Comment Log Display

Ms. Rajinder Sahota
Chief
Cap-and-Trade Program
California Air Resources Board


Object:	 	Support for Mine Methane Capture Protocol 


Dear Ms. Sahota,

Biothermica Technologies Inc. (“Biothermica”) would like to thank
the California Air Resources Board (ARB) for this opportunity to
support the approval of the proposed Mine Methane Capture (MMC)
Protocol. 

Our support is provided from the perspective of a ventilation air
methane (VAM) project developer and technology owner, having
developed and implemented the first VAM destruction project at an
active mine in the U.S. 

Methane abatement and Clean Technology Deployment

Mine ventilation air methane (VAM) emissions are one of the largest
sources of non-regulated greenhouse gas emissions in the U.S. Based
on the nature of these emissions –high volume but very low methane
concentrations - carbon offsets are the most effective way to
support the development of VAM abatement technologies.

Thanks to the carbon price signal finally provided by the
Protocol’s adoption, project developers will be able to deploy
their innovative methane abatement projects at several U.S. mine
sites. This price signal is a crucial factor, considering these
projects rely on carbon offsets as a source of revenues.

Swift implementation

We understand the actual implementation of the Protocol will take
place only after its approval by the Office of Administrative Law
(OAL) and the training of accredited verifiers. While we understand
and respect ARB’s administrative constraints, we do wish to
underline the importance of not delaying the implementation
schedule in order to ensure MMC projects will start delivering
offsets as soon as possible.

Sincerely,


Raphaël Bruneau
Director – Carbon Markets
Biothermica Technologies Inc.