First Name | Ben |
---|---|
Last Name | Apple |
Email Address | ben.apple@envcomcorp.com |
Affiliation | Environmental Commodities Corporation |
Subject | Comment in Support of MMC Protocol |
Comment | I commend the ARB staff for producing a well-designed and effective MMC protocol. The quality and relevance of the work indicates that the staff successfully learned critical intricacies of mining operations and understands the economics of the industry to ensure incentives created by the Protocol are fairly applied and distributed. This MMC protocol will enable and encourage mines to voluntarily reduce GHG emissions that would otherwise be vented, a requirement by law to ensure miner safety, to the atmosphere. Mitigating these emissions is expensive and would not be achieved without financial compensation. The “Mine Methane Capture Protocol and Mining Economics” analysis is very conservative and yet still demonstrates that MMC projects will not impact the financial standing of coal mines. It will not encourage development of new mines, nor will it prolong the life of operating mines. Coal mining will continue as it did before the MMC protocol, however mines that would otherwise vent methane will now have a means to recover some of the costs of reducing their GHG emissions. MMC projects require large capital expenditures that are difficult to securitize and are risky, both operationally and economically. Recognizing the full crediting period of a project is necessary to attract investments and achieve the goals of the Program. Project developers recognize the value of energy in mine methane and endeavor to utilize this resource where possible. Unfortunately, the extreme terrain and remote and often isolated locations of many mines prohibit the utilization of this energy. Recognizing flares as qualifying destruction devices is essential to maximize GHG emission reductions driven by this protocol as the alternative would be to vent this gas. |
Attachment | |
Original File Name | |
Date and Time Comment Was Submitted | 2014-04-04 12:07:38 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.