Comment Log Display

Biothermica would first like to thank the California Air Resources
Board (ARB) for the opportunity to provide comments in the context
of the offsets workshop held in Sacramento on March 28, 2013. 

Our comments are provided from the perspective of a coal mine
ventilation air methane (VAM) carbon project developer and
technology owner, having developed and implemented the first VAM
destruction project at an active coal mine in America. This project
is currently registered with the Climate Action Reserve (CAR), and
follows the guidance of CAR’s Coal Mine Methane (CMM) Project
Protocol. 

Biothermica strongly supports ARB in its efforts to bridge the
expected gap between the supply and demand for high quality and
additional offsets over the cap and trade program’s compliance
periods. We do believe that CMM offsets can significantly
contribute to these efforts and help maintain the cost of
compliance at a reasonable level for covered entities.

Based on our expertise in this field, we remain fully available to
share our experience with ARB and ensure that the CMM Protocol is
in accordance with the reality experienced by CMM project
developers.

We have also acknowledged the planned adoption schedule, which
mentions Board consideration in Fall 2013 and a Protocol effective
date in Spring 2014. While we understand and respect ARB’s
administrative constraints, we do wish to underline the importance
of not delaying this schedule in order to ensure CMM projects will
be able to deliver offsets in time for the second compliance
period.

Indeed, in order to fully move forward with these projects,
developers and investors need framework certainty, which will only
be achieved following the final adoption of the CMM Protocol by
ARB. Following this adoption, several activities must take place
before new CMM projects can ultimately start supplying offsets to
the system. These activities, typically spread out over fifteen
months, include construction, commissioning, monitoring,
verification and final offset issuance by ARB. 

In this context, we also strongly support ARB with regard to the
recognition of rigorous early action programs such as CAR and the
Verified Carbon Standard (VCS). This will indeed provide covered
entities with a quicker access to high quality offsets generated
under these programs.
 
Sincerely,

Raphaël Bruneau
Director – Carbon Markets
Biothermica Technologies Inc.