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Comment 5 for Next Steps for the Post-2020 Cap-and-Trade Regulation (ctoct122017wkshp-ws) - 1st Workshop.
First Name: Thomas
Last Name: Vessels
Email Address: tvessels@vesselscoalgas.com
Affiliation:
Subject: Comments on Cap and Trade system amendments
Comment:
I thank the California Air Resources Board for the hard work and example they have shown the rest of the world for the last many decades. My remarks regarding the changes to the cap and trade system are oriented towards what in my view is best for the environment we all depend on as well as being politically sustainable. The atmospherhic scientific community has made it clear that methane is the most important emission to reduce. I recommend ARB concentrate how to reduce methane emissions whether or not they are anthropogenic. The current offset protocols only include certain methane emissions. That is leaving others to emit. For example, there is no protocol for capturing methane along outcrops where methane naturally emits. Many mines that once emitted methane and injected the methane into pipelines are not doing so now if they have gone out of business, or the natural gas price is so low there is no reason to inject the methane into pipelines. If it is too difficult to amend the current protocols to provide for capture of this methane perhaps the LCFS standard could be amended to include electricity generated from waste methane. There is currently no economic benefit to take waste methane and generate electricity with it or inject it into a pipeline with such low natural gas prices and electricity prices. Regarding all GHG reducgion protocols invalidation should be related only to the project implementation of the protocols. To allow a violation of some other regulation unrelated to the emission reduction under ARB provides for 2 enforcement actions related to some event that had nothing to do with reducing green house gas. The enforcement action by ARB is more likely to have the potential to take the project out of operation and thus allow emissions to resume.
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Date and Time Comment Was Submitted: 2017-10-27 09:12:17
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