Comments to SRBC re: Low Flow Protection Policy

May 16, 2012 – Coalition Comment Letter to the SRBC

Yesterday we submitted this letter on behalf of our members and several partner organizations to the Susquehanna River Basin Commission (SRBC). The SRBC recently revised its existing Low Flow Protection Policy  (LFPP), one program that the agency uses to assess the potential impact of water withdrawals on water resources. While the LFPP covers all withdrawals subject to the Commission’s authority it has direct significance to shale gas development, an industrial practice that requires millions of gallons of freshwater for each “frack” of a well.

Our comments pointed out both the Policy’s improvements – recognizing the need to protect exceptional value and high quality waters – as well as its shortcomings – its inability to assess and protect water resources from cumulative impacts. That is, the LFPP fails to assess and halt impacts that are individually minor and/or occur over time, but that collectively pose significant adverse impacts for water resources. The Commission needs to recognize that widespread industrial development – such as that seen in shale gas – has widespread and as yet, unstudied, impacts for the Basin on the whole, and accordingly ensure its regulatory mechanisms address these types of cumulative impacts. We hope that the Commission takes heed of our concerns and, looking forward, amends its Policy to best protect the Susquehanna’s vital waterways.