Our final report on the Tontitown project is available.
It is now in the hands of our expert committee, and they’ve already shown themselves to be highly engaged, hitting us with a good list of questions about the project particulars. As laid out in the review process, all such questions have been appended to the public report, along with our responses.
Unless you have an intense interest in the design of landfill methane projects, you might find the 10,000-word report a touch dry. The intro is fairly readable, though, and our recommendation at the end is worth a skim.
In the report, we apply three additionality tests to the Tontitown landfill gas (LFG) flaring project: a timing test, a financial test, and a regulatory test.
We didn’t find any controversy around the timing of the project, which began in 1999, within the period allowed by the relevant CCX protocols. However, our review committee did have a question about timing, so we’ll see if their opinion differs from ours.
The financial and regulatory tests are more interesting, and are best considered together. Recall that the project started as a voluntary endeavor, but ultimately was used to satisfy a regulatory requirement to address two separate local environmental issues at the landfill. Although the LFG project itself was never specifically mandated, at issue is whether the local issues imposed a de facto regulatory requirement to destroy the landfill methane.
To put things in a very small nutshell, we concluded that the answer to this question is no. We came to this conclusion because credible alternative means to address the local environmental issues exist; because these alternatives are materially less expensive than the LFG system currently in place; and because the alternatives would not result in the destruction of significant amounts of landfill methane. In other words, the LFG system in place at Tontitown goes above and beyond what we would expect to see if Waste Management was only concerned with addressing the regulatory requirements.
However, we do acknowledge that the LFG system is serving multiple purposes, including a mandate to address some local regulatory issues. Fortunately, there is precedent for such situations under the Kyoto Protocol. Typically the way these hybrid scenarios are handled is to discount the number of offsets created from the project according to whatever proportion of the offsets are being created to satisfy regulatory requirements.
It isn’t always a trivial matter to divide up a project this way. In the case of Tontitown, we believe that only 1% of the methane destroyed is associated with the portion of the project used to address local environmental issues. Therefore, we recommend a 1% baseline adjustment.
We also make a variety of recommendations regarding our project selection process, including a more formalized set of stakeholder interviews and a public comment period.
Expect a few more posts — hopefully more interesting — on some of the bigger-picture learnings from this whole experience. And, of course, we await the final determination of our expert panel, which we hope to have in about a week’s time.