Comment Log Display

http://www.arb.ca.gov/lispub/comm2/bcproc.php
Our attachment seems to have been excluded from our prior
submission of our comment.  As we are having difficulty attaching a
document to our comment, please find the document we would like you
to consider at p. 28 here (EPA website):
http://www.epa.gov/cmop/docs/cmm_conference_sep12/01_Somers.pdf

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

Thank you for your consideration.
Laurie Williams & Allan Zabel
williams.zabel@gmail.com
Volunteers Citizens Climate Lobby
Oakland, CA