American Oil and Gas Reporter - April 2015 - 21

IndustryDigest
Pennsylvania's Future v. Ultra
Resources Inc. potentially holds
national significance in that it runs
contrary to the U.S. Environmental
Protection Agency's position on
aggregation, assesses the Pennsylvania
Independent Oil & Gas Association.
Under the federal Clean Air Act and
the Pennsylvania Department of
Environmental Protection's new source
review rules, PIOGA says a facility that
potentially can emit more than 100 tons
per year of a pollutant is classified as a
major emitting source and must undergo
more stringent permitting. It says each
of Ultra's compressor stations received
authorization to use DEP's General Plan
Approval/General Operating Permit
known as GP-5. However, Citizens for
Pennsylvania's Future filed suit in
2011, arguing that Ultra's compressors
should have been aggregated and
permitted as a single major source of
nitrogen oxide.
PIOGA points out that aggregation
requires meeting a three-pronged test:
whether the pollution sources are within
the same industry, whether facilities are
located on one or more adjacent or
contiguous properties, and whether they
are under control of the same entity.
DEP generally considers facilities
adjacent when they are within a quartermile of one another, but the EPA has
interpreted adjacent or contiguous
property to include a test of whether
there is a functional interrelationship
between the sources, PIOGA explains.
In its 2012 decision in Summit
Petroleum Corp. v. U.S. EPA, the U.S.
Court of Appeals for the 6th Circuit
ruled against the EPA's approach, but
the agency has contended the decision
applies only to facilities within the
region covered by the 6th Circuit
(AOGR, February 2013, pg. 26).
In Citizens for Pennsylvania's
Future, PIOGA says Judge Robert D.
Mariani agreed with the 6th Circuit that
"the plain meaning of 'contiguous' and
'adjacent' should control a
determination of whether two or more
facilities should be aggregated."
"Because a number of separate and
unconnected parcels of land on which
the compressors are located would have
to be aggregated in order for the (NOx)
emissions to reach the level of a 'major'
source, and some of these properties are
separated by several miles, the
properties at issue cannot reasonably be

considered . . . to be 'adjacent,'"
PIOGA says Mariani wrote.
The judge also said functional
interrelatedness could be considered for
aggregation, but in the Ultra case, the
compressors fed into the same metering
station but otherwise were not
connected by a common pipeline
system, the association points out. Ì
See Related Story Page 35

County Judge Upholds
Authority Of Ohio DNR
Over City's Drilling Ban

COLUMBUS, OH.-The Ohio
Supreme Court's 4-3 decision in
Morrison v. Beck Energy Corp. is being
used to guide other lower court rulings
in cases involving municipalities

APRIL 2015 21



American Oil and Gas Reporter - April 2015

Table of Contents for the Digital Edition of American Oil and Gas Reporter - April 2015

Contents
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American Oil and Gas Reporter - April 2015 - Cover3
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