Comment Log Display

October 23, 2013

Ms. Mary Nichols
Chairman, California Air Resource Board
1001 I Street
Sacramento, CA 95814

Blue Source, LLC. Statement of Support and Comments to the
“Proposed Compliance Offset Protocol - Mine Methane Capture
Projects”

Dear Madam Chair:

Thank you for the opportunity to comment in support of ARB’s
adoption of the Proposed Compliance Offset Protocol for Mine
Methane Capture (MMC) Projects.  Blue Source, LLC has been a carbon
offset developer and marketer in North America for the last 12
years, having developed and participated in over 200 offset
projects, including forestry, coalmine methane, wastewater methane,
landfill methane, ODS, transportation and many others.  Blue Source
fully supports the development of new compliance offset protocols
that provide real, permanent and verifiable greenhouse gas emission
reductions.

Blue Source urges ARB to adopt the Proposed Protocol for MMC
Projects.  Through its approval, ARB will enable voluntary
participation in GHG emission reduction activities that, void of
traditional economic viability and absent participation in
California’s Cap and Trade Program, would not otherwise occur.  The
protocol will establish a framework to allow companies to address
the millions of tons of GHG emissions released from coal mining
each year, without incentivizing additional mining activity. 
Adoption of this protocol will serve to encourage and promote the
development and implementation of cleaner and more environmentally
responsible practices in the industry, and will result in the
ultimate goal: Reduced GHG emissions.

In addition to our support of the adoption of the MMC Projects
Protocol, Blue Source respectfully submits the following comments:

§ 3.3 (d) Offset Project Operator

	As it is currently drafted, the express designation of the OPO as
a Mine Operator (any owner, lessee or other person who operates,
controls or supervises a coal or other mine or any independent
contractor performing services or construction at such mine) may be
unnecessarily limiting and problematic in administering the
project.  Blue Source suggests that the definition be expanded to
include the scope of parties likely to be directly and critically
involved in the design, financing, construction and operation of
the project, namely those entities responsible for the direct
operation of the destruction equipment and/or the owners of the
physical assets.

§ 6.2 (a) (1) Instrument QA/QC

	While Blue Source understands and appreciates the motive for
requesting “quarterly cleaning & inspections” to ensure valid and
accurate recording of data, the simple inclusion of “cleaning” has
proven to be overly cumbersome and in some cases impossible in
practice in the field for existing offset projects.  This is
primarily due to equipment design and various requirements of
equipment manufactures.  Many manufacturers warn that removal of
the equipment for cleaning could cause inaccurate or improper
readings, and in some cases the warranties for the devices are
voided in the event of their removal.  This is a challenge that has
been encountered on a number of methane abatement projects. 
Therefore, it is recommended that the word “cleaning” be struck
from the language entirely, as relying on a quarterly inspection
alone meets ARB’s requirement to ensure that the equipment is
operating properly.

	Thank you for your consideration of these issues. Blue Source
reiterates its full support for the MMC protocol and looks forward
to a prompt implementation.



Respectfully submitted,

Eric Townsend
Chief Executive Officer
Blue Source LLC