First Name | Barbara |
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Last Name | Miller |
Email Address | bara.miller@verizon.net |
Affiliation | |
Subject | Mine |
Comment | To the California Air Resources Board; Please do not proceed with the proposed Mine Methane Capture Protocol (MMCP) in California’s Global Warming Solutions Act AB32. The National Resources Defense Council has said it well: "The environmental law clinic at Stanford Law School has pointed out problems with the analysis of how much methane will be captured from abandoned mines without the protocol as well as potential conflicts with future federal regulation under the Clean Air Act. In particular, the opportunity for coal mines to be paid to reduce emissions may make it more difficult to adopt regulations that require them to reduce emissions. And the Sierra Club has raised concerns about the potential that increased revenues for coal mine owners from offset sales could increase coal production, a point that was also raised by the Stanford clinic." Adoption will help keep [Cap and Trade] allowance prices low by adding tens of millions of tons of potential emissions reductions to the carbon market. But there is no need right now for further cost containment. ARB has proposed an additional safeguard to ensure allowance prices stay within a reasonable range and recent forecasts suggest that, if anything, the concern may be in the other direction, as allowances are projected to stay near the floor price for the foreseeable future." (http://switchboard.nrdc.org/blogs/pmiller/coal_mine_methane_offsets_a_ba.html) Sincerely, Barbara Miller |
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Date and Time Comment Was Submitted | 2014-04-02 09:56:56 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.