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I'm writing to ask that flaring of methane emissions from coal
extraction be excluded as a carbon abatement strategy considered in
California's greenhouse gas regulations. Methane escaping from coal
extraction is extra emissions that mining operations should have to
count as part of their GHG burden. It's unfair to count the flaring
of such gas, as a reduction in their impact, especially when it
comes from an activity (coal mining) that is central to causing the
problem in the first place.