| Comment | Thank you for this opportunity to provide comments on the proposed
regulation.
Our comments are attached. We support the CARB's recognition of
coal mine ventilation air methane (VAM) offsets as a reliable
source of offsets for the CARB's cap and trade program.
Our recommendations can be summarized as follows:
(1) Recognize VAM oxidation as an eligible offset project
category for the first compliance period;
(2) Adopt a coal mine methane (CMM) protocol based on CAR’s
existing CMM Project Protocol;
(3) Recognize VAM CRTs generated by projects started after
October 7, 2007.
Best regards,
Raphael Bruneau
Director
Carbon markets
Biothermica Technologies Inc.
|
|---|