1 

Coalbed Methane Industry Detailed Questionnaire 

INSTRUCTION GUIDE 

Instructions for Completing the Questionnaire 

Please read all instructions. 

Contents: 

• Part I – EPA’s Purpose for Collecting the Data 

• Part II – Duty to Respond Within 60 Days 

• Part III – Filing for An Extension 

• Part IV – Claiming Business Information to be Confidential 

• Part V – Contacting Us 

• Part VI – Returning the Detailed Questionnaire 
2 

Part I – EPA’s Purpose for Collecting the Data 

The U.S. Environmental Protection Agency (EPA) is conducting this survey as part of its annual 

review of existing effluent guidelines, which is required by the Clean Water Act (CWA) sections 

301(d) and 304(b). As part of this review, EPA is collecting information about coalbed methane 

(CBM) extraction operations as part of its effort to determine whether to initiate a rulemaking to 

potentially revise the effluent guidelines for the Oil and Gas Extraction Point Source Category (40 

CFR Part 435) to include limits for pollutants discharged in CBM produced water. A screener 

survey was used to ensure EPA had the appropriate contact information and to provide sufficient 

information to stratify and select a sample of operators and “projects” (defined as a well, group of 

wells, lease, group of leases, or some other recognized unit that is operated as an economic unit 

when making production decisions) for the detailed questionnaire. The screener survey was 

completed in July 2009. The detailed questionnaire requests both technical and financial and 

economic data. The technical data collected will be used to determine the characteristics of CBM 

produced water, potential environmental impacts, existing management practices, beneficial use, 

and disposal practices for CBM produced water, and the related costs for this industry sector. The 

financial and economic data collected will be used to characterize the economic status of the 

industry sector and to estimate the possible economic impacts of potential technology and beneficial 

use options for CBM produced water. This instruction guide is designed to provide guidance for 

completion of the detailed questionnaire only. 

Part II – Duty to Respond Within 60 Days 

EPA is conducting this data collection under the authority of Section 308 of the CWA (Federal 

Water Pollution Control Act, 33 U.S.C. Section 1318). You must respond to this questionnaire 

within 60 days of receiving it. Failure to respond, late filing, or failure to comply with the 

instructions may result in criminal fines, civil penalties, and other sanctions, as provided by law. 

The public reporting and recordkeeping burden for this collection of information is estimated to 

average 80 hours per response. Burden means the total time, effort, or financial resources expended 

by persons and the Federal Agency to generate, maintain, retain, or disclose or provide information. 

This includes the time needed to review instructions, develop, acquire, install, and utilize 

technology and systems for the purposes of collecting, validating, and verifying information, 

processing and maintaining information, and disclosing and providing information; adjust the 

existing ways to comply with any previously applicable instructions and requirements; train 

personnel to be able to respond to a collection of information; search data sources; complete and 

review the collection of information; and transmit or otherwise disclose information. An agency 

may not conduct or sponsor, and a person is not required to respond to, a collection of information 

unless it displays a currently valid OMB control number. 

To comment on the Agency’s need for this information, the accuracy of the provided burden 

estimates, and any suggested methods for minimizing respondent burden, including the use of 

automated collection techniques, EPA has established a public docket for this ICR under Docket ID 

No. EPA-HQ-OW-2006-0771, which is available for public viewing at the Water Docket in the 

EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW, Washington, 

DC 20004. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., 
3 

Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is 

(202) 566-1744, and the telephone number for the Water Docket is (202) 566-2426. An electronic 

version of the public docket is available through the federal data management system (FDMS) at 

http://www.regulations.gov. Use FDMS to submit or view public comments, access the index listing 

of the contents of the public docket, and to access those documents in the public docket that are 

available electronically. Also, you can send comments to the Office of Information and Regulatory 

Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, 

Attention: Desk Officer for EPA. Please include the EPA Docket ID No. EPA-HQ-OW-2006-0771 

and OMB control number (2040-0279) in any correspondence. 

Part III – Filing for an Extension 

If you wish to request an extension, you must do so in writing within 30 days of receipt of this 

questionnaire. Written requests may be e-mailed to Mr. Carey Johnston at johnston.carey@epa.gov 

with “CBM Questionnaire Extension Request” in the e-mail subject line, or may be mailed to: 

United States Postal Service One- or Two-Day Delivery (e.g., FedEx)

Mr. Carey Johnston Mr. Carey Johnston 

U.S. EPA, Office of Water U.S. EPA, Office of Water 

Mail Code: 4303T Room 6231G, EPA West 

1200 Pennsylvania Avenue, N.W. 1301 Constitution Avenue, NW 

Washington, DC 20460 Washington, DC 20004 

Extension requests will be evaluated on a case-by-case basis. Submittal of an extension request to 

EPA does not alter the due date of your questionnaire unless and until EPA agrees to the extension 

and establishes a new date. 

Part IV – Claiming Business Information to be Confidential 

If no business confidentiality claim accompanies the information when it is received by EPA, 

EPA may make the information available to the public without further notice.

Regulations governing the confidentiality of business information are contained in the Code of 

Federal Regulations (CFR) at Title 40 Part 2, Subpart B. You may assert a business confidentiality 

claim covering part or all of the information you submit, other than effluent data and information or 

data that is otherwise publicly available, as described in 40 CFR 2.203(b): 

“(b) Method and time of asserting business confidentiality claim. A business which is submitting information 

to EPA may assert a business confidentiality claim covering the information by placing on (or attaching to) the 

information, at the time it is submitted to EPA, a cover sheet, stamped or typed legend, or other suitable form 

of notice complying language such as ‘trade secret,’ ‘proprietary,’ or ‘company confidential.’ Allegedly 

confidential portions of otherwise non-confidential documents should be clearly identified by the business, and 

may be submitted separately to facilitate identification and handling by EPA. If the business desires 

confidential treatment only until a certain date or until the occurrence of a certain event, the notice should so 

state.”

You may claim as confidential all information included in the response to a question by checking 

the Confidential Business Information (CBI) box next to the question number. Alternatively, all 
4 

questions marked with a CBI check box may be claimed confidential by checking the box on page 

iii of the detailed questionnaire. If you do not check this box, any individual response where 

“CBI” is NOT checked will be considered nonconfidential. Note that you may be required to justify 

any claim of confidentiality at a later time. Note also that facility effluent data are not eligible for 

confidential treatment, pursuant to Section 308(b) of the Clean Water Act, and thus will be treated 

as non-confidential even if the CBI box is checked. In addition, information that is publiclyavailable should not be claimed confidential. Note also that information claimed confidential cannot 

be accessed, verified, or used by the industry at a later date to evaluate data and analyses supporting 

the results of the CBM study. 

Information covered by a claim of confidentiality will be disclosed by EPA only to the extent of, 

and by means of, the procedures set forth in 40 CFR Part 2, Subpart B. In general, submitted 

information protected by a business confidentiality claim may be disclosed to other employees, 

officers, or authorized representatives of the United States concerned with implementing the CWA. 

Exemption 4 of the Freedom of Information Act (FOIA) protects from disclosure "trade secrets and 

commercial or financial information obtained from a person and privileged or confidential." See 5 

U.S.C. 552(b)(4). 

Information covered by a claim of confidentiality will be made available to the following EPA 

contractors and subcontractors to enable them to perform the work required by their contracts with 

EPA. 

EPA Contract No. Contractor Name(s) 

68-C-02-095 Eastern Research Group, Inc. 

EP-C-07-029 PG Environmental, LLC, Eastern Research Group, Inc. 

EP-C-05-030 Battelle 

GS-10F-0209P Advanced Resources International, Inc.

All EPA contracts provide that contractor employees use the information only for the purpose of 

performing the work required by their contracts and will not disclose any CBI to anyone other than 

EPA without prior written approval from each affected business or from EPA’s legal office. EPA 

has approved written procedures for each contractor on how they will gather, safeguard, and secure 

CBI. Any comments you may wish to make on this issue must be submitted in writing along with 

your completed survey. 

Part V – Contacting Us 

Frequently asked questions regarding the detailed questionnaire can be found on the EPA Website 

at http://www.epa.gov/guide/cbm/. 

If you would like an electronic version of the detailed questionnaire, it is available on the EPA 

Website at http://www.epa.gov/guide/cbm/. 

EPA has contracted with two private firms, PG Environmental and Eastern Research Group (ERG), 

to operate a telephone and electronic mail helpline to assist respondents with any questions or 

concerns about the detailed questionnaire. You will receive a reply within 1 business day of 

contacting the helpline. Appointments for scheduled support can also be requested over the helpline. 
5 

A conference call with ERG economic staff and PG engineering staff will be scheduled to obtain 

assistance answering questions on all parts of the survey. Requests for appointments will be handled 

within 1 week of contacting the helpline: 

CBM Helpline: 1-800-864-9230 

Internet Electronic Mailing Address: cbmdetailed@pgenv.com

Part VI – Returning the Detailed Questionnaire 

After you have completed the detailed questionnaire, please return it to: 

U.S. Environmental Protection Agency 

CBM Industry Questionnaire 

c/o PG Environmental, LLC 

570 Herndon Parkway 

Suite 500 

Herndon, VA 20170