Comment Log Display

Ms. Rajinder Sahota
Chief - Climate Change Program Evaluation Branch
California Air Resources Board
1001 I Street

Sacramento, CA 95814

Encore BioRenewables is a marketing and business development
company based in California, specializing in sustainable,
recyclable and renewable bio-based products. 

Encore BioRenewables strongly supports the proposed California Air
Resources Board (ARB) compliance offset protocol for mine methane
capture (MMC) projects. This will be the first protocol written
entirely by ARB through the public protocol development process. 
Offset credits represent a crucial cost containment mechanism to
help the California cap-and-trade program achieve GHG emission
reductions in an economically efficient manner.
 
Experts are now reporting that Methane is a green house gas with a
Global Warming Potential twenty five times that of 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 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.  

Mines in the United States 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 overall 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 also encourage more research and measurement of
methane emissions from all sources.

 
Encore BioRenewables encourages officials to approve and make
effective the protocol as soon as possible.

Thank you for your consideration,