Dear Susquehanna River Basin Commission,
The Responsible Drilling Alliance (RDA) is a grassroots organization dedicated to understanding the full ramifications of natural gas extraction. As we are headquartered in Williamsport, PA., our members have a deep affiliation and connection to the Susquehanna River and the associated subwatersheds. After careful examination of the proposed SRBC Low Flow Protection Policy, the RDA would like to submit the following comments and concerns:
1) The proposed regulations are not grounded in a comprehensive, cumulative impacts and alternatives study of the likely build-out associated with natural gas development in the entire basin. This study should be conducted prior to applying a reductionist model of regulation. Understanding cumulative impacts is critical to sound watershed management.
2) The proposed regulations do not account for the direct relationship between land cover conversion (forest loss) as a result of natural gas infrastructure and the corresponding changes in peak and base stream flows. This is a fatal flaw in the policy. By ignoring this relationship the SRBC is guaranteeing system-wide, undesirable ecological cascades to water resources. Issuing permits for withdrawals will encourage development. The development eventually changes watershed runoff and retention rates which, in turn, reduce groundwater recharge and base stream flows. Plug flow volumes will increase as a result of cover changes and stream morphology will suffer. It is not rocket science, the literature is clear.
3) While the proposed regulations try to look at monthly flow rates and attempt to classify water bodies into a few major types, this methodology grossly oversimplifies the impact analysis. The precautionary principle dictates that we should avoid perturbing the system prior to understanding the full consequences of our actions. The appropriate response from the SRBC should be to restrict withdrawal permits until a much greater, site-specific understanding is available for proposed withdrawal locations.
4) The myopic focus by the SRBC on water quantity and the concurrent failure of the Commission to examine the impact of dispersed industrialization on water quality is of deep concern to RDA members . A proper regulatory framework, one that is clearly allowed by the Basin Commission Compact, would factor both water quality and water quantity issues into any withdrawal permit decision.
In consideration of these concerns, the RDA respectfully requests the SRBC re-evaluate and strengthen the proposed recommendations in order to assure the Susquehanna River and its associated tributaries continue to provide vital water resources for current, and future, citizens of the region.
Responsible Drilling Alliance
Board of Directors