1

UNITED STATES DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, D.C.

In The Matter of Compliance

With Federal Obligations

By the City of St. Clair, Missouri

___________________________________________________________________________________

To the Office of the Chief Counsel

Attention: FAA Part 16 Airport Proceedings Docket

AGC-610

Federal Aviation Administration

800 Independence Ave., SW

Washington, DC 20591

COMPLAINT OF THE

Tenants of the St. Clair Regional Airport

FILED PURSUANT TO 14 C.F.R. PART 16, RULES OF PRACTICE FOR

FEDERALLY-ASSISTED AIRPORT ENFORCEMENT PROCEEDINGS

Designation of Persons to Receive Service for Complainants:

Jim De Vries 

501 Ridgefield Dr. 

Pacific, Missouri 

63069 

REPLY TO THE RESPONDENTS ANSWER

FAA DOCKET 16-14-03

This is the Comlainants reply to the answer submitted by the city of St. Clair to the case docketed by the 

FAA, no. 16-14-03.

The city is attempting to Justify the charges to the airport for 5% of its insurance cost. The city has 

produced no evidence or documentation to justify this PERCENTAGE cost, such as payroll amounts that 

show that the airport is accountable for 5% of the city payroll. 

The city has stated in its response that it has charged the airport 5% of its insurance cost “for many 

years”. When in fact this started in 2009 with the Blum administration.

In 2008 the airport income was $33,005, (See page 7) and had operating expense for $6874 (see page 8). 

The city became aware of the fact that all airport revenue was to be used to operate the airport in June 

of 2008 by a letter from MoDOT. (see page 9, 10, 11). In order to substantiate the claims by the city 

that
2

the airport was a finacial burden to the city, the city started to charge the airport for insurance cost in 

order to show expenses were greater than income (see page 6) and produced a budget for 2009 with a 

proposed $10,000 insurance cost. The city failed to correct the revenue situation, according to the 

MoDOT request for information, (See pages 13, 14)and started a policy of revenue diversion by chaging 

the airport for insurance cost that results in a dissaportionate allocation of government cost to the 

airport for the benefit received.

This led to an informal complaint in 2009. (See pages 13, 14) and in September of 2010 MoDOT sent a 

letter addressing the insurance cost for the airport and revenue diversion. Pages 15, 16, 17. The 

practice of overcharging the airport for insurance has continued until the present time. As noted in the 

September 2010 letter from MoDOT, Mr. Pestka recommended that the city contact other communities 

with airports that do not sell fuel to determine how other communities establish their insurance cost. It 

is not known if the city perused this procedure. 

The complainants did do a telephone survey of other communities to find out how MIRMA costs were 

distributed by other municipalities, and every city that responded explained that they did so by payroll 

percentages, and that their insurance cost were distributed to all departments by each departments 

percentage of payroll. Cities without airports were also contacted, not one municipality in the MIRMA 

system, distributes insurance cost in a like manor to St. Clair. Mirma costs are billed to the city by 

payroll cost (See exhibit B page3 item 16 of the city’s response). 

Mr. Broderson of MIRMA at the request of the complainant answered questions regarding aviation 

insurance as shown on page 34. In the response to the 6th question.

Please describe how the contracted aviation coverage is included in the MIRMA package. The cost of the 

aviation liability policy is spread among the entire membership.

Because this is an insurance pool, each of the 74 members participate in this coverage, and each 

member’s share of the $48,094 would be $649.92 to cover the 29 airports. Each members cost for each

airport would be $22.41 even though each member does not contribute equally to the fund. The cost to 

any one individual sponsor for liability coverage to its own airport would be $22.41. 

In a follow up email to Mr. Broderson, the following reply was returned by Mr. Broderson. 

From: Jim De Vries [mailto:jimdevries@live.com]

Sent: Thursday, June 26, 2014 6:02 AM

To: Matthew Brodersen

Subject:

Can you describe how the airport coverage is assessed among the membership, and what determines how the cost 

is divided among the members?

The method to divide the assessment among the membership is proprietary information that I will not describe 

in greater detail.

Can you also send the spreadsheet with the list of airports that show the cost associated with each airport, similar 

to the one included in the insurance binder?

We no longer receive a page listing of the cost of individual airports as part of the aviation liability policy.
3

Jim Johnson and Lynn Martin had a telephone conversation with Mr. Broderson in the spring of 2013, in 

which Mr. Broderson outlined the way MIRMA handles the airport insurance. 

In a previous telephone conversation with Mr. Broderson and the complainant, Mr. Broderson was 

asked if he was familiar with Federal Aviation Administration Policy and Procedures Concerning the Use 

of Airport Revenue; and CFR part 225, and he stated that he was not familiar with the two documents. 

2. Reasonable costs. A cost is reasonable if, in its nature and amount, it does not exceed that which 

would be incurred by a prudent person under the circumstances prevailing at the time the decision was 

made to incur the cost. The question of reasonableness is particularly important when governmental 

units or components are predominately federally-funded. In determining reasonableness of a given cost, 

consideration shall be given to:

c. Market prices for comparable goods or services. 

d. Whether the individuals concerned acted with prudence in the circumstances considering their 

responsibilities to the governmental unit, its employees, the public at large, and the Federal 

Government. 

e. Significant deviations from the established practices of the governmental unit which may unjustifiably 

increase the Federal award’s (airport revenue, or in this case airport. The words airport revenue being 

substituted for Federal Award, as per The federal Register page7719) cost. 

The St. Clair Regional Airport has minimal payroll cost. The city documents provided show no payroll 

expense. The telephone survey of municipalities with airports similar to the St. Clair Regional Airport 

revealed that the municipalities that did not have any payroll expense for the airport did not charge the 

airport for insurance cost, except for Mountain Grove and Maryville.

If St. Clair is following the correct procedure, then the rest of the MIRMA members must be doing it 

incorrectly. 

The documentation that the city is claiming to be adequate to justify the charges to the airport account 

does not explain the cost of the insurance, but instead attempts to justify the charges made to the 

airport. The city and Mr. Brodersen has stated, the cost is not broken down. It is only reasonable to 

conclude that if a cost cannot be broken down, or does not exist, it cannot be documented; adequate 

documentation cannot be provided to meet the documentation requirements of the FAA regulations 

and rules. 

The FAA Policy and Procedures Concerning the Use of Airport Revenue do not address the 

reasonableness of a cost, other than “Market prices for comparable goods or services”; it addresses the 

standard of documentation that must be provided. 
4

The complainants addressed the insurance cost to MoDOT in 2009. MoDOT experienced personnel 

changes and therefore the new director did not pursue the insurance issue after Mr. Pestka resigned. 

Upon the refusal to investigate the issue by MoDOT, the complainants took the issue to the FAA office of 

Airports in the Central Region. The complainant was not notified by the Central Office until Jan of 2014, 

that the office was not in a position to challenge Mr. Brodersen’s opinion and did not offer an 

explanation of the position taken by the FAA Central Region Office. 

As can be seen by the dates on the letters from MoDOT, the city has perpetuated this issue by not 

complying with Mr. Pestka’s request for information, and corrective plans. 

Pages 18, 19, 20, 21, 22, 23 show the income and expenses for 2009, 2010, and 2011. The audited city 

records show the airport losing money for each year. If the undocumented insurance costs are removed 

from these years, the airport would be self sustaining. 

It should also be noted that in 2009 the city charged the airport for 7.8% of its insurance cost. This 

would mean that the “many years” the city has been charging 5% to the airport, is in reality only 2010, 

2011, 2012, 2013, 2014. Five years, all of which take place in the Blum administration.

The city has made the point in its arguments to close the airport, that the airport is a financial burden to 

the city, and has stated repeatedly that the city audited records show this. This overcharging is 

intentional, and designed to help accomplish one thing, to provide evidence that the St. Clair Regional 

Airport should be closed. The financial and physical condition of the St. Clair Airport did not come about 

naturally. It happened by design of the City. The city in its attempts to BULLY its way through a closure 

process, is trying to invent a new way to close an airport by “demolition by neglect”, and financial ruin. 

The City of St. Clair is also in violation of the Federal Register/Vol. 64, No. 30/Tuesday, February 16, 

1999/Notices 7719

d. Costs billed to the airport under the cost allocation plan must be similarly billed to other comparable 

units of the airport owner or operator. 

The city “percentage plan consist of, 5% airport, 40% water and sewer department, 10% parks, 45% 

administration, which includes the street department and the police department, and the city hall. In 

other words, the water and sewer department, along with the airport pay for 45% of the city insurance 

cost. The police department alone accounts for 44% to 48% of the city payroll. Water and Sewer 

account for less than 20%. See page 32. The total administration percentage of payroll is around 70%. 

This percentage breakdown by-other than payroll- is designed to shift the expense of the insurance to 

the business activities of the city, which produce cash. 

In CFR 225 Federal Register / Vol. 70, No. 168 / Wednesday, August 31, 2005 / Rules and Regulations 

page 51913. 

2. Reasonable costs. A cost is reasonable if, in its nature and amount, it does not exceed that which 

would be incurred by a prudent person under the circumstances prevailing at the time the decision was 
5

made to incur the cost. The question of reasonableness is particularly important when governmental 

units or components are predominately federally-funded. In determining reasonableness of a given cost, 

consideration shall be given to:

c. Market prices for comparable goods or services. 

The 5% number does not represent a market price for comparable services. 

Pages 25-31 are a copy of a proposal for the property damage coverage for $1663. The original file is 

attached to the e-mail. 

There are two clear and distinct points to consider in this case. 

1. The assessment to the airport by the city.

2. The cost to the city by MIRMA.

The assessment by the city to the airport is documented by the city.

The cost to the city by MIRMA is not determined and is not documented.

Clearly the assessment by the city to the airport does not document the cost to the city by MIRMA.

It is very clear that the city of St. Clair fails to meet the criteria for compliance as stated below in 

5190.6b. 

b. Preliminary assessment. FAA must make a judgment call in all cases as to whether a

sponsor is reasonably meeting its federal commitments. A sponsor meets its commitments when:

(1). The federal obligations are fully understood;

(2). A program (e.g., preventive maintenance, leasing policies, operating regulations, etc.) is in

place that the FAA deems adequate to carry out the sponsor’s commitments;

(3). The sponsor satisfactorily demonstrates that such a program is being carried out; and,

(4). Past compliance issues have been addressed.

Please investigate this complaint, and require the city of St. Clair to restore to the airport account all 

undocumented charges to the airport account and use all resources available to the FAA to enforce this 

grant assurance as outlined in the FAA Policy and Procedures Concerning the Use of Airport Revenue.

The complainants here by enter a motion asking the FAA compliance office to require the City of St. Clair 

to provide the proprietary information referred to in Mr. Brodersen’s email concerning the distribution 

of the airport coverage among the MIRMA members. 
6
7
8
9
10
11
12

Thayer Mo 0

Richland Mo 0

Mansfield Mo 0

Tarkio 0

Hannibal 0

Hermann 0

Maryville by payroll 1 emp

Albany 0

Mountain Grove no paid employees $500
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14
15
16
17
18
19
20
21
22
23
24
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ST. CLAIR REGIONAL AIRPORT

April 29, 2015

SWETT & CRAWFORD

1001 CRAIG ROAD, SUITE 260

April 29, 2014

ST. LOUIS, MO 63146

PLUS INSURANCE SALES PROPOSAL

@VANTAGE FOR COMMERCIAL ACCOUNTS

POLICY DATE:

IN PARTNERSHIP WITH:

April 29, 2014 thru

This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

1

@VANTAGE FOR COMMERCIAL ACCOUNTS PLUS

INSURANCE SALES PROPOSAL

DATE April 29, 2014

BUSINESS CLIENT ST. CLAIR REGIONAL AIRPORT

EFFECTIVE DATE April 29, 2014

EXPIRATION DATE April 29, 2015

QUOTE 1563857-1

IN PARTNERSHIP WITH SWETT & CRAWFORD

1001 CRAIG ROAD, SUITE 260

ST. LOUIS, MO 63146

UNDERWRITING COMPANY Atlantic Specialty Insurance Company

150 Royall Street

Canton, MA 02021

This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

2

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This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

3

@vantage for Commercial Accounts Plus Quote Proposal

Payment Plan

Agency Bill - Annual - Payment in Full No Installments

Premium Summary for ST. CLAIR REGIONAL AIRPORT

Coverage
26

Coverages Premium

Property Coverages $1,616

Terrorism Coverage $47

Premium When Excluding Terrorism Coverage $1,644

Premium When Including Terrorism Coverage $1,663

This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

4

Common Policy Forms

Form Description

4 VIL 100 10 98 COMMON POLICY DECLARATIONS

ASC 00 02 01 98 PREMIUM STATEMENT

ASC 00 12 01 98 SCHEDULE OF LOCATIONS

VIL 001 02 05 COMMON POLICY CONDITIONS- (N/A TO VA AUTO)

VIL 645 MO 02 13 MO CHANGES - CANCELLATION & NONRENEWAL

ASC 00 11 01 98 Schedule 1 - LIST OF COMMON DEC FORMS

Non-Policy Forms

Form Description

CLD 132 01 08 POLICYHOLDER DISCLOSURE NOTICE OF TERRORISM

INSURANCE COV

CLD 149 01 08 MO TERRORISM INSURANCE DISCLOSURE NOTICE

SUPPLEMENT

IL P 001 01 04 U.S. TREASURY DEPT OFFICE OF FOREIGN ASSETS

NOTICE

VGN 002 01 10 SPECIAL PROPERTY PLUS COVERAGE FORM QUICK

REFERENCE GUIDE

This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

5

SCHEDULE OF LOCATIONS

Loc Bldg Address

1 1 HANGAR 1 ST. CLAIR REGIONAL AIRPORT

SAINT CLAIR, MO 63077-3310

2 HANGAR 2 ST. CLAIR REGIONAL AIRPORT

SAINT CLAIR, MO 63077-3310

3 HANGAR 3 ST. CLAIR REGIONAL AIRPORT

SAINT CLAIR, MO 63077-3310

4 HANGAR 4 ST. CLAIR REGIONAL AIRPORT

SAINT CLAIR, MO 63077-3310

This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

6

Property Location Coverages

Property Policy Coverages

Property Policy Coverage Enhancements

Loc Bldg Coverage Limit Deductible Val Premium

1 1 Building $349,000 $1,000 RC $1,043

2 Building $76,800 $1,000 RC $229

3 Building $38,400 $1,000 RC $115

4 Building $76,800 $1,000 RC $229

Coverage Limit Deductible Val Premium

Equipment Breakdown Portfolio Included

Expediting Expenses $100,000

Hazardous Substances $100,000

Perishable Goods $100,000
27

CFC Refrigerants $100,000

Business Income

Coverage Limit Deductible Val Premium

Bucket

Per Occurrence $250,000

Personal Effects of Officers,

Partners & Employees

Valuable Information Property

Accounts Receivable

Outdoor Property

Fine Arts - Per Item $5,000

Hardware and Media

Fire Extinguisher and Automatic

Extinguishing System Recharge

Emergency Response Service Charge

Conditional Sales Agreement

Decreased value of Stock due to

Damage to another part or parts

of Stock

Tenants Improvements & Betterments

Electronic Data Damage or

Destruction from Inland Marine

Causes of Loss

Electronic Data Loss of Income and

Extra Expense from Inland Marine

Causes of Loss

This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

7

Property Policy Coverage Enhancements

Coverage Limit Deductible Val Premium

Property in Transit $1,000

Per Occurrence $25,000

International Air Shipments $1,000

Per Occurrence $10,000

Property at Other Locations $1,000

Per Occurrence $25,000

Crime Limit of Insurance $10,000 $1,000

Money and Securities

Employee Theft

Money Orders and Counterfeit Paper

Currency

Forgery and Alteration

Inside the Premises - Robbery or

Safe Burglary of Other Property

ERISA Employee Theft $0

Per Occurrence $10,000

Credit, Debit or Charge Card Forgery $1,000

Per Occurrence $5,000

Newly Acquired or Constructed Property $1,000

Building $1,000,000

Days 120

Personal Property $500,000

Days 120

Claim Expense $0

Per Occurrence $25,000
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Reward $0

Per Occurrence $25,000

Contractual Penalties $0

Per Occurrence $25,000

Automatic Seasonal Increase (Peak $1,000

Season)

This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

8

Property Policy Coverage Enhancements

Coverage Limit Deductible Val Premium

Per Occurrence $50,000

Brands and Labels Expense $1,000

Per Occurrence $25,000

Food Contamination $1,000

Per Occurrence $10,000

Lessee's Leasehold Interest Coverage

Per Occurrence $10,000

Limited Coverage for Fungus, Wet Rot, $1,000

Dry Rot and Bacteria

Annual Aggregate $15,000

Electronic Data Damage or Destruction - $1,000

Cyber Vandalism - Employee

Annual Aggregate $25,000

Electronic Data Damage or Destruction - $1,000

Cyber Vandalism - Non-Employee

Annual Aggregate $5,000

Electronic Data Loss of Income and Extra

Expense - Cyber Vandalism - Employee

Annual Aggregate $25,000

Waiting Period - 72 hours

Electronic Data Loss of Income and Extra

Expense - Cyber Vandalism - NonEmployee

Annual Aggregate $5,000

Waiting Period - 72 hours

Denial of Service Coverage

Annual Aggregate $5,000

California Hardware, Media and $1,000

Electronic Data Earthquake

Per Occurrence $100,000

Preservation of Property - Expense $0

This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

9

Property Policy Coverage Enhancements

Property Location Coverage Enhancements

Coverage Limit Deductible Val Premium

Per Occurrence $25,000

Lock Replacement

Per Occurrence $5,000

Catastrophe Allowance $0

Annual Aggregate $25,000

Expediting Expenses $0

Per Occurrence $25,000
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Soft Costs $0

Per Occurrence $10,000

Temporary Relocation of Property $0

Coverage During Renovation or

Remodeling

Per Occurrence $50,000

Days 90

Salesmen's Samples $1,000

Per Occurrence $10,000

Green Upgrades Additional Coverage

Per Occurrence $25,000

10% Green Upgrades Percentage

Loc Bldg Coverage Limit Deductible Val Premium

The following coverages are at each

Location/Building with Building Coverage

unless otherwise stated:

Building Ordinance Combined Coverages

B&C $0

Coverage A included in Building

Limit

Coverages B&C $250,000

This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

10

Property Location Coverage Enhancements

Additional Terms, Conditions, and Underwriter Comments:

AGREED VALUE APPLIES TO BUILDING COVERAGE

_______________

THE FOLLOWING EXCLUSION APPLIES:

VCP 475 01 10 BROAD WATER EXCLUSION

Loc Bldg Coverage Limit Deductible Val Premium

The following coverages are at each

Location/Building unless otherwise

stated:

Pollutant Clean Up and Removal $25,000 $1,000

Debris Removal $50,000 $1,000

Special Theft Limits of Insurance

Furs $10,000 $1,000

Jewelry $10,000 $1,000

Precious Metals $10,000 $1,000

Stamps $1,000 $1,000

Property Forms

Form Description

ASC 00 03 01 98 PROPERTY COV PART DEC - POLICY LEVEL LIMITS

OF INSURANCE

ASC 00 13 01 10 SUPPLEMENTAL PROPERTY DEC

IL 01 05 10 08 MO CHANGES - POLLUTION

IL 09 52 03 08 CAP ON LOSSES FROM CERTIFIED ACTS OF

TERRORISM

IL 09 95 01 07 CONDITIONAL EXCLUSION OF TERRORISM

VCP 001 01 10 SPECIAL PROPERTY PLUS COVERAGE FORM

VCP 003 01 10 PROPERTY CONDITIONS

VCP 004 01 10 CRIME CONDITIONS

VCP 100 01 10 COMMERCIAL PROPERTY DEC

VCP 470 01 10 GREEN UPGRADES ADDITIONAL COVERAGE
30

VIL 663 MO 01 10 MO CHANGES

ASC 00 11 01 98 Schedule 2 - PROPERTY FORMS LIST

POLICYHOLDER DISCLOSURE

NOTICE OF TERRORISM INSURANCE COVERAGE

You are hereby notified that under the Terrorism Risk Insurance Act (the Act), as amended, that you now 

have a

right to purchase insurance coverage for losses arising out of acts of terrorism, as defined in Section 

102(1) of the

Act: The term “act of terrorism” means any act that is certified by the Secretary of the Treasury, in 

concurrence

with the Secretary of State and the Attorney General of the United States, to be an act of terrorism; to be 

a violent

act or an act that is dangerous to human life, property, or infrastructure; to have resulted in damage within 

the

United States, or outside the United States in the case of certain air carriers or vessels or the premises of 

a United

States mission; and to have been committed by an individual or individuals as part of an effort to coerce 

the

civilian population of the United States or to influence the policy or affect the conduct of the United States

Government by coercion.

COVERAGE TO BE PROVIDED BY THE POLICY FOR LOSSES CAUSED BY CERTIFIED ACTS OF

TERRORISM, AS DEFINED IN THE ACT, MAY BE PARTIALLY REIMBURSED BY THE UNITED 

STATES

GOVERNMENT IN ACCORDANCE WITH A FORMULA ESTABLISHED UNDER THE ACT. UNDER THE

FORMULA, THE UNITED STATES GOVERNMENT WOULD PAY 85% OF COVERED TERRORISM 

LOSSES

THAT EXCEED THE STATUTORILY IMPOSED DEDUCTIBLE FOR WHICH THE INSURANCE 

COMPANY IS

RESPONSIBLE. THE PREMIUM TO BE CHARGED FOR THIS COVERAGE IS PROVIDED BELOW 

AND DOES

NOT INCLUDE ANY CHARGES FOR THE PORTION OF LOSS COVERED BY THE FEDERAL 

GOVERNMENT

UNDER THE ACT.

THE ACT CONTAINS A $100 BILLION CAP THAT LIMITS U.S. GOVERNMENT REIMBURSEMENT AS 

WELL

AS INSURERS’ LIABILITY FOR LOSSES RESULTING FROM CERTIFIED ACTS OF TERRORISM 

WHEN THE

AMOUNT OF SUCH LOSSES EXCEEDS $100 BILLION IN ANY ONE CALENDAR YEAR. IF THE 

AGGREGATE

INSURED LOSSES FOR ALL INSURERS EXCEED $100 BILLION, YOUR COVERAGE MAY BE 

REDUCED.

SELECTION OR REJECTION OF TERRORISM INSURANCE COVERAGE

The prospective premium required for your terrorism coverage is: $ _____________. If you wish to reject 

this

offer of coverage, you should check the box below, sign this notice and send it to your agent. An 

exclusion of

terrorism losses, as defined by the Act, will then be made part of your policy.

If you wish to reject this offer of coverage, you should check the box below, sign this notice and send it to 

your

agent. An exclusion of terrorism losses, as defined by the Act, will then be made part of your policy.

I hereby reject the offer of terrorism coverage. I understand that I will have no

_____ coverage for losses arising from acts of terrorism, as defined in the Act.

Possibility of Additional or Return Premium

The premium shown above is calculated based in part on the federal participation in payment of terrorism

losses as set forth in the Terrorism Risk Insurance Act. The federal program established by the Act is
31

scheduled to terminate at the end of 12/31/14. If the federal program terminates or if the level or terms of

federal participation change, the estimated premium shown above may not be appropriate.

If this policy contains a Conditional Exclusion, continuation of coverage for certified acts of terrorism, or

termination of such coverage, will be determined upon disposition of the federal program, subject to the 

terms

and conditions of the Conditional Exclusion. If this policy does not contain a Conditional Exclusion, 

coverage

for certified acts of terrorism will continue. In either case, when disposition of the federal program is

determined, we will recalculate the estimated premium shown above and will charge additional premium 

or

refund excess premium, if indicated.

If we notify you of an additional premium charge, the additional premium will be due as specified in such 

notice.

CLD 130 01 08

ST. CLAIR REGIONAL AIRPORT

Atlantic Specialty Insurance Company

Quote Number: 1563857-1

OneBeacon Insurance Group LLC

47

Copyright 2008, Page 1 of 2

Insured Name and Address:

150 Royall Street

Canton, MA 02021

If your policy includes Property Coverage in one or more of these states: CA, CT, GA, HI, IA, IL, 

MA,

ME, MO, NC, NJ, NY, OR, RI, VA, WA, WI, or WV; the following statement applies:

The terrorism exclusion makes an exception for (and thereby continues your coverage for) property fire

losses resulting from an act of terrorism. Therefore, if you reject the offer of terrorism coverage, that

rejection does not apply to fire losses resulting from an act of terrorism - the coverage in your policy for

such fire losses will continue. If such a loss occurs, and is certified under the Act, the loss will be

reimbursed by the United States under the formula detailed above.

The portion of your policy premium attributable to terrorism (fire only) coverage in all of the states listed

above, in which your policy provides property coverage, is $________________. This amount is included

in your policy premium and cannot be rejected.

Policyholder/Applicant’s Signature Insurance Company 

 

Print Name Date 

If you have any questions about this notice, please contact your agent. 

CLD 130 01 08 Copyright 2008, OneBeacon Insurance Group LLC Page 2 of 2

28

Atlantic Specialty Insurance Company
32

The following is from the minutes for December 5, 2011,

http://stclairmo.com/stclairmo/pdf/minutes/2011/12052011.pdf

Public comments: 

Mr. Jim Devries, 501 Ridgefield Drive, Pacific, MO. a tenant of the St. Clair Regional Airport. 

Mr. Devries asked the insurance cost for the airport in 2012. Administrator Childers responded, 

“The budgeted number is $6,900, and in 2011 it is $6,736 to date which is a split of 50% of the 

general fund, which is 45% Administration, 5% Airport, 10% Parks, 20% Water and 20% Sewer. 

Mr. Devries discussed an FAA cost guideline that pertains to how insurance costs are allocated 

on airport fund. Mr. Devries is questioning the cost of $6,000 for insurance when MIRMA is 

only paying $1,500. Administrator Childers responded this was discussed with both MIRMA and 

MoDOT Aviation. MIRMA is on record stating they believe the allocation formula the City of 

St. Clair uses is adequate and accurate. Mr. Devries responded MIRMA is not the governing 

body of the FAA. Mayor Blum advised Mr. Devries, “The FAA is fully aware of what we charge 

them and we have not received any complaints from them.”
33

Jim Dc Vries

501 Ridgetield Dr.

Pacific MO 63069

To Mat Brodersen

Mirma

3002 Falling Leaf Court

Columbia, MO 65201

Thank you for agreeing to answer my Questions.

Mr DeVries,

My answers are found below in bold type and are current as of 6-25-2014

How much is the current contract for aviation coverage? The current aviation liability policy that 

MIRMA purchased was $48,094.

How many airports are in the Mirma system? 29

How many members are there in the Mirma System? 74

Does each member of MIRMA share equally in the expense of the airport contracted coverage? No, the 

cost of the aviation liability policy is spread among the entire membership but the amount each

member contributes is not equal.

What is the approximate percentage of a municipality’s premium account for workman’s compensation? 

(Ballpark figure in the case of St. Clair Missouri) MIRMA does not rate by line of coverage and does not 

divide membership costs by department or by line of coverage.

Please describe how the contracted aviation coverage is included in the MIRMA package. The cost of the 

aviation liability policy Is spread among the entire membership.

Does the contracted aviation coverage only cover the operations (liability) portion of the airport? The 

aviation liability coverage is a group purchase and covers only the risks associated with aviation.

Does Mirma provide the property damage portion of the coverage? MIRMA provides coverage for 

damage to the property located at the airport that is owned by the city.

Is it a standard practice for the MIRMA members to distribute the MIRMA cost among its departments 

based on Payroll percentages of the individual departments? I cannot speculate on the various

methods used by the membership to distribute the MIRMA costs among their departments. MIRMA 

does not rate by line of coverage and does not divide membership costs by department or by line of 

coverage.

Date 6/2512014
34

Mr DeVries,

See bold type below.

Matthew Brodersen

Executive Director

3002 Falling Leaf Ct

Columbia MO 65201

(573) 817-2554

(573) 441-0515 fax

mbrodersen@mirma.org

From: Jim De Vries [mailto:jimdevries@live.com]

Sent: Thursday, June 26, 2014 6:02 AM

To: Matthew Brodersen

Subject:

Can you describe how the airport coverage is assessed among the membership, and what 

determines how the cost is divided among the members?

The method to divide the assessment among the membership is proprietary information that I will not 

describe in greater detail.

Can you also send the spreadsheet with the list of airports that show the cost associated with 

each airport, similar to the one included in the insurance binder?

We no longer receive a page listing of the cost of individual airports as part of the aviation liability 

policy.
35
ST. CLAIR REGIONAL AIRPORT

April 29, 2015

SWETT & CRAWFORD

1001 CRAIG ROAD, SUITE 260

April 29, 2014

ST. LOUIS, MO 63146

PLUS INSURANCE SALES PROPOSAL

@VANTAGE FOR COMMERCIAL ACCOUNTS 

POLICY DATE:

IN PARTNERSHIP WITH:

April 29, 2014 thru
This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

 1

@VANTAGE FOR COMMERCIAL ACCOUNTS PLUS

INSURANCE SALES PROPOSAL

 DATE April 29, 2014

 BUSINESS CLIENT ST. CLAIR REGIONAL AIRPORT

 EFFECTIVE DATE April 29, 2014

 EXPIRATION DATE April 29, 2015

 QUOTE 1563857-1

 IN PARTNERSHIP WITH SWETT & CRAWFORD

1001 CRAIG ROAD, SUITE 260

ST. LOUIS, MO 63146

 UNDERWRITING COMPANY Atlantic Specialty Insurance Company

150 Royall Street

Canton, MA 02021
This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

 2

ABOUT ONEBEACON

OneBeacon Insurance Group, Ltd. is a Bermuda-domiciled holding company that is publicly traded on the New

York Stock Exchange under the symbol "OB". OneBeacon's underwriting companies offer a range of specialty

insurance products sold through independent agencies, regional and national brokers, wholesalers and managing

general agencies. Each business is managed by an experienced team of specialty insurance professionals

focused on a specific customer group or industry segment. OneBeacon's solutions target professional liability;

ocean and inland marine;entertainment, sports and leisure; excess property;environmental;group accident;

programs; public entities; commercial surety; technology; and tuition refund. For further information about our

products and services visit www.onebeacon.com and to remain up to date on OneBeacon's news, follow us on

Twitter @OneBeaconIns or visit our online newsroom: www.onebeacon.com/newsroom.
This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

 3

@vantage for Commercial Accounts Plus Quote Proposal

Payment Plan

Agency Bill - Annual - Payment in Full No Installments

Premium Summary for ST. CLAIR REGIONAL AIRPORT

 Coverage

Coverages Premium

Property Coverages $1,616

 Terrorism Coverage $47

Premium When Excluding Terrorism Coverage $1,644

Premium When Including Terrorism Coverage $1,663
This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

 4

Common Policy Forms

Form Description

4 VIL 100 10 98 COMMON POLICY DECLARATIONS

ASC 00 02 01 98 PREMIUM STATEMENT

ASC 00 12 01 98 SCHEDULE OF LOCATIONS

VIL 001 02 05 COMMON POLICY CONDITIONS- (N/A TO VA AUTO)

VIL 645 MO 02 13 MO CHANGES - CANCELLATION & NONRENEWAL

ASC 00 11 01 98 Schedule 1 - LIST OF COMMON DEC FORMS

Non-Policy Forms

Form Description

CLD 132 01 08 POLICYHOLDER DISCLOSURE NOTICE OF TERRORISM

 INSURANCE COV

CLD 149 01 08 MO TERRORISM INSURANCE DISCLOSURE NOTICE

 SUPPLEMENT

IL P 001 01 04 U.S. TREASURY DEPT OFFICE OF FOREIGN ASSETS

 NOTICE

VGN 002 01 10 SPECIAL PROPERTY PLUS COVERAGE FORM QUICK

 REFERENCE GUIDE
This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

 5

SCHEDULE OF LOCATIONS

 Loc Bldg Address

 1 1 HANGAR 1 ST. CLAIR REGIONAL AIRPORT

SAINT CLAIR, MO 63077-3310

 2 HANGAR 2 ST. CLAIR REGIONAL AIRPORT

SAINT CLAIR, MO 63077-3310

 3 HANGAR 3 ST. CLAIR REGIONAL AIRPORT

SAINT CLAIR, MO 63077-3310

 4 HANGAR 4 ST. CLAIR REGIONAL AIRPORT

SAINT CLAIR, MO 63077-3310
This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

 6

 Property Location Coverages

 Property Policy Coverages

 Property Policy Coverage Enhancements

 Loc Bldg Coverage Limit Deductible Val Premium

 1 1 Building $349,000 $1,000 RC $1,043

 2 Building $76,800 $1,000 RC $229

 3 Building $38,400 $1,000 RC $115

 4 Building $76,800 $1,000 RC $229

Coverage Limit Deductible Val Premium

Equipment Breakdown Portfolio Included

 Expediting Expenses $100,000

 Hazardous Substances $100,000

 Perishable Goods $100,000

 CFC Refrigerants $100,000

 Business Income

Coverage Limit Deductible Val Premium

Bucket

 Per Occurrence $250,000

 Personal Effects of Officers,

 Partners & Employees

 Valuable Information Property

 Accounts Receivable

 Outdoor Property

 Fine Arts - Per Item $5,000

 Hardware and Media

 Fire Extinguisher and Automatic

 Extinguishing System Recharge

 Emergency Response Service Charge

 Conditional Sales Agreement

 Decreased value of Stock due to

 Damage to another part or parts

 of Stock

 Tenants Improvements & Betterments

 Electronic Data Damage or

 Destruction from Inland Marine

 Causes of Loss

 Electronic Data Loss of Income and

 Extra Expense from Inland Marine

 Causes of Loss
This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

 7

 Property Policy Coverage Enhancements

Coverage Limit Deductible Val Premium

Property in Transit $1,000

 Per Occurrence $25,000

International Air Shipments $1,000

 Per Occurrence $10,000

Property at Other Locations $1,000

 Per Occurrence $25,000

Crime Limit of Insurance $10,000 $1,000

 Money and Securities

 Employee Theft

 Money Orders and Counterfeit Paper

 Currency

 Forgery and Alteration

 Inside the Premises - Robbery or

 Safe Burglary of Other Property

ERISA Employee Theft $0

 Per Occurrence $10,000

Credit, Debit or Charge Card Forgery $1,000

 Per Occurrence $5,000

Newly Acquired or Constructed Property $1,000

 Building $1,000,000

 Days 120

 Personal Property $500,000

 Days 120

Claim Expense $0

 Per Occurrence $25,000

Reward $0

 Per Occurrence $25,000

Contractual Penalties $0

 Per Occurrence $25,000

Automatic Seasonal Increase (Peak $1,000

 Season)
This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

 8

 Property Policy Coverage Enhancements

Coverage Limit Deductible Val Premium

 Per Occurrence $50,000

Brands and Labels Expense $1,000

 Per Occurrence $25,000

Food Contamination $1,000

 Per Occurrence $10,000

Lessee's Leasehold Interest Coverage

 Per Occurrence $10,000

Limited Coverage for Fungus, Wet Rot, $1,000

 Dry Rot and Bacteria

 Annual Aggregate $15,000

Electronic Data Damage or Destruction - $1,000

 Cyber Vandalism - Employee

 Annual Aggregate $25,000

Electronic Data Damage or Destruction - $1,000

 Cyber Vandalism - Non-Employee

 Annual Aggregate $5,000

Electronic Data Loss of Income and Extra

 Expense - Cyber Vandalism - Employee

 Annual Aggregate $25,000

 Waiting Period - 72 hours

Electronic Data Loss of Income and Extra

 Expense - Cyber Vandalism - Non-

 Employee

 Annual Aggregate $5,000

 Waiting Period - 72 hours

Denial of Service Coverage

 Annual Aggregate $5,000

California Hardware, Media and $1,000

 Electronic Data Earthquake

 Per Occurrence $100,000

Preservation of Property - Expense $0
This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

 9

 Property Policy Coverage Enhancements

 Property Location Coverage Enhancements

Coverage Limit Deductible Val Premium

 Per Occurrence $25,000

Lock Replacement

 Per Occurrence $5,000

Catastrophe Allowance $0

 Annual Aggregate $25,000

Expediting Expenses $0

 Per Occurrence $25,000

Soft Costs $0

 Per Occurrence $10,000

Temporary Relocation of Property $0

 Coverage During Renovation or

 Remodeling

 Per Occurrence $50,000

 Days 90

Salesmen's Samples $1,000

 Per Occurrence $10,000

Green Upgrades Additional Coverage

 Per Occurrence $25,000

 10% Green Upgrades Percentage

 Loc Bldg Coverage Limit Deductible Val Premium

The following coverages are at each

Location/Building with Building Coverage

unless otherwise stated:

Building Ordinance Combined Coverages

 B&C $0

 Coverage A included in Building

 Limit

 Coverages B&C $250,000
This proposal contains only a general description of the coverages and does not include all of the benefits, terms, conditions, exclusions and limitations

found in the policy. The insurance policy itself, not this descriptive proposal, will form the contract between the insured and the insurance company.

Quote: 1563857-1

 10

 Property Location Coverage Enhancements

Additional Terms, Conditions, and Underwriter Comments:

AGREED VALUE APPLIES TO BUILDING COVERAGE

_______________

THE FOLLOWING EXCLUSION APPLIES:

VCP 475 01 10 BROAD WATER EXCLUSION

 Loc Bldg Coverage Limit Deductible Val Premium

The following coverages are at each

Location/Building unless otherwise

stated:

Pollutant Clean Up and Removal $25,000 $1,000

Debris Removal $50,000 $1,000

Special Theft Limits of Insurance

 Furs $10,000 $1,000

 Jewelry $10,000 $1,000

 Precious Metals $10,000 $1,000

 Stamps $1,000 $1,000

Property Forms

Form Description

ASC 00 03 01 98 PROPERTY COV PART DEC - POLICY LEVEL LIMITS

 OF INSURANCE

ASC 00 13 01 10 SUPPLEMENTAL PROPERTY DEC

IL 01 05 10 08 MO CHANGES - POLLUTION

IL 09 52 03 08 CAP ON LOSSES FROM CERTIFIED ACTS OF

 TERRORISM

IL 09 95 01 07 CONDITIONAL EXCLUSION OF TERRORISM

VCP 001 01 10 SPECIAL PROPERTY PLUS COVERAGE FORM

VCP 003 01 10 PROPERTY CONDITIONS

VCP 004 01 10 CRIME CONDITIONS

VCP 100 01 10 COMMERCIAL PROPERTY DEC

VCP 470 01 10 GREEN UPGRADES ADDITIONAL COVERAGE

VIL 663 MO 01 10 MO CHANGES

ASC 00 11 01 98 Schedule 2 - PROPERTY FORMS LIST
POLICYHOLDER DISCLOSURE 

NOTICE OF TERRORISM INSURANCE COVERAGE 

You are hereby notified that under the Terrorism Risk Insurance Act (the Act), as amended, that you now have a 

right to purchase insurance coverage for losses arising out of acts of terrorism, as defined in Section 102(1) of the 

Act: The term “act of terrorism” means any act that is certified by the Secretary of the Treasury, in concurrence 

with the Secretary of State and the Attorney General of the United States, to be an act of terrorism; to be a violent 

act or an act that is dangerous to human life, property, or infrastructure; to have resulted in damage within the 

United States, or outside the United States in the case of certain air carriers or vessels or the premises of a United 

States mission; and to have been committed by an individual or individuals as part of an effort to coerce the 

civilian population of the United States or to influence the policy or affect the conduct of the United States 

Government by coercion. 

COVERAGE TO BE PROVIDED BY THE POLICY FOR LOSSES CAUSED BY CERTIFIED ACTS OF 

TERRORISM, AS DEFINED IN THE ACT, MAY BE PARTIALLY REIMBURSED BY THE UNITED STATES 

GOVERNMENT IN ACCORDANCE WITH A FORMULA ESTABLISHED UNDER THE ACT. UNDER THE 

FORMULA, THE UNITED STATES GOVERNMENT WOULD PAY 85% OF COVERED TERRORISM LOSSES 

THAT EXCEED THE STATUTORILY IMPOSED DEDUCTIBLE FOR WHICH THE INSURANCE COMPANY IS 

RESPONSIBLE. THE PREMIUM TO BE CHARGED FOR THIS COVERAGE IS PROVIDED BELOW AND DOES 

NOT INCLUDE ANY CHARGES FOR THE PORTION OF LOSS COVERED BY THE FEDERAL GOVERNMENT 

UNDER THE ACT. 

THE ACT CONTAINS A $100 BILLION CAP THAT LIMITS U.S. GOVERNMENT REIMBURSEMENT AS WELL 

AS INSURERS’ LIABILITY FOR LOSSES RESULTING FROM CERTIFIED ACTS OF TERRORISM WHEN THE 

AMOUNT OF SUCH LOSSES EXCEEDS $100 BILLION IN ANY ONE CALENDAR YEAR. IF THE AGGREGATE 

INSURED LOSSES FOR ALL INSURERS EXCEED $100 BILLION, YOUR COVERAGE MAY BE REDUCED. 

SELECTION OR REJECTION OF TERRORISM INSURANCE COVERAGE 

The prospective premium required for your terrorism coverage is: $ _____________. If you wish to reject this 

offer of coverage, you should check the box below, sign this notice and send it to your agent. An exclusion of 

terrorism losses, as defined by the Act, will then be made part of your policy. 

If you wish to reject this offer of coverage, you should check the box below, sign this notice and send it to your 

agent. An exclusion of terrorism losses, as defined by the Act, will then be made part of your policy.

 I hereby reject the offer of terrorism coverage. I understand that I will have no

 _____ coverage for losses arising from acts of terrorism, as defined in the Act. 

Possibility of Additional or Return Premium 

The premium shown above is calculated based in part on the federal participation in payment of terrorism 

losses as set forth in the Terrorism Risk Insurance Act. The federal program established by the Act is 

scheduled to terminate at the end of 12/31/14. If the federal program terminates or if the level or terms of 

federal participation change, the estimated premium shown above may not be appropriate. 

If this policy contains a Conditional Exclusion, continuation of coverage for certified acts of terrorism, or 

termination of such coverage, will be determined upon disposition of the federal program, subject to the terms 

and conditions of the Conditional Exclusion. If this policy does not contain a Conditional Exclusion, coverage 

for certified acts of terrorism will continue. In either case, when disposition of the federal program is 

determined, we will recalculate the estimated premium shown above and will charge additional premium or 

refund excess premium, if indicated. 

If we notify you of an additional premium charge, the additional premium will be due as specified in such notice. 

CLD 130 01 08

ST. CLAIR REGIONAL AIRPORT

Atlantic Specialty Insurance Company

Quote Number: 1563857-1

OneBeacon Insurance Group LLC

47

Copyright 2008, Page 1 of 2

Insured Name and Address:

150 Royall Street

Canton, MA 02021
If your policy includes Property Coverage in one or more of these states: CA, CT, GA, HI, IA, IL, MA, 

ME, MO, NC, NJ, NY, OR, RI, VA, WA, WI, or WV; the following statement applies: 

The terrorism exclusion makes an exception for (and thereby continues your coverage for) property fire

losses resulting from an act of terrorism. Therefore, if you reject the offer of terrorism coverage, that 

rejection does not apply to fire losses resulting from an act of terrorism - the coverage in your policy for 

such fire losses will continue. If such a loss occurs, and is certified under the Act, the loss will be 

reimbursed by the United States under the formula detailed above. 

The portion of your policy premium attributable to terrorism (fire only) coverage in all of the states listed 

above, in which your policy provides property coverage, is $________________. This amount is included 

in your policy premium and cannot be rejected. 

 

Policyholder/Applicant’s Signature Insurance Company 

 

Print Name Date 

If you have any questions about this notice, please contact your agent. 

CLD 130 01 08 Copyright 2008, OneBeacon Insurance Group LLC Page 2 of 2

28

Atlantic Specialty Insurance Company