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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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