Shale Gas Well Pad Air Quality Permitting in Ohio and West Virginia

Air permit application requirements and the resultant operating permit conditions for shale gas well pad production facilities differ from state to state. The lack of standardized permitting requirements and inconsistent permit conditions obliges applicants to evaluate and apply differing strategies from state to state to obtain approvals to install and operate the same equipment. Recent shale gas air permitting experiences in West Virginia and Ohio illustrate the different approaches between the Ohio Environmental Protection Agency and the West Virginia Department of Environmental Protection. The unique characteristics of gas production decline curves and their impacts on the potential-to-emit of proposed operations present unique challenges. Differences in permit application requirements and the resulting operating permits in Ohio and West Virginia are highlighted and discussed.