Emily Collins Co-Presented at PBI Environmental Law Forum
On March 28, 2012, Professor Emily Collins co-presented at the PBI Environmental Law Forum on trends in how EPA and Pennsylvania have approached whether multiple sources of air emissions should be aggregated into a single source for the purpose of determining that the aggregated emissions subject the source to Title V requirements. Shale gas development companies and affected communities and environmental groups are seeking counsel on how to navigate the regulatory decision making process on aggregation of compressor stations and associated gas well pad emissions. The U.S. Environmental Protection Agency and Pennsylvania Department of Environmental Protection appear to be taking very different approaches to the decision-making process. She assessed past decisions of both agencies and analyzed potential outcomes.