We’re nearing the conclusion of our data-gathering for the additionality review. The report should be in the hands of our review panel by the end of this week.
We had an opportunity last week to interview the Arkansas Department of Environmental Quality. These folks are the source of the most serious charges in the BusinessWeek article. To recap, ADEQ contends in the article that the methane flaring system was installed at Tontitown to address a groundwater contamination problem, calling into question whether offsets played a role in development of the project.
The ADEQ interview was the most important remaining step in our review process. Our interview notes, along with the interview notes from our previous conversation with Waste Management, are available on the project review web site. There is a regrettable he-said/she-said quality to some aspects of this issue, but that is something the review board will have to sort through.
I’m not going to get too deeply into the specifics of the interviews here, as they don’t lend themselves to easy summary. I do want to draw out some higher level points, though.
The first is that everyone has been helpful and forthright throughout this entire process. Although the BusinessWeek article may have given the impression of startling accusations and revelations, in fact the people involved in the project are engineers who are more than happy to chat about the ins and outs of landfill methane, and are loathe to make assertions that they can’t back up with prior experience or solid data.
The second is that the BusinessWeek article is increasingly coming across one-sided. Not because the article failed to uncover a real issue, but because it largely ignored the ambiguities surrounding its major claims. At this point, the situation basically boils down to four facts and one contention.
The facts, in chronological order:
- Waste Management’s initial work on a methane flaring system was voluntary.
- ADEQ placed Waste Management under a “corrective action” to compel them to fix a groundwater contamination problem.
- The methane flaring system was fully implemented after the corrective action was issued.
- The methane flaring system fixed the groundwater issue and also allowed Waste Management to generate carbon credits for sale on the Chicago Climate Exchange.
Based on our conversations with everyone involved, no one disputes these facts or this essential timeline. At issue is this single contention:
According to Waste Management, the methane flaring system represents an investment that goes significantly above and beyond what was necessary to address the groundwater problem. Because the project voluntarily exceeds the requirements of the corrective action, it is a legitimate source of carbon credits.
It is up to our expert panel to judge the merit of this contention. But here’s what ADEQ’s Gerald Delevan (the source of the BusinessWeek quotes) had to say about it:
Whether [Waste Management] went above and beyond what they needed to do, I don’t have the first clue…I know that the system they installed addressed the groundwater problem. Whether it went over and above that, I don’t think there’s anyone here that knows that. That’s not something we evaluate. Whether they went the extra mile, I don’t know.
I can’t stress strongly enough that this is not a “gotcha” or smoking gun. Delevan was being up front about the fact that he’s never been asked to evaluate whether the project went above and beyond requirements. Assessing additionality is not in ADEQ’s purview.
Which leaves us wondering why the BusinessWeek piece didn’t present a more nuanced view of the questions it raised, or at least bother to ask a credible outside authority about the allegations. Water under the bridge at this point. The final report should be available shortly.