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Comment 7 for Informal public comments on the proposed draft 15-day changes to the Cap-and-Trade Regulation (discussion-draft-ws) - 1st Workshop.
First Name: Laurie Williams
Last Name: Allan Zabel
Email Address: williams.zabel@gmail.com
Affiliation: Volunteer Citizens Climate Lobby
Subject: Draft Coal Mine Methane Protocol
Comment:
The January 31, 2014 Draft Coal Mine Methane Protocol released by the California Air Resources Board (CARB) does not comply with AB 32 Section 38562(d)(2) because it fails to reliably exclude non-additional offsets. Specifically, United States EPA has found that approximately 23 million metric tons CO2e of Coal Mine Methane was captured for a variety of uses in the United States in 2010, and the protocol does not describe how to reliably exclude this profitable practice. See attached EPA PowerPoint pdf at p. 28. Further as noted by the Stanford Law School comments, issuance of the protocol will have the "perverse effect" of increasing resistance to appropriate regulation of coal mine methane as coal mine owners and operators seek to hang onto the profits from the offset credits associated with the protocol. Finally, we request that when the protocol is issued for a final public comment period that all information relied upon and considered for issuing the protocol be made available online so that the public can see the documentation that was considered by CARB in considering and potentially approving the protocol. We also request that all documents at the following web addresses be added to the Administrative Record for any coal mine methane protocol considered and/or adopted by CARB: U.S. EPA Coal Mine Methane Conference 2012: http://www.epa.gov/cmop/conf/cmm_conference_sept12.html U.S. EPA Coal Mine Methane Outreach Program (all pages): http://www.epa.gov/cmop/index.html Climate Action Reserve Coal Mine Methane (all pages): http://www.climateactionreserve.org/how/protocols/coal-mine-methane/ Thank you for your consideration. Laurie Williams and Allan Zabel williams.zabel@gmail.com Volunteers for Citizens Climate Lobby Oakland, CA
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Date and Time Comment Was Submitted: 2014-02-14 08:35:06
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