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Comment 59 for Cap and Trade 2013 (capandtrade13) - 15-1.

First NameSarah
Last NameSauter
Email Addresssarah@theconservationcenter.org
AffiliationWestern Slope Conservation Center
Subjectroposed offset protocol for mine methane capture
Comment
The Western Slope Conservation Center is a grassroots non-profit
conservation organization in western Colorado. We are dedicated to
protecting and enhancing the environment and quality of life in
Delta County and Colorado's Western Slope. The Conservation Center
strongly supports the proposed California Air Resources Board (ARB)
compliance offset protocol for mine methane capture (MMC) projects.


The Conservation Center is located in Colorado's North Fork Valley
which is home to three coal mines. Each of our mines must vent
methane gas as a safety precaution. We have always encouraged the
mines to capture the methane because of its properties as a potent
green house gas, which is up to 25 times more potent than carbon
dioxide. 

Methane also is an energy source that if used conserves energy from
other sources and reduces green house gas emissions. The World Bank
estimates that 7,500,000,000 metric tons of CO2 equivalent per year
of methane is emitted annually around the world. That methane if
used for electricity generation for example could produce
250,000,000 Mega Watt Hours per year.  

In 2012 a local partnership between Aspen Ski Company, Holy Cross
Energy, Oxbow Carbon, Gunnison Energy Corporation, and Vessels Coal
Gas enabled the first coal mine methane capture facility in
Colorado to go online. While groundbreaking, the project in our
valley was only possible because Aspen Ski Company was willing to
pay higher rates for the energy generated from the coal mine
methane. The Conservation Center envisions a future where all
methane vented from mines can be converted to local electricity.

Unfortunately, mines in the USA typically are pressured to sign
electricity agreements prohibiting them from self generating any
electricity from their own waste methane. There is no incentive to
avoid methane emissions and rules to reduce emissions are likely to
take years and never be as effective as an economic incentive. We
have no verifiable estimate of methane emissions over all from
active or abandoned mines as the cost of performing detailed
surveys is prohibitive. This protocol will encourage the generation
of new and accurate data of methane emissions from mines. This
could encourage more research and measurement of methane emissions
from all sources.

The Conservation Center encourages the California Air Resources
Board to approve and make effective the protocol as soon as
possible. 

Attachment
Original File Name
Date and Time Comment Was Submitted 2014-04-03 08:48:54

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