Settling Natural Resource Damage Responsibilities for Steel Mill Operations
By Andrew J. Halmstad, P.E., Senior Consultant
Nicole Ott, Principal, Hydrology, Geosciences, and Chemistry
OUR CHALLENGE
Trustees drafted an allocation of natural resource damage shares for Portland Harbor using nontransparent calculations and misrepresentations of facility information. The resulting proposal exaggerated industrial impact contributions from our client’s facilities to the environment. Our challenge was to craft a more equitable allocation framework.
OUR APPROACH
Over several communications, we educated the Trustees about relevant facilities, including materials handling, and the relative completeness of potential pathways to the harbor. In response to the Trustees’ draft allocation proposal, we independently recreated the contaminant footprints and calculations for estimating shares, fact-checking each of the Trustees’ assumptions. Integral’s independent analysis identified critical technical corrections to Trustee assumptions, resulting in refinements to the final allocation proposal. The team presented clear and concise presentations to the Trustees outlining corrections to their inputs and explaining why the operational details of each relevant facility warranted refinements or adjustments within their original framework.
OUR IMPACT
Our work resulted in a 50-percent reduction in shares allocated to our client. With thorough and expert analyses of our client’s facilities and potential pathways to the harbor, we were able to provide transparent and accurate information to refine the final allocation proposal and set a foundation for more equitable future allocation agreements. The Trustees and our client reached an agreement amenable to both parties, despite the inflated initial proposal.