First and foremost, Virginia specific emissions data needs to be gathered and evaluated before proceeding with the generation of regulations.  Proceeding without this information by utilizing national data or data from other states will generate regulations that do not meet the Virginia specific needs criteria as specified in the NOIRA, and, most likely, be ineffective and overly burdensome.

As the regulatory process proceeds, existing, pro-active industry efforts on emissions reduction need to be recognized and expanded upon.  Encouraging innovation will achieve far more than simply maintaining compliance.   To achieve this, upstream, midstream and downstream industry representatives should be included on a regulatory advisory panel.

Additionally, one size fits all regulation needs to be avoided.  The upstream, midstream, and downstream segments of the industry are each unique, and, to achieve effective regulation, each should be addressed separately.

Finally, the benefits of any regulation needs to be weighed against its financial impact to Virginia’s consumers and industry.  Additionally, proposed regulation should be crafted to promote innovation by rewarding compliance with off-ramps reducing regulatory burdens for facilities that meet or exceed standards.  Virginia is best served by focusing efforts where the greatest benefits can be achieved and expending resources where minimal, if any, emissions potentially exist would be counterproductive and costly.