The members of the Marcellus Shale Coalition?s (“MSC”) Air and Emissions Subcommittee listened with interest at the Committee?s meeting with representatives of the Pennsylvania Department of Environmental Protection (“PA DEP”), Bureau of Air Quality (“BAQ”) on June 22, 2010. The MSC learned that BAQ is currently engaged in the development of technical guidance to assist in the evaluation of oil and gas facilities at multiple locations for possible aggregation into single source for permitting purposes. This process is commonly referred to as “source aggregation.” Given the MSC?s keen interest in the predictable and timely permitting of its members? planned oil and gas facilities in Pennsylvania, the MSC would like to provide the BAQ with this White Paper raising a number of our concerns for your consideration in the development of such guidance. […]
