*A-,MARCELLUS 

SHALE COALITION'S 

June 16, 2014 

Re: Comments on EPA White Paper for Oil and Natural Gas Sector Liquids Unloading 

Processes 

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) Oil 

and Gas Sector Liquids Unloading Processes. 

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 412.705.5160 F 412.706.5170 I www.marcelluscoalition.org 
L e 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.) Plunger lifts do increase the efficiency of liquids unloading, but do not necessarily 

eliminate the need for venting. In fact, venting may be used in conjunction with plunger 

lifts to reduce backpressure at the surface. 

2.) Swabbing is used when the well will not respond to other techniques. It is not frequently 

used due to cost and increased venting. 

3.) The data from the GHGRP for 2012 indicates that a very small percentage of producers 

account for the vast majority of venting emissions associated with liquids unloading. This 

might indicate a more concentrated and targeted approach addressing those few high 

emitters, rather than a one-size-fits-all approach that would punish operators that are 

currently incorporating sound and effective practices. 

4.) Once a well declines to the point that the reservoir energy will not remove liquids on its 

own, artificial lift must be applied to continue producing a well. Once installed, venting 

is no longer beneficial and will not occur. These systems are cost prohibitive on lowproducing wells and have many other limiting factors. 

5.) There is no "magic bullet" for liquids unloading. Every well is unique and will likely 

require a variety of techniques throughout its operating life. Operators must have the 

flexibility to employ the most effective technique as warranted by the well conditions. 

Once the well stops producing to the point it can no longer support the cost to remove the 

liquids, it has reached the end of its economic life and is properly plugged and 

abandoned. 

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, Pennsylvania Department of Environmental Protection's General Permit 5 

(GP5) and Pennsylvania's Exemption #38 for wellpads. MSC believes this information should 

be considered as additional requirements are considered for the industry. 

4 MARCELLUS 

SHALE COALITION" 
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. 

Yot struly, 

_ 

D avid Spigelmyer 

President 

MARCELLUS 

'SHALE COALITION" 
MARCELLUS 

Nib SHALE COALITION' 

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