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I wish to add a short supplemental comment to my previous comments
about the Rice Cultivation (Cap and Trade-related)
protocol. 

Philip Swanson, who is associated with a UN-led industry
partnership, is reported to have asserted that the GWP of Methane
is 84 -- which is the 2013 IPCC (5th) methane GWP for the 20 year
interval, without feedbacks incorporated. If someone associated
with a UN-led industry partnership is using a methane GWP of 84,
then so should the CARB with regard to the rice cultivation
protocol and all other protocols (both presently approved and to be
considered in the future) that relate to methane.

Sincerely, Todd Shuman, Camarillo, CA 


http://www.watoday.com.au/environment/climate-change/methane-emissions-raise-doubts-about-gas-industrys-climate-advantage-20150603-ghg9qu.html
 by Tara Patel, June 4, 2015


Methane emissions raise doubts about gas industry's climate
advantage 

Philip Swanson, administrator of a United Nations-led industry
partnership aimed at curbing leakage of the primary component of
natural gas, presented at the World Gas Conference in Paris.
[In][h]is presentation at the World Gas Conference in Paris on
Tuesday. . . . He stated "This is a reputational issue for the
industry," Swanson said. Methane is 84 times more potent than
carbon dioxide, another greenhouse gas, and yet data on emissions
during production and transport of natural gas "are still patchy."