I'd like to respond to that question by using two examples. One is the concept of additionality, and one is the concept of looking at the entire emissions or the net emissions, as opposed to one aspect of emissions.
On additionality, the answer is highlighted in our report, with the exhibit showing the graph that tries to depict the notion of additionality. It's a question of whether this fund resulted in the reductions attributed to the fund or whether other factors were at play. In this case, it was the methane regulations.
If one funds the same activities that were going to happen anyway with the methane regulations, one cannot say that those emissions reductions were attributable to the program. By failing to carve out the cause and effect of the program from the methane regulations, there was an overestimation because the concept of additionality was not utilized properly.
A second aspect is the net emissions question. The figures provided by the department do not provide the big picture in terms of the total effect of the funding on the facilities and the equipment at issue. We wanted to know what the net effect of the program was, not just the emissions attributed to the piece of equipment that was being upgraded at the site. This is a problem, because many of the applications that we reviewed that produced the facilities indicated that they would be increasing production. However, those increases in production, which could offset the emissions reductions from the equipment being installed, were not factored into the estimations of the department.