Recently, at a public U.S. Environmental Protection Agency hearing, Marcellus Shale Coalition (MSC) president and executive director Kathryn Klaber underscored the fact that "clean-burning natural gas has undeniable air quality benefits."

Klaber strongly recommended a 60-day extension for a rulemaking comment period on new regulations, given the host of proposed air regulations related to domestic oil and natural gas development, and expressed hope that regulators will join industry in recognizing the tremendous air quality benefits of natural gas.

The Marcellus Shale Coalition is a multistate association, formed in 2008, and is comprised of nearly 250 exploration and production, midstream and supply-chain member companies.

According to Klaber, "There are several examples in the Regulatory Impact Analysis in which EPA bases cost per ton reduction on gas with an inflated volatile organic compound weight percentage. For example, the northern Marcellus play in Pennsylvania contains dry gas, which would dramatically increase the cost per ton reduction when evaluating the feasibility of reduced emissions completions, vapor recovery units, flares, optical imaging leak detection and repair programs, as well as others. The EPA should reconsider and provide for exemptions or other reasonable provisions for activities associated with dry gas plays."

Also, she noted that a proposed rule calls for a New Source Performance Standards compliance date immediately upon publication of the final rule in the Federal Register. The coalition proposes EPA implement a reasonable phase-in period for any regulations that may create delays in delivering gas to market and disrupt energy supplies.

"Considering the myriad of regulation changes and additions proposed with this rulemaking; sufficient equipment, manpower and contractors likely will not be available to handle the inevitable rush," she said. "In addition, the MSC strongly suggests EPA reconsider its retroactive NSPS effective date of August 23. Delaying the effective date will help provide the time necessary to develop effective compliance programs and secure the equipment and manpower necessary to meet the requirements of the rules."

Also, the rulemaking proposes modifications to existing New Source Performance Standards, as well as the introduction of a new standard, and changes to two separate National Emission Standards for Hazardous Air Pollutants subparts.

"A 60-day comment period would barely be a sufficient comment period for a single proposed rule, much less a reasonable length of time to comment on the five included in this rulemaking," she said. "We strongly recommend a 60- day extension."

According to the coalition, the compliance costs associated with the proposed rulemaking clearly would "place a severe burden on all operators," particularly those with limited manpower, equipment and resources. Klaber encouraged the EPA to reconsider the financial impacts with "a more realistic approach" relying on the extensive amount of supporting data from industry experts that will follow in the written comments.

"Just as importantly, it is my hope that members of this panel will join me and my Marcellus Shale Coalition partners in recognizing the tremendous air quality benefits of natural gas—benefits that must be taken into account as rulemaking progresses on this issue," she said.