Comment Log Display

To the Air Resources Board and Staff, congratulations on all you
have accomplished since 2006.  My comments are oriented to making
the Mine Methane Capture part of Cap and Trade more cost effective
so more greenhouse gas emissions are captured sooner than later.  I
believe the invalidation requirements should be adjusted as
follows:  drop the requirement to identify any MSHA violations if
the project is owned and operated by an entity separate and apart
from the mine, do not invalidate offsets if there are violations
from other jurisdictional agencies who are competent to rule and
administer their own enforcement proceedings if they see the need
to, if you do not do that than please consider invalidation of
destruction device that is assessed a violation not the entire
project, finally we recommend being consistent and using the same
GWP for methane in the Cap and Trade system as you do in
enforcement.

Thank you for all the work you have done and the GHG emission
reductions you have caused to occur. Internally in our company we
use the most recent IPCC AR 5 of a 20 year GWP of 84 and the most
recent scientific recommendation of 100.  We do not believe we have
100 years to effect climate change and believe 20 years is the
appropriate time frame to use as a GWP for methane.

Because of your cap and trade system we destroyed 440 million cubic
feet of methane with the approximate effect of taking at least
120,000 hydrocarbon fueled passenger vehicles off the highway. 

Sincerely Tom Vessels