In May 2005, a group of petitioners led by the Northern Plains Resource Council (NPRC) submitted a petition to revise water quality requirements to the Montana Board of Environmental Review (BER). Under Montana law, the BER had to consider the petition and either reject it or propose it as a new regulation. In September 2005, the BER announced proposed changes to the Montana water quality regulations. The proposal, which included almost the exact language found in the petition, was directed toward discharges of water from coal bed natural gas (CBNG) production. The key elements of the proposal included: (1) No discharges of CBNG water are allowed to Montana surface waters unless operators can demonstrate that injection to aquifers with the potential for later recovery of the water is not feasible. (2) When operators can demonstrate the injection is not feasible, the CBNG water to be discharged must meet very strict technology-based limits for multiple parameters. (3) The Montana water quality standards for the sodium adsorption ratio (SAR) and electrical conductivity (EC) would be evaluated using the 7Q10 flow (lowest 7-consecutive-day flow in a 10-year period) rather than a monthly flow that is currently used. (4) SAR and EC would be reclassified as ''harmful parameters'', thereby greatly restricting the ability for CBNG discharges to be allowed under Montana's nondegradation regulations. The proposed regulations, if adopted in their current form, are likely to substantially reduce the amount of CBNG production in Montana. The impact also extends to Wyoming CBNG production through much greater restrictions on water quality that must be met at the interstate border.