To Whom It May Concern:
Anew Climate, LLC (“Anew”) was formed through the merger of Element Markets and Bluesource in February 2022. Anew is one of the largest climate solutions providers in North America and, through its legacy companies, has a successful track record over the past two decades in developing and marketing carbon credits, renewable natural gas, low carbon fuels, electric vehicle credits, emissions credits, and renewable energy credits, in both compliance and voluntary markets, and in supporting client companies in quantifying and reporting on their greenhouse gas (“GHG”) inventories and developing corporate climate strategies and targets.
Anew applauds the Virginia Department of Energy for evaluating policy options to encourage the capture and beneficial use of Coal Mine Methane (CMM). We appreciate the opportunity to submit the following comments:
A well-designed Virginia policy program could significantly reduce the amount of methane that is vented into the atmosphere. This would:
CMM is defined as voluntarily captured methane that is liberated from coal mines. Methane is released before, during and after coal mining activities take place; in active, closed, as well as abandoned mines. For safety reasons, federal laws require mine operators to actively vent methane at underground mining sites to assure that concentrations of this explosive gas do not reach harmful levels. Even after active mining has ceased, waste methane may continue to seep for many years. Under current federal regulations, waste methane from mining activities may be released into the atmosphere unmitigated. This methane is a greenhouse gas that is more than 28 times more potent than carbon dioxide on a mass basis over a 100-year period. According to the US EPA, methane emissions from coal mining and abandoned coal mines accounted for 8% of total US methane emissions in 2019, making it the fifth largest source of this powerful greenhouse gas.[1] According to the U.S. EPA’s GHG Inventory, about 41.5 million tons of GHG emissions (CO2e) could have been avoided in 2021 through CMM capture from underground coal mines[2].
Importantly, the majority of CMM potential is in Justice40 areas covering large segments of Virgina, West Virgina, and Kentucky [5]. There are significant socioeconomic benefits associated with the development of CMM as it creates jobs in communities that are hit hardest by the energy transition.[6]
The following state, voluntary, and federal programs and initiatives are focused on creating avenues for beneficial use of CMM as a low carbon fuel resource. While these pioneering programs create a welcome recognition of the benefits of waste gas capture, we highlight that most place restrictions either on the qualifying end use or sourcing (e.g. from abandoned mines only) of CMM, so no comprehensive framework for driving beneficial use of CMM in the US exists today:
Programs targeted at supporting the beneficial use of CMM through gas capture, upgrade, and pipeline injection are an essential component of reducing emissions associated with necessary mine safety precautions. Beneficial use of CMM – alongside its GHG impact and social, economic benefits – is a powerful tool for the remediation of coal mines. By incentivizing the capture and use of CMM, state and local governments and communities will reduce costs and impacts associated with environmental mitigation from closed or abandoned mine operations, which do not cease to produce waste methane at the cessation of mining operations. If not captured and put to beneficial use, CMM would otherwise be wasted; released into the atmosphere rather than as an alternative source of methane for power generation, heating, transportation, and key energy transition fuels such as SAF, hydrogen, and ammonia. With proper programmatic support at the state level, CMM could become a driver of economic and environmental success in Virgina.
We therefore recommend that the Virginia Department of Energy design a policy that would incentivize the capture and beneficial use of CMM. As an established leader in the environmental markets with broad experience navigating different policy programs, Anew would welcome the opportunity to engage in further dialogue with the Department to support the analysis of different policy options and scenarios.
Thank you for the opportunity to provide these comments.
[1] US EPA Coalbed Methane Outreach Program: About Coal Mine Methane | US EPA
[3] U.S. Environmental Protection Agency. 2023. "Underground Coal Mines. Greenhouse Gas Reporting Program (GHGRP)." Office of Atmospheric Protection. https://enviro.epa.gov/query-builder/ghg.
[4] U.S. Energy Information Administration. 2023. "Annual Coal Report 2022." https://www.eia.gov/coal/annual/pdf/acr.pdf.
[6]Council on Environmental Quality Climate and Economic Justice Screening Tool: Explore the map - Climate & Economic Justice Screening Tool (geoplatform.gov)
[7]American Carbon Registry (ACR). Mine Methane Capture Methodology v.11 (2022)
[8] Climate Action Reserve (CAR). (2012). U.S. Coal Mine Methane Protocol https://www.climateactionreserve.org/wp-content/uploads/2009/10/CMM_Project_Protocol_V1.1_Package_031014.pdf
[9] Environmental Protection Agency (2023). Coalbed Methane Outreach Program (CMOP). https://www.epa.gov/cmop