Comment Log Display

Where there is coal there is methane.  Methane seeps from coal
deposits whether the coal is mined or not.  Methane from coal is a
natural resource that can be hard to capture too.  Historically,
methane was viewed as a waste product of mining valuable coal.   Of
the known methane emissions, EPA estimates that less than 25% are
being captured and beneficially used.   

The proposed California Air Resources Board (ARB) compliance offset
protocol for mine methane capture (MMC) projects encourages use of
a natural resource that is being wasted.  We have no rigorous
verifiable estimate of overall methane emissions including
emissions 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
because the potential value of using and eliminating those
emissions. This could encourage more research and measurement of
methane emissions from all sources.

Please approve the Mine Methane Capture Protocol and the make
effective date of the protocol as soon as possible.