reference only general obligation bonds on the Bond Rating Test and not revenue bonds. Non-general purpose local governments (e.g., special districts, school districts) must reference revenue bonds.

What to Do with Completed Forms

  • An owner or operator must maintain financial responsibility records (the completed form parts with required supporting documentation) at the facility or at their business office.
  • If not kept at the facility, they shall be made available at the facility or another agreed upon location upon five business days notice by a department or county inspector.

Links to Verify Bond Ratings

  • Moody's – Will need to set up free account, or phone Ratings Desk at (212) 553-0377.
  • Standard and Poor's – Will need to set up free account, or phone Ratings Desk at (877) 772-5436.

Return to Storage Tank Financial Assurance Forms (Mechanisms) webpage

Form Number: 
62-761.900(3) Part I
Effective-Revision Date: 
Friday, February 7, 2020
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Last Modified:
February 25, 2020 - 2:02pm

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