Good morning. My name is Mike Moore, and I am the Executive Director of the Waste Gas Capture Initiative. First, I want to say thank you to the Treasury and the IRS for holding these important hearings this week on the future of IRA implementation. I appreciate the opportunity to share my views, and the views of the Waste Gas Capture Initiative.
The WGCI is a diverse group of leading American energy industry partners, NGOs, and experts who are committed to recognizing the economic benefits and environmental impact of a strong mine methane capture industry, especially for local communities. The WGCI is dedicated to expanding fugitive methane capture practices to realize the economic and environmental benefits of this often-wasted resource. We are grateful to the Treasury for its commitment to exploring additional pathways for electric generation, especially the capture and utilization of fugitive methane, such as coal mine methane.
Coal mine methane, or CMM is waste methane that must be released for mine safety, and it is responsible for 8-10% of all U.S. methane emissions. CMM is distinct from coalbed methane and CMM emissions are not regulated by any current framework. That is why the WGCI encourages the Treasury today to consider the policy implementation factors that are necessary to ensure the successful inclusion of mine methane under the Inflation Reduction Act.
First, the WGCI requests that the Treasury accept Argonne National Laboratory’s GREET R&D model as the sole life cycle analysis tool accepted under the program. The Treasury should include the CMM and Waste Gas Utilization pathway recognized by the R&D GREET Model and incorporate the R&D GREET Model’s methodology for measuring lifecycle GHG emissions, including methane emissions avoidance accounting and blending. This approach aligns with the broader vision of an energy economy that is both economically viable and environmentally responsible. Without the incorporation of the GREET R&D mode, the proposed regulations stand in opposition to U.S. federal methane reduction pledges.
In addition, the first productive use requirement, if implemented as drafted, is overly burdensome and will unnecessarily restrict opportunities to decarbonize electric generation as well as curtail methane abatement at scale. The WGCI strongly opposes this measure in the form proposed. Many legacy capture operations have terminated productive use due to economic conditions and would not be afforded the opportunity to re-deploy capture systems if strictly implemented.
Any CMM project that achieves meaningful methane abatement is necessarily expansive and spans multiple point source boreholes for methane capture. Capturing new CMM source boreholes for beneficial use is an incremental, discrete investment decision that is unjustified economically today since the capture and collection infrastructure for each borehole requires significant investment and ongoing operational expenditures.
The WGCI also respectfully requests that the finalized regulations recognize the important benefits of feedstock blend averaging across an electric facility to drive meaningful CMM capture for power generation. The current regulations as drafted have been insufficient to promote beneficial CMM capture due to the high cost of CMM capture and the need to leverage blending into traditional gas infrastructure to transport fuel to market. Blending of multiple feedstocks as it applies to CMM is essential in order to enable scaling and decarbonization.
Furthermore, when adopting reasonable waste production anti-abuse rules to mitigate waste causality, the IRS and the Treasury should not “freeze” CMM waste streams that existed on or before the enactment of the IRA as reported to the Greenhouse Gas Reporting Program. If adopted as previously proposed, the overly restrictive provisions would disqualify the currently highest polluting mines and best candidates for new CMM capture projects as the most prolific sources of CMM pollution have been installed after 2023. This would actively discourage the highest polluting mines from engaging in CMM capture.
You will likely hear concerns in other testimony about industry’s ability to effectively deploy fugitive methane capture technology and to track emissions. Allow me to take this opportunity to dispel those concerns.
Local communities near active or inactive mining areas bear the brunt of the environmental impacts from emissions. For this reason, investing in fugitive methane capture projects in these communities is essential. Excluding fugitive methane sources from both active and abandoned mines will only continue to harm the areas most affected by point-source methane pollution. The inclusion of mine methane capture in the proposed regulations aligns with broader goals to achieve significant emissions reductions.
Fugitive methane capture and potential electric generation applications can drive economic growth and create thousands of good-paying jobs, especially in regions that have faced economic decline due to the clean energy transition. By supporting the development of robust fugitive methane capture and clean electric generation industries in the U.S., we can foster innovation and job creation, propelling the nation toward a sustainable, low-carbon future. Encouraging and incentivizing the capture and beneficial use of mine methane can create much-needed jobs and expand economic activity, particularly in some of the most socioeconomically challenged communities in the U.S.
These programs will benefit communities in Appalachia, the South, and the rural American West who need it most. Recent analysis highlights the potential in West Virginia, the top state for CMM emissions by volume. Their estimates indicate that capturing coal mine methane could reduce emissions by 236 million metric tons of carbon dioxide equivalent over a 20-year period. This effort would create more than 1,400 jobs and contribute $2.7 billion to West Virginia’s GDP supporting a state and region that has long relied on the energy industry to support its economy.
In closing, we appreciate the opportunity to contribute to the development of regulations that will shape the future of electric generation and methane emissions reduction in the United States.
The industry is prepared to advance this effort. This is about remediation of a coal industry that is required to vent methane for safety of its workers. However, failing to capture this methane at the source risks the more challenging and expensive task of capturing methane directly from the atmosphere in the future. We should work to capture the methane emitted from coal mines now, before it becomes necessary to capture it from the atmosphere—a process estimated to be ten times as expensive.
We look forward to continued partnership and dialogue to ensure the final rules capture the full spectrum of environmental and economic benefits associated with fugitive methane capture and utilization while advancing the electric generation landscape and cleaning our power grid.
Thank you.