# MARCELLUS

SHALE COALITION

### June 16, 2014

Re: Comments on EPA White Paper for Oil and Natural Gas Sector Hydraulically Fractured Oil Well Completions and Associated Gas during Ongoing Production


### To whom it may concern,
The Marcellus Shale Coalition (MSC), a regional trade association with a national membership, appreciates the opportunity to comment on the U.S. Environmental Protection Agency (EPA) White Paper for the Oil and Gas Sector Hydraulically Fractured Oil Well Completions and Associated Gas during Ongoing Production.

The MSC was formed in 2008 and is currently comprised of approximately 300 producing and supply chain members who are fully committed to working with local, county, state and federal government officials and regulators to facilitate the development of the natural gas resources in the Marcellus, Utica and related geological formations. Our members represent many of the largest and most active companies in natural gas production, gathering and transmission in the country, as well as the suppliers, consultants and contractors who serve the industry. MSC member companies have a steadfast commitment to strengthen communities by making our region a better place to live, work and raise our families — for our generation and for future generations. Our members have a strong and unwavering commitment to the safety of our employees, contractors and communities. More information about our organization can be found at http://marcelluscoalition.org

. As background, the Marcellus Shale Formation is the most prolific natural gas production basin in the U.S., generating approximately 14 billion cubic feet per day and contributing more than 20% of daily U.S. supply. The Marcellus is making a significant contribution to energy security, while generating sustainable economic and environmental benefits for the nation. According to a recent economic analysis, the natural gas industry invested more than $12 billion in Pennsylvania in 2011 while supporting more than 230,000 new hires in the region. Domestically produced natural gas has provided a clean-burning energy resource for power generation that is contributing to air quality improvements in the U.S. According to the U.S. Energy Information Administration, nationwide energy-related carbon dioxide emissions dropped 3.8% in 2012 versus 2011. In addition, the U.S. Environmental Protection Agency has determined that carbon dioxide emissions from power plants decreased 10% in 2012 versus 2010. Both of these emission reductions were attributed, in large part, to the increased use of natural gas.

24 Summit Park Drive • 2" Fl • Pittsburgh PA 15275 I P 412.706.5160 I F 412.706.5170 I www.marcelluscoalition.orgPage 2

In addition to the specific comments below, the MSC also wishes to take this opportunity to voice our support for all comments submitted by the American Petroleum Institute (API), Western Energy Alliance (WEA), and the Interstate Natural Gas Association of America (INGAA).

1.) The MSC would like to clearly point out that during flowback gas is only vented long enough (typically less than a day, not 3 to 7 days as indicated in the white paper) to develop flow at the necessary pressure to be routed to a test or production separator. After the separator the gas is either combusted or delivered to the sales line. Gas is not vented during the entire flowback period. 2.) It is not very clear to the reader that the emissions are represented as potential uncontrolled emissions. The emissions estimates in this paper do not represent actual emissions and this distinction needs to be more apparent. 3.) By using uncontrolled emission numbers and over estimating the venting duration, the VOC and Methane emissions are greatly overstated. Subsequently, these numbers lead to an incorrect cost/benefit analysis as they indicate a greater economic benefit than is actually present. 4.) The MSC believes the white paper does an inadequate job of detailing and representing current industry practices used in controlling emissions from venting. 5.) It appears that many operators have voluntarily reported completion emissions from oil producing formation in the GHGRP. This data should be considered and incorporated into any analysis performed by EPA on this topic. It is the most recent and most accurate data available. The data in the GHGRP for 2011 and 2012 indicates 1,004 oil well completions were reported with 64% using some sort of REC's. The emissions from these reports are substantially lower than what was used for purposes of this white paper. 6.) The MSC would like to identify delays in Federal permitting as a major impediment to infrastructure construction and, subsequently increasing the amount of emissions vented rather than sold.
MSC is concerned that the compressed time schedule for EPA to develop additional requirements for the Oil and Gas Industry will not include recent study data or recent regulatory requirements in its evaluation of any new regulations. There are numerous studies currently underway evaluating methane sources and regional methane emissions across the country, which should be reviewed and considered. MSC member companies are voluntarily participating in several of these studies because the resulting information is valuable.
In addition, MSC is unsure whether the recent emission reduction requirements for the Oil and Gas Industry in Pennsylvania can be evaluated under this schedule. These requirements include NSPS 0000, Peimsylvania Department of Environmental Protection's General Permit 5



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### (GP5) and Pennsylvania's Exemption #38 for wellpads. MSC believes this information should be considered as additional requirements are considered for the industry.
MSC appreciates the opportunity to comment on the white paper and looks forward to further opportunities to work with EPA to develop regulations and guidelines that are economically and environmentally sound. If you have any questions, please do not hesitate to contact the undersigned.
Yptcs truly,

David Spigelmyer President



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SHALE COALITIONT"

### MARCELLUS 11111 SHALE COALITIONT"