New York’s landfill lining codes often set the tone for the adoption of liner codes throughout the United States. In Somerset, New York, however, a power company’s fly ash landfill has not met the double-liner system requirements. A new cell is being constructed and should meet the strictures of a joint agreement to use HDPE geomembranes, but a questions remain about the legitimacy of the old cell and of the rules as they pertain to the company’s situation.