The Usable Past of MGPs: Annual Returns and MGP Remediation
It has been known for some time in the MGP remediation and legal community that MGPs have a special well-documented past. The manufactured gas industry, in the U.S. and overseas, is almost unique in that it has been closely regulated since the early 20th century and even earlier in some states and in Western Europe. This poster presentation revisits, in light of current MGP environmental and legal concerns, the continued value of the key documentary records of the industry: namely, the annual returns filed with public service commissions and similar agencies. Supplemental handouts provide a concise survey showing which states still hold, at archives or offices, available annual returns which can be consulted if needed.
This poster presentation includes specific examples of sites where annual returns have been used to counter false conclusions. Prompted by rate issues, gas companies regularly filed detailed “annual returns” and these records can materially aid MGP professionals in the remediation and legal communities in several important ways. Notably, the returns serve to provide exact officially-required information about MGP ownership, operations, structure locations and uses over time, process changes, and gas and byproduct nature and production volumes. Knowing such data can pin down solid answers to relevant environmental, legal and community relations questions; these include who owned and managed a plant and may still hold liability for clean-up costs; precisely where and when allegedly waste-generating structures were located; how long did certain processes take place, i.e., “time–on-risk”; and how much tar and other compounds was recycled and resold as byproducts.
History Associates’ collective project experience shows that locating and carefully mining annual returns continues to have “usable past” relevance to remedial decision-making as well as legal negotiations concerning former MGP sites and potentially responsible parties (PRPs). Public communities have also become far more sophisticated in their knowledge of alleged MGP operations in their backyards and data drawn from annual returns can effectively arm utility representatives in advance with accurate, official information to counter mistaken impressions or dubious assertions.
Michael Reis, Senior Vice President, HAI
Kimberly Silvi, Senior Historian, HAI
Dennis Unites, Senior Vice President (ret.), GEI Consultants, Inc.
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