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I commend the ARB staff for producing a well-designed and effective
MMC protocol.  The quality and relevance of the work indicates that
the staff successfully learned critical intricacies of mining
operations and understands the economics of the industry to ensure
incentives created by the Protocol are fairly applied and
distributed.

This MMC protocol will enable and encourage mines to voluntarily
reduce GHG emissions that would otherwise be vented, a requirement
by law to ensure miner safety, to the atmosphere.  Mitigating these
emissions is expensive and would not be achieved without financial
compensation.

The “Mine Methane Capture Protocol and Mining Economics” analysis
is very conservative and yet still demonstrates that MMC projects
will not impact the financial standing of coal mines.  It will not
encourage development of new mines, nor will it prolong the life of
operating mines. Coal mining will continue as it did before the MMC
protocol, however mines that would otherwise vent methane will now
have a means to recover some of the costs of reducing their GHG
emissions.

MMC projects require large capital expenditures that are difficult
to securitize and are risky, both operationally and economically. 
Recognizing the full crediting period of a project is necessary to
attract investments and achieve the goals of the Program.

Project developers recognize the value of energy in mine methane
and endeavor to utilize this resource where possible. 
Unfortunately, the extreme terrain and remote and often isolated
locations of many mines prohibit the utilization of this energy. 
Recognizing flares as qualifying destruction devices is essential
to maximize GHG emission reductions driven by this protocol as the
alternative would be to vent this gas.