Comment Log Display

Vessels 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. There are currently no incentives
to avoid methane emissions and regulations to reduce emissions are
not likely in the near term.  Regulations will never be as
effective as an economic incentive and not implemented as quickly.
 
Experts are now reporting that methane emissions are the most
important greenhouse gas emissions to reduce.  Methane is now
considered to have a Global Warming Potential twenty five times
that of carbon dioxide (CO2). Methane also is an energy source that
if used conserves energy from other sources while reducing
greenhouse 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
from human related activity. That methane if used for electricity
generation for example could produce 250,000,000 Mega Watt Hours
per year.  Mines in the US typically are pressured to sign
electricity agreements prohibiting them from generating any
electricity from the naturally occurring methane in their mines.  

Projects based on this protocol could incentivize mines to use a
valuable resource and not purchase electricity at additional
expense.  In locations where such energy conversion is not
economical or practical the MMC protocol will encourage feasibility
studies to reduce the emissions by combustion.  
 
Vessels encourages the Board to approve the Mine Methane Capture
Protocol and make effective date of the protocol as soon as
possible