The proposed methodology will create a market incentive that encourages the removal of U.S. thermal coal from the global commodities marketplace. This proposed project activity is the first such coal incentive, and the advantages of this methodology are numerous. The following are five key methodology
attributes:
• The coal is owned by entities and individuals in the U.S. other than the U.S. Government. The nonfederally
owned minerals not only allow for quick action but also provide accountability and
enforceability.
• The methodology is scalable, with the ability to remove significant amounts of thermal coal in an
expedient timeframe as the U.S. has the world’s largest coal reserves, of which nearly 67% are owned
by individuals, corporations, and others outside the U.S. Government.
• Institutional risks are minimized, as the coal volume calculations follow the U.S. Securities Exchange
Commission reporting guidelines for public entities.
• Reducing risks further, the base datasets in calculating the GHG emission mitigations, leakage, and
functional equivalence all originate from well-respected third-party sources (e.g., Energy Information
Agency (“EIA”), The Intergovernmental Panel on Climate Change (“IPCC”), and others) and
International Monetary Fund (IMF).
• Publicizing the successful execution of coal removal projects at scale using this methodology will have a future negative economic impact on those who are currently dependent on and/or plan to be dependent on inexpensive, high-quality coal availability.
As this methodology is implemented at scale, the negative economics will lead to shifts in strategic direction
away from long-term thermal coal usage.