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To the California Air Resources Board;

Please do not proceed with the proposed Mine Methane Capture
Protocol (MMCP) in California’s Global Warming Solutions Act AB32.
The National Resources Defense Council has said it well:

"The environmental law clinic at Stanford Law School has pointed
out problems with the analysis of how much methane will be captured
from abandoned mines without the protocol as well as potential
conflicts with future federal regulation under the Clean Air Act.
In particular, the opportunity for coal mines to be paid to reduce
emissions may make it more difficult to adopt regulations that
require them to reduce emissions. And the Sierra Club has raised
concerns about the potential that increased revenues for coal mine
owners from offset sales could increase coal production, a point
that was also raised by the Stanford clinic."

Adoption will help keep [Cap and Trade] allowance prices low by
adding tens of millions of tons of potential emissions reductions
to the carbon market. But there is no need right now for further
cost containment. ARB has proposed an additional safeguard to
ensure allowance prices stay within a reasonable range and recent
forecasts suggest that, if anything, the concern may be in the
other direction, as allowances are projected to stay near the floor
price for the foreseeable future."
(http://switchboard.nrdc.org/blogs/pmiller/coal_mine_methane_offsets_a_ba.html)

Sincerely,

Barbara Miller