JI Comments

From	John Baxter
Date	03/18/2006 06:10 PM
Subject	JI Comments
Attachments
	Page 8: Operational Lifetime of a Project: Crediting shall not extend beyond the operational lifetime of the project. Comment: Assume a closed landfill emitting methane. The methane emissions extend outward for up to 100 years. Now assume an aerobic process that "composts" the organic elements within 3 years. At the conclusion of that three (3) year period, all compostable elments have been rendered into compost. There are no methane emissions. The aerobic bioreactor is shut down because it has accomplished its goals. Under CDM rules, one would anticipate that the "project" would attract CDM credits for a 21 year period, regardless that the project systems were shut down after year three (3) Is this not the same case with a JI project? The goal of eliminating the generation of methane (for all time) is completed within a short time frame. The mechanical process can cease at that time. Are all emissions that would have occurred over the 21 years period, in the absence of the aerobioc process, now validated? John