Proposed Draft Regulations Addressing Hydraulic Fracturing and Additional Clarifying Amendments

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Comment From: Sam Bernhardt

2/21/18 @ 5:00 PM

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Comment From: Stephanie Catarino-Wissman

2/21/18 @ 5:00 PM

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Comment From: Sue Mickley

2/21/18 @ 5:00 PM

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Comment From: Tara Zrinski

2/21/18 @ 5:00 PM

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Comment From: Thomas Stinnett

2/21/18 @ 5:00 PM

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Comment From: Edith Kantrowitz

2/21/18 @ 5:00 PM

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Comment From: Faith Zerbe

2/21/18 @ 5:00 PM

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Comment From: Gail Domalakes

2/21/18 @ 5:00 PM

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Comment From: Donald Miles

2/21/18 @ 5:00 PM

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Comment From: Beth Kelley

2/21/18 @ 5:00 PM

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Comment From: Bill Shaughnessy

2/21/18 @ 5:00 PM

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Comment From: Blayne Diacont

2/21/18 @ 5:00 PM

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Comment From: Bruce Rosen

2/21/18 @ 5:00 PM

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Comment From: William Buskirk, Jr.

2/21/18 @ 5:00 PM

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Comment From: Tracy Carluccio

2/21/18 @ 5:00 PM

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Comment From: Rebecca Canright

2/21/18 @ 3:15 PM

I support achieving a complete and permanent ban on natural gas drilling and fracking and all related activities (including wastewater processing and discharges from and water withdrawals for drilling and fracking operations) throughout the Delawa...↓

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Comment From: william haegele

2/21/18 @ 11:49 AM

Why is it so hard to convince you to do the right thing regarding the Delaware river and fracking? Don't you have children? Grandchildren? It's not rocket science. Fracking destroys our environment. Do you care? It's a no brainer.

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Comment From: Arianne Elinich

2/21/18 @ 11:41 AM

MY NAME IS ARIANNE ELINICH AND I AM A RESIDENT OF BUCKS COUNTY, PA. I AM WRITING THE DRBC TO RESPECTFULLY ASK THAT YOU INSTITUTE A COMPLETE BAN ON FRACKING IN THE DELAWARE RIVER BASIN. CLIMATE CHANGE – AND THE FOSSIL FUEL INFRASTRUCTURE THAT COMP...↓

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Comment From: anne veraldi

2/21/18 @ 10:08 AM

Continue to protect the Delaware River watershed from hydraulic fracturing.

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Comment From: Kyle Ashcroft

2/21/18 @ 9:58 AM

Dear Comments, I am writing today to voice my strong opposition to the Delaware River Basin Commission's (DRBC's) proposed rules to severely restrict---and therefore effectively ban---hydraulic fracturing ("fracking") and horizontal drilling with...↓

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Comment From: Michael Lombardi

2/21/18 @ 9:40 AM

Fracking in the Delaware River is unacceptable and MUST not be permitted!

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Comment From: Lorraine and Bruce McMahon

2/21/18 @ 9:23 AM

Save the health of our water, our wildlife and our people.

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Comment From: William Bushner

2/21/18 @ 9:09 AM

Please reconsider the devastating effects that will take place within the path of this pipeline.

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Comment From: Stephen Chuckra

2/21/18 @ 8:51 AM

I oppose all fracking initiatives in the Delaware River basin due to the exceptional water quality and ecological diversity of the watershed: and the fact that millions of people rely on this water daily. The upper Delaware river is also the best qu...↓

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Comment From: Yohance Basdeo

2/21/18 @ 6:02 AM

Hydraulic-fracturing has created a way for the oil and gas companies and government to make a lot of money with a lot of different consequences to the environment. Domestic oil from natural resources is a great concept but there are many different sa...↓fety concerns. Hydraulic fracking should be banned or heavily regulated regarding the safety of the public and wildlife environments. This whole process uses millions of gallons of water per well and included with the water is a lot of different chemicals that are needed to break apart the shale. As these chemicals are blasted in the ground beneath us there is a big chance that it can contaminate the water supply for many people. The worst type of chemicals that are being used have hazards related to reproductive and developmental toxicity. Out of about 1021 chemicals used in the fracking fluid 67 different chemicals are of developmental toxicity (Elliott et al. 93). This worries me deeply because these types of chemicals can affect our children that are the future of the world and it can also affect every human being in terms of new sicknesses that may develop. Wildlife is also affected as well because we are the ones in their natural habitat, and fracking fluids after being pumped into the ground is then left as wastewater, either in brines or accidental spills and leaks that may or may not be reported. Birds fly everywhere, and it is seen that the riparian songbird in Marcellus and Fayetteville shale regions have an increase in metals which is associated to the fracking chemicals used in those areas (Latta et al. 1). Not only does fracking affect land wildlife but it also affects the aquatic wildlife. Millions of gallons of fresh water are being used for fracking for each well station. The fresh water will be taken from the Delaware basin and river flow will be affected. River flow is very important for the organism's biodiversity and the ecosystem. In an article on the effect of the water stress in Arkansas it is stated that it does have potential to affect the aquatic biodiversity but also states that in the Marcellus shale region it is more humid, and this plays a bigger role in since stream flow is considerably lower. (Entrekin et al. 1) So, it is important that regulations are in place as to when freshwater is to be used for this process. Lastly natural gas is much cleaner than coal but evidentially methane is 100 times greater to absorb heat than carbon dioxide. This methane is being leaked into the air because of the increase of hydraulic fracturing in the world. In the process of fracking an estimated 12% o total production of methane is leaked in the atmosphere (Howarth 48). This number is very large, and it is just influencing climate change which is certainly happening because of greenhouse gasses. In addition, since the fracking process requires so much water there is a lot of energy being used to transport the water to these sites, which ends up burning more fossil fuels, negatively impacting the environment. It is great that we can harvest domestic oil, but the safety of people should always come first. Regulations should be followed strictly to make sure that rules are not broken for the safety of many. There should be efforts to introduce new engineering methods that have a better use of the amount of water used, as this will impact humans, wildlife and our future generations wellbeing. Elliott, EG, et al. "A Systematic Evaluation of Chemicals in Hydraulic-Fracturing Fluids and Wastewater for Reproductive and Developmental Toxicity." Journal of Exposure Science and Environmental Epidemiology, vol. 27, no. 1, 2017, pp. 90-99. Latta, Steven C., et al. "Evidence from Two Shale Regions that a Riparian Songbird Accumulates Metals Associated with Hydraulic Fracturing." Ecosphere, vol. 6, no. 9, 2015, pp. art144-10. Entrekin, Sally, et al. "Water Stress from High-Volume Hydraulic Fracturing Potentially Threatens Aquatic Biodiversity and Ecosystem Services in Arkansas, United States" Environmental Science & Technology 2018 52 (4), 2349-2358 Howarth, Robert. (2015). Methane emissions and climatic warming risk from hydraulic fracturing and shale gas development: Implications for policy. Energy and Emission Control Technologies. 3. 45. 10.2147/EECT.S61539.

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Comment From: sharon furlong

2/21/18 @ 1:03 AM

Water is the most precious resource we have. doing anything to endanger water for anyone, people, animals, fish, plants, communities, is an abuse of the public trust. we are a free country of people, not indentured servants to corporations. we are no...↓

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Comment From: Brande Blasi

2/21/18 @ 12:14 AM

Please continue to keep the Delaware River Basin regulated so that the contaminants found in hydraulic fracking waste is not discharged to the area. Considering it is near impossible for a new Industrial facility to be able to pull water from the De...↓

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Comment From: Rev David Reppert

2/20/18 @ 12:21 PM

Fracking has contaminated water sources wherever it has been permitted. At the same time, perversely, Sunoco and other companies are given eminent domain power - supposedly because what they're doing is in the public interest! https://stateimpact.npr...↓.org/pennsylvania/ Clearly, the only interests benefiting from fracking are Sunoco and related firms. The people are losing their land, losing drinkable water, losing the beauty of the natural environment. The millions of people who rely on the Delaware River for their drinking water enjoy some of the cleanest water in the East. Jeopardizing this water by allowing wastewater to be imported, stored, or transported into the Basin is foolish and irresponsible.The DRBC itself said, "The disposal of produced water poses a significant risk to the water resources of the basin if the wastewater is not properly managed." Allowing for storage and importation poses similar risks to disposal. The entire nontidal Delaware River is protected by the Delaware River Basin Commission's Special Protection Waters regulations that do not allow water quality to be degraded. We are dependent on that protection to keep our water safe. Fracking and the discharge of wastewater produced by fracking will degrade the water quality of the river as pollutants are released. Toxic, hazardous and radioactive materials will build up over time in the water, sediments, and aquatic life and spills, leaks, and catastrophic events will add pollution, degrading water quality, habitats, and downstream water supplies. As I mentioned previously, Sunoco and related firms are allowed windfall profits while masquerading as acting in the public interest in order to use eminent domain power. In addition, the natural gas and oil industry has received unprecedented exemptions from our nation's most important environmental and public health laws, including portions of: Clean Air Act; Clean Water Act; Safe Drinking Water Act; Resource Conservation and Recovery Act, Comprehensive Environmental Response, Compensation and Liability Act (the Superfund Law); and Emergency Planning and Community Right-to-Know Act. These exemptions allow pollution to occur through loopholes and reduce the controls of how hazardous materials from fracking must be disposed of. This exposes the Delaware River Watershed to adverse impacts that would degrade water quality and contaminate water supplies of up to 17 million people. I strongly hope and pray that you will ban fracking throughout the Delaware River Basin. Thank you for your consideration.

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Comment From: James Rosenthal

2/20/18 @ 8:12 AM

Please institute a complete and permanent ban on natural gas drilling and fracking and all related activities (including wastewater processing and discharges from and water withdrawals for drilling and fracking operations)throughout the Delaw...↓

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Comment From: Daniel RUTLEDGE

2/20/18 @ 5:09 AM

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Comment From: Tyler Peek

2/20/18 @ 5:04 AM

Dear Comments, I write to oppose the Commission's proposal that effectively bans natural gas development in the Delaware River Basin region. Our nation's public policies---at all levels of government---must be based on evidence, science, and n...↓

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Comment From: Tyler Peek

2/20/18 @ 5:00 AM

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Comment From: Sharon Furlong

2/20/18 @ 4:38 AM

I am strongly opposed to opening the entire Basin area to any form of fracking activities. I believe the technology is just not there to guarantee safe construction or maintenance activities. The more than 12,000 leaks in New Mexico alone ifeom this ...↓industry over the years is incontrovertible proof that the industry cannot claim complete competency. And that the technology has advanced over the years to reduce the harm. InPennsylvania alone there have been over 500 reported incidences of leakage from these fracking and transport related activities, and that is what is "officially"reported to the state government agency. In addition, once agsin, the technology is just not there that can successfully treat or even mitigate or dilute already contaminated fracked water. In our public water treatment facilities. Really, how can even be a hint that there can be successful mitigation or treatment when over 3/4's of the chemicals are unknown and unknowable?? And the flushing out of dormant radioactive substances!?!? bucks county is known for being a radon hotspot...if there is going to be the eventual push for injection of waste waters into the earth, and we all know that is what they are looking at, especially in a quite crowded and populated Delaware River Basin area, that procedure is now known to cause earthquakes, so what is to stop injection to create opened pockets of radon that can become free to do its own Migration?? This is one nasty and shortsighted industry asking us to suspend our desire for a life that is not under constant assault from cancer causing chemicals, air pollution and water contamination. I find this morally, scientifically, politically and ethically reprehensible. It needs to be stopped. I for one am tired of living in a country that is returning to its bad old roots of exploitation , rape and pillage, and destruction for the sake of the almighty dollar....we had only begun to rein this tendency in a few short decades ago....and we are returning to it?!. Really? These people need to be stopped once and for all, all of them. And the political people who take money from 5em and support their efforts since they don't live near a pipeline or a well or a treatment facility...they need to be voted out. All of them. Please, do your job....do what you were set up to do.....stop ideas and projects like this from destroying us and the River and the environs around that river. Please please please protect this river....and us.

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Comment From: pamela campbell

2/20/18 @ 3:55 AM

To: Delaware River Basin Commission My family has lived in Northeastern Pennsylvania for the last 150 years. Years ago, they worked in the anthracite coal mines near Carbondale, Pa. I am painfully aware, of the environmental destruction wrought b...↓

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Comment From: Susan Mickley

2/20/18 @ 1:59 AM

Health and Well-ness A presentation to DRBC January 23, 2018 Susan Mickley, MPH, Yale University Freelance Consultant/Health Researcher Good afternoon and thank you for the opportunity to present to you today. My presentation will focus on th...↓e impact natural gas development has on public health. I recently conducted extensive research on the public health trends, specifically mortality rates, in the 6 highest drilled counties in Pennsylvania using horizontal hydraulic fracturing. These counties had over 7,000 wells, representing over 70% o all wells drilled in Pennsylvania during the study period. The State of Pennsylvania trends were used for baseline comparisons and differences of age distribution and economic trends were also analyzed. It is important to note that the source of all my data was the Pennsylvania Department of Health in their annual Health Data Reports released under the guidelines established by the CDC for all states that have been reported annually for several decades. Therefore, I could not manipulate the data, only report it. The reports provide historical information by county which allows for trend analysis for seven categories of health data that represent the major groupings of mortality rates due to health. These categories include: - Chronic Lower Respiratory Disease (CLRD) including Asthma - Cancer - Diseases of the Heart - Stroke - Cerebrovascular Disease - Influenza and Pneumonia - Nephritis (Kidney Disease and related diagnoses) - Septicemia (infections) - Infant Mortality Rates Using these categories to identify long-term health trends has been standard practice. As a result, there is substantial data that can be compared using data over years and even decades. These comparisons can identify significant changes and anomalies and lead the reviewer to seek causes for these anomalies. Trends can indicate causes for the diseases themselves, but are more an indicator of outcomes of treatment and access to care. Most importantly, trends can document the overall health of a population and whether it is improving or declining, particularly as it relates to longevity and survival. It is important to note that a significant period of time is needed to identify valid trends with death rates; usually a decade is the minimum time period to determine if community heath is changing. My study covered the period of 2000-2015 which allowed a comparison of pre-development years to the data reported during the development years. A brief review of demographics is in order. In the 6-county study area the total population saw minimal change with 509,985 in 2000 vs. 506,652 in 2014. However, it is important to note that the percentage of elderly increased from 16.6% t 19.1%. The state experienced a similar increase in the percent of elderly. The Per Capita Income improved at a faster pace in the 6-counties vs. the State with Greene County having a notable increase from less than $20,000 in 2000 to over $43,000 in 2014, or a 116% icrease vs. the states average increase of 62%. In 2000 all 6-counties had unemployment rates higher than the state average. By 2014, 4 of the 6 counties had unemployment rates lower than the state average with Lycoming and Tioga slightly higher than the state average. These trends show that the 6-counties experienced significant economic improvements over the study period. In reviewing the public health trends for the 6-counties over the study period and compared to the state all of the trends were favorable, especially when the increase in the elderly population is considered. The trends did not show any increase in mortality rates resulting from Marcellus shale resource development. In fact, in most cases and on average across the 6-counties, the mortality rates did not meet the expectations based on the increase in the % ederly and were stable or declined in almost all the areas. Infant mortality rates also saw significant declines in the 6-county study area and the decline surpassed the state's decline, -21% v. -14.7%. ote: A post study review of the percent of Low birth weight babies show that while the state saw an increase in % o low birth weight babies from 2000-2014, Bradford, Greene, Tioga saw declines, Susquehanna and Washington stayed the same, and Lycoming was consistent with the state. The relationship between improving economies and declining mortality rates has been recognized by epidemiologists and Public Health researchers for many decades. I quote Dr. M. Harvey Brenner (an internationally renowned public health researcher and a fellow alumni of Yale's Public Health Program), "Economic growth, cumulative over at least a decade, is the central factor in mortality rate decline..." (Source: Brenner, M.H. "Economic Growth is the Basis of Mortality Rate Decline in the 20th Century," International Journal of Epidemiology, July 2005.) You will hear many presentations that will cite a study that was published the same week as mine that concludes that fracturing of wells can lead to an increase in low birth weight babies to mothers living within 1km of the well. I caution you to not rely on this study due to the weaknesses and data manipulation the authors admit to in their study. The authors chose a distance from wells of 1km (0.6mile) even though they admit that this resulted in insufficient data to reach a reliable conclusion and the additional number of low birth weight babies was less than 30 babies over 9 years and over 7,000 wells developed. At the same time, they make a point to cite 2 other studies that used 2kms and 1 mile as distance from suspected source of traffic pollution and industrial sites to determine impact on % o low birth weights. If the authors had used either of these distance criteria they would have had statistically significant data, in fact, 4 times the number of births to draw conclusions from but their conclusion would have been the opposite. Their conclusion would have been that proximity to wells resulted in no change or even a decline in % o low birth weight babies. This conclusion would be more in line with the Pennsylvania Health Department's data that I reviewed for the 6-counties. The arbitrary use of a distance from well of 1km to force a conclusion for whatever unknown reason which points to bias was irresponsible and deceiving and a gross misjustice to decision making bodies like yourself and to the public. The study also never considers the improved survival rate of infants I noted earlier and how these surviving infants would be more likely to have a higher incidence of low birth weight. I don't know any parent or compassionate soul who would not be supportive of this improved survival even if it may result in more long-term health consequences for those babies. I ask the DRBC governing board to please consider these facts when determining whether they will ban shale resource development in the basin. Denying the economic and public health benefits to the citizens in the basin is tantamount to condemning these communities to higher mortality rates and declining economies. Basing this decision on poorly contrived studies like the Low Birth Weight one I cite in this presentation that provide false conclusions would be an injustice. My study, consistent with years of research of epidemiologist and public health experts around the world, proves that there is no rational public health reason to deny development in the basin because the benefits to public health (reductions of Mortality Rates) can be directly tied to the economic benefits realized from Marcellus Shale Resource Development.

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Comment From: terri fennimore

2/19/18 @ 11:40 PM

We cannot afford to frack in the area of the delaware river basin. Contaminates from fracking in both ground and water are a toxic time bomb for all that live in this area. Stop fracking N-O-W.

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Comment From: Joanne Wagner

2/19/18 @ 9:59 PM

I am very concerned about the Proposed Draft Regulations Addressing Hydraulic Fracturing. and the toxicity of Produced Water. The Delaware River Basin needs to be protected not ruined to support the oil and gas industry. The DRBC itself said, "T...↓

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Comment From: Kathy and Jim Grentzenberg

2/19/18 @ 1:05 PM

Man, it is certainly difficult to "keep up" with all the critical issues we face. This one hits close to home. That is the water I drink. Fracking, not only uses tremendous amounts of water, but obviously produces mass quantities of "waste water."...↓

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Comment From: Jude Montarsi

2/19/18 @ 7:37 AM

Ban the Fracking!

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Comment From: Henry Berkowitz

2/19/18 @ 6:59 AM

Please do not make decisions that make wealthy people wealthier at the cost of degrading the health of everyone else. There are so many negative consequences caused by the fracking industry and I am sure you are aware of them all. There are plenty of...↓

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Comment From: Brenda Sabistina

2/18/18 @ 11:50 PM

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Comment From: Robert Krause

2/18/18 @ 1:19 PM

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Comment From: Robert Krause

2/18/18 @ 1:18 PM

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Comment From: Robert Krause

2/18/18 @ 1:16 PM

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Comment From: Nichole Diamond

2/18/18 @ 11:21 AM

A complete and permanent ban on natural gas drilling and fracking and all related activities (including wastewater processing and discharges from and water withdrawals for drilling and fracking operations) throughout the Delaware River Watershed i...↓

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Comment From: Caroline Ashurst

2/18/18 @ 7:56 AM

To Whom It May Concern: There is a moratorium on all gas drilling, hydraulic fracturing (fracking), water withdrawals for and wastewater treatment and discharges from fracking throughout the entire Delaware River Basin today, since 2010. The mo...↓ratorium was put in place by the Delaware River Basin Commission (DRBC), the federal-interstate agency that manages the water resources of the Delaware River Watershed. The DRBC members the Governors of Pennsylvania, New York, New Jersey, and Delaware, and the federal government have the responsibility of protecting the shared waters that provide 15-17 million people in all four of the Watershed states with drinking water, including New York City and Philadelphia. There is significant evidence that natural gas development, and its related operations, which include all the phases of the hydraulic fracturing ("fracking") process, from the first stage of industrial land preparation; to the storage, handling, and use of chemicals and additives for extraction and stimulation; to drilling and fracking; to the withdrawal of and degradation of large volumes of water and its discharge and disposal as waste, has substantial adverse effects on public health, property interests, agriculture, and on our air, water, and land.4 The most recent statistical analysis of the body of scientific literature by the Concerned Health Professionals of New York and Physicians for Social Responsibility, 685 peer-reviewed papers examining gas drilling and/or hydraulic fracturing ("fracking") were reviewed and the overwhelming majority of studies found evidence of or potential adverse impacts on water, air, and human health.5 Fracking pollutes groundwater, destroying the quality of aquifers for generations to come. The chemicals in fracking fluids will migrate to drinking water aquifers and to the surface it is not a question of "if", but "when".9 Considering groundwater flow, time, and the corrosive downhole environment created by gas extraction processes, including the lack of durability of the cement sealant and steel well casings, aquifers and surface waters are not sufficiently isolated from the toxic fluids and deep geology pollutants that are distributed by drilling and fracking.10 Aquifers could be impacted quickly, such as when there is a faulty cement seal or casing during construction, or over time. But it is certain that the life of the cement and/or steel (usually 80 to 100 years or less) is less than the life of the aquifer - so even if there is no evidence in the near term, the eventual pollution likely occur in less than a century11 - ruining water sources for the generations that will follow. The potential for fracking fluids to move from the production zone of a gas well to water resources "cannot be engineered out of the process (Gassiat et al. 2013). In other words, the process of injecting fluids into and fracturing the shale causes the potential pollution problem."12 Contaminated fluids from the fracking process can move from the deep shale to water resources through various pathways including fractures and natural vertical flow, in thousands of years or in less than ten years, polluting groundwater.13 Dr. Ted Auch of Fractracker Alliance reports there has been an 8-12% icrease in lateral length of well bores each year since 2013 in the major shale gas and oil basins. This increases the amount of water used per fracked well to 9.7 mg on average. In the Marcellus Shale, horizontal well bores are increasing at 11% pr year, today reaching from a mile or two up to 4 miles. This increases the volume of water used to frack each well to between 10 and 20 million gallons. There are wells in Ohio that have used as much as 87 million gallons of water per "super lateral" well.25 The use of water for fracking is "depletive" - all of the water is lost either by being polluted or by being consumed since most of the water injected for fracking is not recovered and is not returned to the source (PADEP reports that between 8% ad 10% o Marcellus Shale frack water is returned to the surface, meaning up to 90% o the injected water stays underground.) This consumption depletes the surface waterway and/or groundwater from where it is taken. Frack wastewater contains many dangerous and toxic constituents and properties including: Total Dissolved Solids (TDS), Total Kjeldahl Nitrogen (TKN), Ammonia Nitrogen, NitrateN, Chloride, Bromide, Sodium, Sulfate, Oil and Grease, BTEX (benzene, toluene, ethylbenzene, xylene), VOC (volatile organic compounds), Naturally Occurring Radioactive Materials (NORM), Barium, and Strontium.45 Some are carcinogenic, some have known health effects, and some are toxic to aquatic life and plant life. Yale University School of Public Health, in a study of chemicals used in fracking, found that of the 119 compounds with sufficient data to classify them in terms of carcinogenicity (only 20% o chemicals in use had sufficient data a problem in itself), "44 percent of the water pollutants and 60 percent of air pollutants were either confirmed or possible carcinogens."46 55 unique compounds with carcinogenic potential could be released to both water or air and 20 chemicals had evidence of increased risk for leukemia or lymphoma specifically.47 As a business owner who works in the Health Field, I am strongly against fracking. It is a hazard to our health and the health of generations to come! WE REJECT THIS!!! Sincerely, Caroline Grace Ashurst, M.Ac, L.Ac. 4 PSE Healthy Energy Library, https://www.zotero.org/groups/pse_study_citation_database/items; See Compendium, http://concernedhealthny.org/compendium/, p. 4; Environmental Protection Agency (EPA). 2015. U.S. EPA. Hydraulic Fracturing for Oil and Gas: Impacts from the Hydraulic Fracturing Water Cycle on Drinking Water Resources in the United States (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-16/236F, 2016. Available at: www.epa.gov/hfstudy and https://cfpub.epa.gov/ncea/hfstudy/recordisplay.cfm?deid=332990; PADEP, accessed 10.25.2017 at: http://files.dep.state.pa.us/OilGas/BOGM/BOGMPortalFiles/OilGasReports/Determination_Letters/Regional_Dete rmination_Letters.pdf 5 PSE Healthy Energy Library, https://www.zotero.org/groups/pse_study_citation_database/items; See Compendium, http://concernedhealthny.org/compendium/, p. 4 Delaware Riverkeeper Network, "Unsafe and Unsustainable," 9 Rubin, Paul, 2014. "Unsafe and Unsustainable", Delaware Riverkeeper Network, p. 36, 38 and 39. 10 Rubin, Paul, 2014. "Unsafe and Unsustainable", Delaware Riverkeeper Network, p. 27. 11 Rubin, Paul, 2014. "Unsafe and Unsustainable", Delaware Riverkeeper Network, p. 36, 38 and 39. 12 Myers, T., 2014. "Unsafe and Unsustainable", Delaware Riverkeeper Network, p. 56. 13 Myers, T., 2012. Potential contaminant pathways from hydraulically fractured shale to aquifers. Ground Water 50(6): 872-882 doi: 10.1111/j.1745-6584.2012.00933.x 25 Ted Auch, Fractracker Alliance, "The Freshwater and Liquid Waste Impact of Unconventional Oil and Gas in Ohio and West Virginia", //midatlanticwrc.org/event-info/agenda/the-freshwater-and-liquid-waste-impact-of-unconventional-oil-and-gas- in-ohio-and-west-virginia/ 45 NRDC Document, "In Fracking's Wake: New Rules are Needed to Protect Our Health and Environment from Contaminated Wastewater", May 2012 d:12-05-A, Table 1. 46 Yale University School of Public Health, https://publichealth.yale.edu/news/article.aspx?id=13714 47 Ibid.

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Comment From: Amy Golder

2/17/18 @ 8:56 AM

I oppose the total ban of natural gas development in the Delaware River Basin because I see it as the beginning of overreach by an out of control agency bowing to the political winds of the environmentalists like the Delaware Riverkeeper Network and ...↓

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Comment From: Cathy Golder

2/17/18 @ 8:45 AM

A complete ban on natural gas development in the Delaware River Basin is just the beginning of overreach by an organization of unelected officials. Not only is it a violation of the DRBC Compact, it is unconstitutional and a violation of my rights. ...↓

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Comment From: Lance Kounitz

2/17/18 @ 2:16 AM

The Delaware River Watershed as I have read is the source of drinking water for some 14 million people plus or minus. If we were to allow this fracturing to go forward and it proves itself a source of groundwater and surface water pollution there is...↓

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Comment From: Don Hawkins

2/16/18 @ 11:48 AM

PLease ban fracking throughout the Watershed, ban frack wastewater from being dumped here, and ban Delaware River Watershed water from being exported to fuel fracking elsewhere.

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Comment From: Thomas Wheeler

2/16/18 @ 10:52 AM

I own property on Starlight Lake in Starlight, PA, within the Delaware River Basin. I urge you to ban fracking within the Basin. Fracking threatens the beautiful environment of this region, which is valued by vacationers, tourists, fisherman, and oth...↓

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Comment From: Judy Paulus

2/16/18 @ 8:51 AM

Why did NY state ban fracking??because thay have proof of health problems and are smarter than Pa!!!! Air impacts—-respiratory problems Climate change impacts ——-due to methane and other volatile organic chemicals released in the atmosphere Drin...↓

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Comment From: Scott Cannon

2/16/18 @ 6:57 AM

In light of this new study that shows that fracked gas is worse than coal for climate change, a moratorium on fracking and wastewater disbursement in the Delaware Water Shed Basin should be enacted. https://www.edf.org/energy/explore-pennsylvanias-oi...↓

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Comment From: Larry Morton

2/16/18 @ 6:00 AM

Once again, the Delaware River Commission is proposing to restrict fracking related oil and gas development in the Basin, utilizing unfounded science and public "hysteria" as it's justification. This restriction will likely impose serious and signif...↓icant financial impacts on land and mineral owners in the basin, far beyond whatever real impacts might actually arise. I therefore offer the following comments for consideration. I worked in the oil and gas industry for over 30 years, in the drilling and production arm of both major integrated and independent Corporations in Texas, Louisiana, California and Alaska. As a result of this experience, I know that the industry has a stellar record for production safety and impact prevention that is unmatched in the world. Overall, when done properly (and there is absolutely no reason to believe that it would be done improperly), fracing is a safe and effective means of enhancing the productivity of a well. Wells are drilled and cased with several "layers" of steel and cement to ensure the protection of potable and surface waters. If this were not the case, then there would now be no unpolluted surface or near surface water in areas like Texas, Louisiana, Oklahoma, Colorado, etc. where fracing has been a common practice for decades! This Commission needs to give serious consideration to the "real science" of fracing, and discount the hysteria of the "chicken-little--the sky is falling" opponents to such a practice. Land and mineral owners in the Basin will suffer serious financial harm if they are not allowed to take advantage of their property rights because of the "not in my backyard" mentality of the opponents. I could go on and on about the unfair and biased way our nation's energy policy has been negatively impacted and compromised by the environmentalists and preservationists that seem to be against any and every fossil fuel development project in our nation. Fracing has put us back in the lead in the world-wide quest for oil and gas----because it is still the most cost effective and environmentally friendly source of energy that our nation and the world will continue to use. Therefore, I ask that you please stop the unfounded restraints to our nation's growth and prosperity imposed by unfounded regulations and restrictions on this region's assets. Thank you

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Comment From: Louise Kidder

2/16/18 @ 5:45 AM

We need a complete ban on fracking in Pennsylvania to protect what is essential for a healthy life. We cannot live without safe clean potable water. Let's not be short-sighted or blind!

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Comment From: Patsu Padgett

2/16/18 @ 4:16 AM

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Comment From: Susan Wheeler

2/16/18 @ 1:55 AM

Since 1896, our family has owned property in Starlight, PA which is located within the Delaware River Basin. We have enjoyed the beauty and peacefulness of this area for 5 generations now and the idea of it being ruined by outside interests scares us...↓

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Comment From: Leslie Martin-Borsuk

2/16/18 @ 1:33 AM

I am the owner of a home on a lake in the Delaware River Basin. Based on our experiences with a test well near the property I can see no benefit that the fracking industry can offer. Jobs were filled by workers brought in from Texas and the truck tra...↓

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Comment From: Proctor Schenk

2/16/18 @ 1:22 AM

I own woodland acreage and a lake near our house in Starlight PA, which is in the Delaware River Basin. We are terrified that fracking could have a deleterious effect on our property and the surrounding area. The economy in our community is large...↓

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Comment From: Deborah Schenk

2/16/18 @ 1:04 AM

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Comment From: Debra Forman

2/15/18 @ 9:44 PM

I support a complete ban on fracking and am dismayed that the DRBC is even considering permitting the dumping of a drop of fracked waste water into the Delaware River, much less a plan to allow it. As your name implies, you are directed to protect t...↓

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Comment From: Steve Picerno

2/15/18 @ 9:32 PM

Please ban tracking. Our drinking water supply and our health is at stake.

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Comment From: Brion Vallone

2/15/18 @ 11:47 AM

END FRACKING,PUMPING CHEMICALS INTO THE EARTH IS INSANE, JUST LIKE DUMPING GARBAGE INTO THE OCEAN WAS AND STILL IS,WAKE UP, YOU CAN'T BE THAT DUMB, HOW MUCH YOU POLITICIANS PUTTING IN YOUR POCKETS?...SHAME ON YOU !

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Comment From: JOHN PASQUA

2/15/18 @ 11:43 AM

BAN THE FRACKING THAT RUINS THE ENVIRONMENT FOR GOOD.

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Comment From: Thomas Simonet

2/15/18 @ 10:01 AM

I own mineral rights to a few acres in the Bakken play in North Dakota. My siblings, cousins and I will tell you that fracking is NOT a boon to landowners. After each of us received initial payments of about $3,000 several years ago, none of us has s...↓

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Comment From: Stephanie Jones

2/15/18 @ 9:55 AM

Water and clean air are our most precious resources. Please do everything in your power to stop fracking and jeopardizing our drinking water

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Comment From: William Kellner

2/15/18 @ 9:28 AM

w We all depend on clean water to survive so it is up to all of us to do our part to protect it.We need to put a stop to hydraulic fracturing in shale and other formations before it is to late and the harm is already. Thank you, Will Kellner

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Comment From: Steve Troyanovich

2/15/18 @ 8:00 AM

There needs to be a permanent ban on all fracking. Research clearly indicates that fracking has resulted in many unintended and destructive consequences to land and communities. It is also a totally unneeded process in the 21st Century!!!

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Comment From: MaryAnn Barrett

2/15/18 @ 7:44 AM

NO FRACKING NOW OR EVER, PLEASE. NONE NONE NONE. EVER.

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Comment From: Cathy Pregmon

2/15/18 @ 6:40 AM

I am asking the DRBC to support and promulgate a complete and permanent ban on all activities of fracking in the Delaware River Basin. No fracking, no water taken out of our basin, no waste waters from fracking in other parts of Pennsylvania into the...↓

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Comment From: anne veraldi

2/15/18 @ 6:37 AM

Please do not allow fracking in the Delaware River Basin.

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Comment From: Vivian Radebaugh

2/15/18 @ 6:15 AM

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Comment From: Suzanne Day

2/15/18 @ 6:05 AM

I've taught environmental science at Temple University, have lived many decades using well water, had a gas pipeline (the "Big Inch") go through my family's farm in Chester County PA when I was a child in the 1940s. Now I'm over 80 and, as an informe...↓

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Comment From: Jena Laske

2/15/18 @ 6:01 AM

Dear DRBC, 1) Please do not allow the toxic wastewater produced by fracking to be stored, processed, and discharged in the Delaware River Watershed 2) Please do not allow Delaware River Watershed water to be exported from the Basin for fracking...↓

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Comment From: Bettie Reina

2/15/18 @ 5:59 AM

It is beyond comprehension that those who are tasked with protecting our health and well-being are the very ones who appear to be destroying those regulations that do just that. It is no longer a matter of conjecture, the facts are in.

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Comment From: Gerson Lesser, MD

2/15/18 @ 5:34 AM

Suggest discontinuation of hydraulic fracturing. This procedure uses large amounts of freshwater, using multiple (and often unknown) chemical additives,, and has severely contaminated discharge.

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Comment From: Cathie Forman

2/15/18 @ 5:17 AM

There is more than enough evidence that fracking is a dangerous, toxic, harmful to humans procedure, used to extract natural gas. From Wyoming to West Virginia to Pennsylvania and everywhere else it's been used, there are higher rates of cancer, liv...↓

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Comment From: Jill Arbuckle

2/15/18 @ 4:58 AM

Everyone has a right to clean water. We NJ citizens will soon have that right protected by law. Fracking water is laden with chemicals, some probably carcinogenic The records show that settling ponds leak. Fracking water must not be allowed to be s...↓

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Comment From: Mark Laitysnyder

2/15/18 @ 4:32 AM

Please ban all fracking, frack wastewater, & water exports for fracking within our jurisdiction.

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Comment From: Eric Stein

2/15/18 @ 4:01 AM

PLEASE MAINTAIN THE MORATORIUM ON FRACKING IN THE DELAWARE RIVER BASIN I base this request on the results of extensive study and incontrovertible evidence. See: http://www.delawareriverkeeper.org/sites/default/files/Talking Points Webinar (2018-01-...↓18).pdf Talking Points DRBC Frack Ban Campaign Achieving a complete and permanent ban on natural gas drilling and fracking and all related activities (including wastewater processing and discharges from and water withdrawals for drilling and fracking operations) throughout the Delaware River Watershed. Background, Delaware River Watershed in regional/national context � There is a moratorium on all gas drilling, hydraulic fracturing (fracking), water withdrawals for and wastewater treatment and discharges from fracking throughout the entire Delaware River Basin today, since 2010. � The moratorium was put in place by the Delaware River Basin Commission (DRBC), the federal-interstate agency that manages the water resources of the Delaware River Watershed. The DRBC members the Governors of Pennsylvania, New York, New Jersey, and Delaware, and the federal government have the responsibility of protecting the shared waters that provide 15-17 million people in all four of the Watershed states with drinking water, including New York City and Philadelphia. � The Delaware River was designated as a national Wild and Scenic River by Congress because of its outstanding features, irreplaceable resources, exceptional water quality and scenic and recreational value. These prized assets provide important economic benefit to all four states whose tributaries flow to the Delaware River. These values are gravely jeopardized by fracking and its polluting operations and must be protected for the public and future generations. � The entire nontidal Delaware River is protected by DRBC's Special Protection Waters regulations that do not allow water quality to be diminished in any way. We are dependent on that protection to keep our water safe. � After exhaustive study, the State of New York prohibited fracking based on environmental and public health analysis. The NY Department of Health concluded that the overall weight of the evidence demonstrated the likelihood that adverse health outcomes and environmental impacts from fracking could not be prevented, leading to the Governor's decision to ban high volume hydraulic fracturing in the state.1 The State of Maryland permanently banned fracking after 2 years of study, based on the potential for adverse public health and environmental impacts.2 1 http://www.dec.ny.gov/docs/materials_minerals_pdf/findingstatehvhf62015.pdf http://www.health.ny.gov/press/reports/docs/high_volume_hydraulic_fracturing.pdf 2 http://thinkprogress.org/climate/2015/05/29/3664098/larry-hogan-maryland-fracking-ban/ 2 � The natural gas industry has received unprecedented exemptions from our nation's most important environmental and public health laws, including the Safe Drinking Water Act, Clean Air Act, and the Clean Water Act.3 Hydraulic Fracturing (Fracking) Harms � There is significant evidence that natural gas development, and its related operations, which include all the phases of the hydraulic fracturing ("fracking") process, from the first stage of industrial land preparation; to the storage, handling, and use of chemicals and additives for extraction and stimulation; to drilling and fracking; to the withdrawal of and degradation of large volumes of water and its discharge and disposal as waste, has substantial adverse effects on public health, property interests, agriculture, and on our air, water, and land.4 � The most recent statistical analysis of the body of scientific literature by the Concerned Health Professionals of New York and Physicians for Social Responsibility, 685 peer-reviewed papers examining gas drilling and/or hydraulic fracturing ("fracking") were reviewed and the overwhelming majority of studies found evidence of or potential adverse impacts on water, air, and human health. 5 � Pennsylvania Department of Environmental Protection (PADEP) has determined that there are 301 cases of private water well contamination caused by oil and gas operations in the Commonwealth6 ; over 4,400 water complaints related to oil and gas have been filed by the public with PADEP. Between 2004 and 11.2016, PADEP lists 9,443 public complaints about environmental problems in shale gas drilling areas.7 http://mgaleg.maryland.gov/webmga/frmMain.aspx?pid=narrowsubjpage&tab=subject3&id=hydrfrac&stab=01&y s=2017rs 3 NRDC Policy Basics, 2013. Available at: http://bit.ly/2yPF7Re 4 PSE Healthy Energy Library, https://www.zotero.org/groups/pse_study_citation_database/items; See Compendium, http://concernedhealthny.org/compendium/, p. 4; Environmental Protection Agency (EPA). 2015. U.S. EPA. Hydraulic Fracturing for Oil and Gas: Impacts from the Hydraulic Fracturing Water Cycle on Drinking Water Resources in the United States (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-16/236F, 2016. Available at: www.epa.gov/hfstudy and https://cfpub.epa.gov/ncea/hfstudy/recordisplay.cfm?deid=332990; PADEP, accessed 10.25.2017 at: http://files.dep.state.pa.us/OilGas/BOGM/BOGMPortalFiles/OilGasReports/Determination_Letters/Regional_Dete rmination_Letters.pdf 5 PSE Healthy Energy Library, https://www.zotero.org/groups/pse_study_citation_database/items; See Compendium, http://concernedhealthny.org/compendium/, p. 4 Delaware Riverkeeper Network, "Unsafe and Unsustainable," http://www.delawareriverkeeper.org/Documents/DRN_Report_Unsafe Unsustainable_fr.pdf 6 http://files.dep.state.pa.us/OilGas/BOGM/BOGMPortalFiles/OilGasReports/Determination_Letters/Regional_Det ermination_Letters.pdf 7 https://stateimpact.npr.org/pennsylvania/2017/01/31/data-trove-offers-new-details-on-complaints-to-depduring-shale-boom/ and https://docs.google.com/spreadsheets/d/1_tg1zTCA- 3 � EPA's most recently released fracking study provides scientific evidence that fracking activities can impact drinking water resources and includes water impacts from shale gas in the Pennsylvania community of Dimock. 8 � Fracking pollutes groundwater, destroying the quality of aquifers for generations to come. The chemicals in fracking fluids will migrate to drinking water aquifers and to the surface it is not a question of "if", but "when".9 Considering groundwater flow, time, and the corrosive downhole environment created by gas extraction processes, including the lack of durability of the cement sealant and steel well casings, aquifers and surface waters are not sufficiently isolated from the toxic fluids and deep geology pollutants that are distributed by drilling and fracking.10 Aquifers could be impacted quickly, such as when there is a faulty cement seal or casing during construction, or over time. But it is certain that the life of the cement and/or steel (usually 80 to 100 years or less) is less than the life of the aquifer - so even if there is no evidence in the near term, the eventual pollution likely occur in less than a century11 - ruining water sources for the generations that will follow. The potential for fracking fluids to move from the production zone of a gas well to water resources "cannot be engineered out of the process (Gassiat et al. 2013). In other words, the process of injecting fluids into and fracturing the shale causes the potential pollution problem."12 Contaminated fluids from the fracking process can move from the deep shale to water resources through various pathways including fractures and natural vertical flow, in thousands of years or in less than ten years, polluting groundwater.13 � Natural gas is primarily methane, a greenhouse gas 86 times more efficient at warming the atmosphere than carbon over a 20 year time frame14 and its effects persist for hundreds of years15. The well documented vented and fugitive losses from natural gas systems contribute to atmospheric warming; current technology and practices have not controlled these releases. The emissions from shale gas development are so great that it is projected that their release from the build out of xTmFk4erdcYJt4zqmQZ9x89qliQg55zekg/edit#gid=1060152199 and https://maps.fractracker.org/latest/?appid=f973714e27c14e1ebee222d2560f8cb0 8 Environmental Protection Agency (EPA). Assessment of the Potential Impacts of Hydraulic Fracturing for Oil and Gas on Drinking Water Resources External Review Draft. June 2015. Available at: www.epa.gov/hfstudy; Hein 2012, p. 2. https://cfpub.epa.gov/ncea/hfstudy/recordisplay.cfm?deid=332990 9 Rubin, Paul, 2014. "Unsafe and Unsustainable", Delaware Riverkeeper Network, p. 36, 38 and 39. 10 Rubin, Paul, 2014. "Unsafe and Unsustainable", Delaware Riverkeeper Network, p. 27. 11 Rubin, Paul, 2014. "Unsafe and Unsustainable", Delaware Riverkeeper Network, p. 36, 38 and 39. 12 Myers, T., 2014. "Unsafe and Unsustainable", Delaware Riverkeeper Network, p. 56. 13 Myers, T., 2012. Potential contaminant pathways from hydraulically fractured shale to aquifers. Ground Water 50(6): 872-882 doi: 10.1111/j.1745-6584.2012.00933.x 14 Intergovernmental Panel on Climate Change (IPCC). 2013. Climate Change 2013: The Physical Science Basis. Contribution of Working Group I to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change. 15 http://www.pnas.org/content/early/2017/01/03/1612066114.full 4 Pennsylvania's Marcellus shale will prevent the achievement of global warming goals in the state, accelerating climate change.16 Climate change impacts on the basin's water resources include changes in precipitation and runoff that increase flooding and drought, impairment of habitats and water quality (including salt water intrusion to Delaware Estuary water supplies) and sea level rise17 . � Changes to stream water quality occur where gas drilling and related activities are located. For instance, a publication of the Proceedings of the National Academy of Sciences found streams adjacent to gas wells are negatively impacted by runoff and sedimentation (Total Suspended Solids), harming benthic life, fish and wildlife and causing streams to be eroded and destabilized.18 � Substantial damage is caused by the toxic wastewater produced by fracking which contains many dangerous pollutants, including naturally occurring radioactive materials, that cannot be fully removed by treatment and those damages can substantially harm the water quality of our streams and the life in them. Pollutants will inevitably spread downstream to negatively impact all of the watershed states, the habitats, fish, wildlife, and recreational values of the river and our vulnerable drinking water supplies. � Fracking uses proppants such as silica sand that is mined in the Midwest, states such as Wisconsin, Minnesota, and Iowa, to prop open the fractures in the rock caused by the fracking process. The sand mining activities are having devastating impacts in the sand regions and pose serious health impacts for workers.19 The sand is primarily transported by rail, often on heavy, mile-long trains, and then offloaded onto trucks to be carried into the well site. Some Local/Regional Impacts from Fracking � For the local region, fracking and its activities will cause increased truck traffic. Every gas well results in at least 1400 truck trips to bring in and take out chemicals, fracking proppants, equipment, water and wastewater. As well bores lengthen, the number of truck trips increase up to 2200 per well. � Air emissions and water pollution have greater adverse health impacts on those who reside, work, go to school, or frequent the zone within approximately 2 miles from 16 PSE Healthy Energy, "Lifecycle Greenhouse Gas Emissions Associated with Projected Future Marcellus Development", 2017. 17 https://www.epa.gov/climate-impacts/climate-impacts-water-resources 18 Olmstead, et.al., "Shale gas development impacts on surface water quality in Pennsylvania", Proc Natl Acad Sci U S A. 2013 Mar 26; 110(13): 49624967. Published online 2013 Mar 11. Doi: 10.1073/pnas.1213871110, PMCID: PMC3612605 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3612605/ 19 Wisconsin Center for Investigative Journalism; https://www.wisconsinwatch.org/series/frac-sand/ 5 the gas operation. Studies show that those closest have greater exposure and are more likely to develop disease and other health problems.20 21 � Noise, lights, and changes in quality of life occur in areas where gas drilling and related operations occur. Drilling of a gas well, for instance, takes many days and cannot be interrupted, causing round the clock noise and lights. DRBC Draft Fracking Regulations and WATER � Considering that only 1% o the earth's water is drinkable, how we manage water will define our future and the future of the planet. Since 99% o that water is groundwater22, how we look after our aquifers is the most critical component involved. � Little is being done nationally or on a global scale about our high water consumption and out of date planning. An article in the Harvard Business School's Working Knowledge points out that by 2050, the Earth's population will likely exceed 9 billion people, many expected to live in cities yet in terms of urban planning, "Water is often planned last and gets short shrift," said John Briscoe, a professor at the Harvard School of Engineering and Applied Sciences, who participated in a panel a session dedicated to water. "Water is absolutely the poor cousin of the utilities." � In the Delaware River Watershed, water supplies contribute 3.82 billion dollars in annual value to the regional economy and water quality brings $2.5M in annual economic benefit to the Basin, according to a study out of the University of Delaware.23 When water is depleted, it has real economic impacts for the source watershed that has lost the value of that water. � Fracking uses enormous volumes of water, approximately 5-10 million gallons per well, and increases of 10-20 million gallons are becoming more frequent. The old 20 Webb E1 , Moon J1 , Dyrszka L1 , Rodriguez B1 , Cox C1 , Patisaul H1 , Bushkin S1 , London E1 . "Neurodevelopmental and neurological effects of chemicals associated with unconventional oil and natural gas operations and their potential effects on infants and children". Rev Environ Health. 2017 Oct 25. pii: /j/reveh.ahead-of-print/reveh-2017-0008/reveh-2017-0008.xml. doi: 10.1515/reveh-2017-0008. https://www.ncbi.nlm.nih.gov/pubmed/29068792 21http://www.delawareriverkeeper.org/sites/default/files/resources/Reports/CNA Impacts in DRB.8.15. pdf ; http://www.delawareriverkeeper.org/sites/default/files/MarcellusPA_FullReport.pdf 22 Tom Gleeson, et.al., "Water balance of global aquifers revealed by groundwater footprint", published on line 6.1.12. 23 Gerald J. Kauffman, Socioeconomic Value of the Delaware River Basin in Delaware, New Jersey, New York, and Pennsylvania", University of Delaware, 10.11.11, p. 26. 6 estimates of 4-5 million gallons, used by DRBC, are no longer valid as well bores lengthen. Technology used today can lengthen horizontal well bores up to 4 miles.24 � Dr. Ted Auch of Fractracker Alliance reports there has been an 8-12% icrease in lateral length of well bores each year since 2013 in the major shale gas and oil basins. This increases the amount of water used per fracked well to 9.7 mg on average. In the Marcellus Shale, horizontal well bores are increasing at 11% pr year, today reaching from a mile or two up to 4 miles. This increases the volume of water used to frack each well to between 10 and 20 million gallons. There are wells in Ohio that have used as much as 87 million gallons of water per "super lateral" well.25 � The use of water for fracking is "depletive" - all of the water is lost either by being polluted or by being consumed since most of the water injected for fracking is not recovered and is not returned to the source (PADEP reports that between 8% ad 10% o Marcellus Shale frack water is returned to the surface, meaning up to 90% o the injected water stays underground.) This consumption depletes the surface waterway and/or groundwater from where it is taken. � The water injected for fracking is not only "consumed", but is a total loss to its source. Evaporative losses for uses such as agriculture, power plants or golf courses use water that evaporates to the atmosphere, essentially recycling the water used into the air where it returns as precipitation. But the water used for fracking is no longer available to the hydrologic cycle because most of it is left sequestered deep in the ground, cut off from the natural water cycle, compounding the impacts of the loss. � The DRBC Water Code establishes "Policy of Protection and Preservation" that states "The waters of the Delaware River Basin are limited in quantity and the Basin is frequently subject to drought warnings and drought declarations due to limited water supply storage and streamflow during dry periods. Therefore, it shall be the policy of the Commission to discourage the exportation of water from the Delaware River Basin." 26 24 http://www.post-gazette.com/powersource/companies/2018/01/15/These-days-oil-and-gas-companies-aresuper-sizing-their-well-pads/stories/201801140023 25 Ted Auch, Fractracker Alliance, "The Freshwater and Liquid Waste Impact of Unconventional Oil and Gas in Ohio and West Virginia", //midatlanticwrc.org/event-info/agenda/the-freshwater-and-liquid-waste-impact-of-unconventional-oil-and-gasin-ohio-and-west-virginia/ 26 Delaware River Basin Water Code, Section 2.30.2, p. 46 http://www.nj.gov/drbc/library/documents/watercode.pdf 7 � The DRBC Water Code's Policy of Protection and Preservation also states "The Basin waters have limited assimilative capacity and limited capacity to accept conservative substances without significant impacts. Accordingly, it also shall be the policy of the Commission to discourage the importation of wastewater into the Delaware River Basin that would significantly reduce the assimilative capacity of the receiving stream on the basis that the ability of Delaware River Basin streams to accept wastewater discharges should be reserved for users within the Basin.27 � The draft regulations at proposed 18CFR Part 440.4 and 401.35 say the transfer, diversion, or exportation of water for fracking is to be discouraged and that the transfer of ANY AMOUNT of surface or groundwater, treated wastewater or mine drainage for fracking (not only high volume hydraulic fracturing) outside of the basin requires DRBC approval (raising the threshold for DRBC review from 100,000 gallons of water per day).28 � It is unclear what "discourage" means but DRBC's Water Code does require, on a case by case basis, review of several issues when considering an application for water transfer out of the basin. These conditions were not changed or supplemented for the use of water for fracking; they are the same for all uses. They require: consideration of alternatives, including "no project"; conservation or development of resources outside of the basin be developed first; consideration of economic and social impacts of available alternatives; consideration of amount, timing, and duration of the proposed transfer and its relationship to passing flow requirements, hydrologic conditions, and impacts on instream uses and downstream assimilation capacity; benefits to the basin; how the volume of transfer relates to DRBC actions; how the volume relates to all other diversions; and any significant benefit or impairment to the basin.29 � DRBC regulates withdrawals from streams with the use of a "pass-by flow" that limits the amount of water that can be withdrawn to protect streams from being overdrawn. However, a pass-by flow that is based on using the Q7-10 (the flow which occurs for a period of seven consecutive days one time in 10 years considered "drought flow") is not adequate to protect waterways and the life that depends on them30 and can be expected to cause direct harm to the habitats and water quality of the 27 Delaware River Basin Water Code, Section 2.30.2, p. 46 47 http://www.nj.gov/drbc/library/documents/watercode.pdf 28 Proposed Revisions and Additions to Section 18CFR 401.35 relating to project review classifications Section 401.35(a)(2) and (16). 29 Delaware River Basin Water Code, Section 2.30.4, p. 47 http://www.nj.gov/drbc/library/documents/watercode.pdf 30 Instream Flows for Riverine Resource Stewardship, Instream Flow Council, Cheyenne, Wyoming, 2004, page178 8 stream.31 Using the Q7-10 allows the stream's flow to be artificially "flattened" because the natural flow regime and seasonality will be disrupted and potentially eliminated. An ecological flow analysis of the waterway is required to measure the natural variation of the waterway's flows in terms of volume, rate, temperature, stream stricture, and quality. This analysis should be completed before any withdrawal of surface water in order to provide an ecologically-based flow regime that will give needed protection to the habitats, species and water quality of that particular stream. � Water withdrawals from surface waterways have the potential to deplete downstream groundwater resources if set based on pass-by flows that do not take seasonality into account, including local benefits of high flows such as springtime flows or heavy precipitation events. Such a withdrawal may downstream cause some additional discharge from the aquifer to make up the loss of stream flow. This additional base flow will be contributed by shallow groundwater downstream of the withdrawal site, impacting aquifers. This presents the potential for loss of groundwater reserves that will discharge to the stressed waterway to maintain base flow that was lost to the withdrawal. 32 � The withdrawal of water from a waterway or groundwater has the potential to directly disrupt or diminish the flow of water to hydrologically connected wetlands or other water-dependent bodies such as open ponds and springs. � The removal of water from aquifers or surface water bodies reduces the amount of fresh water available to dilute the input of pollutants. � Pumping of aquifers has the potential to cause a pollution plume to move toward the pump location, spreading the pathway of pollution and/or the rate of movement. � Pumping of aquifers has the potential to disrupt the flow of groundwater that feeds existing water supply wells or natural resources such as wetlands, seeps, and springs. It can also diminish and/or disrupt available groundwater that supports forests and other vegetation, including agriculture, harming existing uses. 31 Instream Flows for Riverine Resource Stewardship, Instream Flow Council, Cheyenne, Wyoming, 2004, page178- 179 32 "Review of XTO Energy Oquaga Creek Withdrawal, DRBC Docket D-2010-022"1-, Peter Demicco, Demicco and Associates, 5.9.11 9 DRBC Draft Fracking Regulations and WASTEWATER � The supersized wells, with horizontal well bores up to 4 miles long33 , as discussed under WATER in these Talking Points, use 10-20 million gallons of water per well.34 This means not only more water is needed but also means there are greater volumes of wastewater produced by these wells as well. Gone are the old estimates of flowback from a well of approximately 10-15% o 5 million gallons; the new normal is steadily climbing to 10-15% o 10 to 20 million gallons being produced short term at the fracked well site. That translates into between 1-1.5 million gallons of wastewater (at 10M gal. of water) to between 2 and 3 million gallons of wastewater (at 20M gal. of water) per well, increasing the volumes three to four times over a new glut of wastewater that has to go somewhere. The need for more places to get rid of this wastewater is a problem becoming so acute that the industry is now targeting the Delaware River Basin and, with these draft regulations, the DRBC is opening the door. The Delaware River Watershed's proximity to one of the most productive regions of the Marcellus Shale play, in the northeastern portion of the Susquehanna Watershed, makes it especially attractive. � DRBC proposes to require Treatability Studies for the treatment of frack wastewater at Centralized Wastewater Treatment Facilities that plan to discharge to the Watershed. These studies are to show that the Pollutants of Concern are addressed, using USEPA Tables from the agency's technical document on oil and gas waste discharges to define the Pollutants of Concern. 35 There are 78 pollutants listed but those are not all the toxic and/or hazardous pollutants contained in frack wastewater. For instance, NYDEC listed 154 parameters in frack wastewater they sampled from the Marcellus in Pennsylvania and West Virginia. 36 And over 1000 additives are in the fluids used to frack wells today3738; many are carried into the 33 http://www.post-gazette.com/powersource/companies/2018/01/15/These-days-oil-and-gas-companies-aresuper-sizing-their-well-pads/stories/201801140023 34 Ted Auch, Fractracker Alliance, "The Freshwater and Liquid Waste Impact of Unconventional Oil and Gas in Ohio and West Virginia", //midatlanticwrc.org/event-info/agenda/the-freshwater-and-liquid-waste-impact-of-unconventional-oil-and-gasin-ohio-and-west-virginia/ 35 USEPA Technical Development Document for the Effluent Limitations Guidelines and Standards for the Oil and Gas Extraction Point Source Category (2016), Tables C -11, C-13, C-15, C-17, C-19. 36 New York State Department of Environmental Conservation, Revised Draft Supplemental Generic Environmental Impact Statement on the Oil, Gas, and Solution Mining Regulatory Program, Well Permit Issuance for Horizontal Drilling and High-Volume Hydraulic Fracturing to Develop the Marcellus Shale and other Low-Permeability Gas Reservoirs, September 2011, Table 5.9. 37 USEPA, Hydraulic Fracturing for Oil and Gas: Impacts from the Hydraulic Fracturing Water Cycle on Drinking Water Resources in the United States", EPA-600-R-16-236Fa, December 2016 www.epa.gov/hfstudy 38 New York State Department of Environmental Conservation, Revised Draft Supplemental Generic Environmental Impact Statement on the Oil, Gas, and Solution Mining Regulatory Program, Well Permit Issuance for Horizontal 10 frack wastewater produced by the well. Many of these frack fluids are toxic and/or have harmful health effects for humans or fish, wildlife and plant life. � DRBC proposes, in certain circumstances, to use the "background concentration" of a pollutant, or the measurement of the existing level of a pollutant in a waterway, as the amount that a discharger of effluent must not exceed. The problem with this approach is the waterway will, effectively, be doomed to maintaining that concentration of a pollutant if the effluent discharged simply meets the background; the stream won't have a chance to become cleaner. This is especially problematic where concentrations of some pollutants are too high. In the Estuary parameters such as Total Dissolved Solids and some toxics already far exceed healthy conditions and are in need of improvement. DRBC and the states, under federal EPA regulatory requirements such as the Clean Water Act, work regularly on plans to minimize pollution to restore healthy water quality but the background concentration approach undermines those efforts. � DRBC says they have not yet developed the analytical methods, method detection limits, and quantification limits that a discharger must use to define the background concentration of a pollutant so there is no certainty about its accuracy or reliability. � Total Dissolved Solids are extremely high in frack wastewater and constitute, by sheer mass, the largest pollutant, containing potent salts. In such huge amounts, TDS is very difficult to keep under control. DRBC proposes a limit of 500 mg/l of TDS, or not to exceed background, for zones of the river as far south as River Mile 95, located roughly at the southern part of the Philadelphia region. However, 500 mg/l is not protective of aquatic life. For instance, 350 mg/l TDS reduced spawning of Striped bass (Morone saxatilis) in the San Francisco Bay-Delta region, and concentrations below 200 mg/l promoted even healthier spawning conditions for fish.39 And in the Truckee River, the EPA found that juvenile Lahonton cutthroat trout were subject to higher mortality when exposed to thermal pollution stress combined with high total dissolved solids concentrations. 40 � In Zones 4 to 641, encompassing most of the Estuary south to the Bay and Ocean, DRBC is allowing a TDS standard of "not to exceed 1,000 mg/l" "or a concentration Drilling and High-Volume Hydraulic Fracturing to Develop the Marcellus Shale and other Low-Permeability Gas Reservoirs, September 2011, Table 6.1. 39 Kaiser Engineers, California, Final Report to the State of California, San Francisco Bay-Delta Water Quality Control Program, State of California, Sacramento, CA (1969). 40 C.M. Hogan, Marc Papineau et al. Development of a dynamic water quality simulation model for the Truckee River, Earth Metrics Inc., Environmental Protection Agency Technology Series, Washington D.C. (1987). 41 DRBC Water Quality Regulations, 18 CFR, Part 410 http://www.state.nj.us/drbc/library/documents/WQregs.pdf 11 established by the Commission that is compatible with designated water uses and stream quality objectives". In the Estuary drinking water is not a protected use, so safe drinking water standards don't apply, allowing less strict pollution controls. DRBC also allows "mixing zones" there, which means pollution in wastewater that doesn't meet clean water standards can be mixed, or diluted by the waterway, before meeting a required standard. This spells DOOM for this region, affecting resources of Pennsylvania, New Jersey and Delaware. This threatens all life in these zones of the Estuary and Bay. And since the tides carry pollutants, including increased salinity, upstream and into tributaries, areas that do provide drinking water (including the State of Delaware's tributary drinking water intakes, and Philadelphia and south Jersey drinking water intakes serving millions of people) and upstream river zones that are tidally influenced will all be negatively impacted to some degree. � Allowing DRBC flexibility to set a TDS concentration (as stated in the bullet point above: "...or a concentration established by the Commission that is compatible with designated water uses and stream quality objectives") is not reliable or protective because DRBC currently grants variances for TDS loadings from wastewater into these areas now. DRBC even has a form that a discharger fills out to explain why they can't meet TDS limits and why they need a mixing zone it is that standard a practice. Examples of specific approvals for permits where DRBC has been lax in applying TDS limits are Global Advanced Metals Industrial Wastewater Treatment Facility, Schuylkill River, Perkiomen Creek, Swamp Creek, PA42 (TDS of 15,000 mg/l) and JBS Souderton Industrial Wastewater Treatment Facility for a meat packing plant, Schuylkill River, Perkiomen Creek, Skippack Creek, PA43 (TDS of 3,100mg/l). Even when it is known that a discharger could not possibly meet required standards throughout the year due to high levels of pollution in the wastewater, DRBC currently bends the rules by allowing open lagoons to temporarily store wastewater that at certain times cannot be discharged due to conditions in the receiving waterway, such as low flows. So not only are the regulations not strict enough but DRBC already goes around the rules and allows for pollution by TDS. DRBC simply can't be relied on to stick to what is in the rules. � Monitoring and reporting of numeric effluent limits is not a requirement in the draft regulations, only "may" be required. DRBC has no enforcement police. � Whole Effluent Toxicity (WET) testing should only be the first stage in a risk assessment; WET testing identifies a hazard(s), not how much risk is associated with that hazard. WET testing used to assess the effect of all pollutants in a facility's 42 http://www.state.nj.us/drbc/library/documents/dockets/interactive-map/1970-072-5.pdf 43 http://www.state.nj.us/drbc/library/documents/dockets/interactive-map/1996-021-4.pdf 12 effluent is not conclusive.44 DRBC should not rely on WET testing to predict toxic effects. � Frack wastewater contains many dangerous and toxic constituents and properties including: Total Dissolved Solids (TDS), Total Kjeldahl Nitrogen (TKN), Ammonia Nitrogen, NitrateN, Chloride, Bromide, Sodium, Sulfate, Oil and Grease, BTEX (benzene, toluene, ethylbenzene, xylene), VOC (volatile organic compounds), Naturally Occurring Radioactive Materials (NORM), Barium, and Strontium. 45 Some are carcinogenic, some have known health effects, and some are toxic to aquatic life and plant life. � Yale University School of Public Health, in a study of chemicals used in fracking, found that of the 119 compounds with sufficient data to classify them in terms of carcinogenicity (only 20% o chemicals in use had sufficient data a problem in itself), "44 percent of the water pollutants and 60 percent of air pollutants were either confirmed or possible carcinogens." 46 55 unique compounds with carcinogenic potential could be released to both water or air and 20 chemicals had evidence of increased risk for leukemia or lymphoma specifically.47 � In its national study of fracking and drinking water, EPA identified 1,606 chemicals in fracking fluid or drilling wastewater including 1,084 identified in fracking fluid and 599 identified in wastewater, yet only 173 had toxicity values from sources that met EPA's standards for conducting risk assessments. "This missing information represents a significant data gap that makes it difficult to fully understand the severity of potential impacts on drinking water resources." However, EPA also reported that "health effects associated with chronic oral exposure to these chemicals include carcinogenicity, neurotoxicity, immune system effects, changes in body weight, changes in blood chemistry, liver and kidney toxicity, and reproductive and developmental toxicity."48 It is highly likely that at least some of these chemicals will leak, spill, or migrate into water supplies. Therefore, allowing drilling and fracking activities in the Delaware River Basin amounts to a huge gamble with people's health. (EPA did not mention that the agency's own failure to request 44 PETER M. CHAPMAN, "WHOLE EFFLUENT TOXICITY TESTINGUSEFULNESS, LEVEL OF PROTECTION, AND RISK ASSESSMENT", Environmental Toxicology and Chemistry, Vol. 19, No. 1, pp. 313, 2000, q 2000, SETAC, 0730- 7268/00. 45 NRDC Document, "In Fracking's Wake: New Rules are Needed to Protect Our Health and Environment from Contaminated Wastewater", May 2012 d:12-05-A, Table 1. 46 Yale University School of Public Health, https://publichealth.yale.edu/news/article.aspx?id=13714 47 Ibid. 48 U.S. Environmental Protection Agency. Hydraulic fracturing for oil and gas: impacts from the hydraulic fracturing water cycle on drinking water resources in the United States. Washington, DC: Office of Research and Development; 2016, at ES-45 to ES-46 and 9-1. EPA Report # 600/R-16/236F. See https://www.epa.gov/hfstudy. 13 health testing for new chemicals proposed for oil and gas drilling and regulated by EPA under the Toxic Substances Control Act contributed to the lack of information about chemical risks.)49 � EPA officials could not be certain about the accuracy of their list of chemicals found in fracking fluid and wastewater in part because the list did not include confidential chemicals used by drilling companies for hydraulic fracturing. Drilling companies have withheld fracking chemical identities from the public as confidential thousands of times. Two Harvard researchers found that 92 percent of the well-by-well fracking chemical disclosures submitted to the non-governmental organization FracFocus between approximately March 2011 and April 2015 included at least one chemical identity withheld from the public as confidential business information (CBI).50 FracFocus is the nation's leading repository of fracking chemical disclosure information and currently contains disclosures from more than 127,000 wells.51 EPA commented that "when chemicals are claimed as CBI, there is no public means of accessing information on these chemicals. Furthermore, many of the chemicals and chemical mixtures disclosed, or those detected in produced water, lack information on properties affecting their movement, persistence, and toxicity in the environment should they be spilled."52 This information, too, shows that allowing drilling and fracking activities in the basin would be a huge roll of the dice with public health and the environment. It also raises questions about how water treatment facilities would be able to treat fracking wastewater if neither they nor EPA know what's in it. � Bromide is a contaminant consistently found in frack wastewater. Pennsylvania Department of Environmental Protection acknowledges that bromide is a key parameter of concern in the effluent because it can form brominated disinfection byproducts (DBP's) in water supplies.53 These are a drinking water hazard because of the propensity for the brominated DBP's to form trihalomethanes and haloacetic acid, which can cause cancer.54 An example of how difficult it is to control bromides 49 Dusty Horwitt, Environmental Issues Concerning Hydraulic Fracturing, Volume 1 (Kevin A. Schug and Zachariah L. Hildenbrand, eds.), at 101 (2017). 50 U.S. Environmental Protection Agency. Hydraulic fracturing for oil and gas: impacts from the hydraulic fracturing water cycle on drinking water resources in the United States. Washington, DC: Office of Research and Development; 2016, at 9-1, 10-25. EPA Report # 600/R-16/236F. See https://www.epa.gov/hfstudy. 51 FracFocus. See http://fracfocus.org/. 52 U.S. Environmental Protection Agency. Hydraulic fracturing for oil and gas: impacts from the hydraulic fracturing water cycle on drinking water resources in the United States. Washington, DC: Office of Research and Development; 2016, at 10-25. EPA Report # 600/R-16/236F. See https://www.epa.gov/hfstudy. 53 PADEP "Permitting Strategy for High Total Dissolved Solids (TDS) Wastewater Discharges", April 11, 2009. 54 http://www.duq.edu/academics/schools/natural-and-environmental-sciences/academicprograms/environmental-science-and-management/3-rivers-quest; 14 and the far-reaching effect high concentrations can have is the Monongahela River in Pennsylvania in 20102011. Bromide concentrations increased significantly, leading to increases in trihalomethane and haloacetic acids from mixing with drinking water supply disinfectants. For more detail on the contamination, which affected the drinking water for millions of people in the Pittsburgh region, see "Bromide levels in Monongahela River rose in 2010, remain high", 55 Pittsburgh Post-Gazette and "Bromide pollution persists in Allegheny River in Western Pa.," Associated Press. 56 � It is well known and long understood that the Marcellus Shale formation is radioactive57. Wastewater contaminated with radioactivity is unavoidable. Exposure to these radioactive materials by the public will occur as a result of flowback produced by fracking through one pathway or another, as discussed in this document, increasing the likelihood of cancers58. Radium-226 has a half-life of 1,600 years, so it will be present in the environment for thousands of years. It is also water soluble, meaning it easily travels with water. 59 Radionuclides can also be trapped in drill cuttings and residual solids, providing another pathway for the release to the environment, increasing human exposure and a legacy of enduring environmental contamination. � Interstitial or formation water (the brine in the shale formation) can be highly radioactive (as concentrated as 15,000 pCi/L), so each time the water is reused, the radium is concentrated. This will result in TENORM, or Technically Enhanced Naturally Occurring Radioactive Materials. 60 Frack wastewater containing TENORM is not properly regulated by the federal government or the states due to lack of requirements for monitoring/testing for TENORM at crucial junctures in the waste stream where it should be targeted for detection and removal. For instance, the concentrated residuals that are filtered from wastewater at treatment plants can occur at levels that are so dangerous they would need to be removed to a specially designed storage facility, such as those used for nuclear waste. DRBC states in the proposed regulations that residuals from wastewater treatment should not be affected by the treatment process but radioactive properties inevitably pose a http://edtech.msl.duq.edu/Mediasite/Play/12100228599f4678bf6f83da3a5e6f5c1d?catalog=aac5db45-9272- 4d67-b8aa-df5d052dc62e 55 http://www.post-gazette.com/local/south/2011/11/04/Bromide-levels-in-Monongahela-River-rose-in-2010- remain-high/stories/201111040150 56 http://www.record-courier.com/news/20121113/bromide-pollution-persists-in-allegheny-river-in-western-pa 57 Swanson, VE, "Oil Yield and Uranium Content of Black Shales," USGS paper 356-A, 1960 58 Resnikoff, Marvin, ""Review of Pennsylvania Department of Environmental Protection Technologically Enhanced Naturally Occurring Radioactivity Materials (TENORM) Study Report", Dec. 2015. 59 Ibid. 60 Marvin Resnikoff, Ph.D., Radioactive Waste Management Associates, "Comments on Marcellus Shale Development", October 2011. 15 treatment challenge that will affect both the waste liquids and solids, including residuals; the radioactivity doesn't just disappear. In addition, the lack of testing at the well site and related lack of truck signage ("placarding") that accurately reflects the level of radioactivity of the wastewater that is transported61 adds great risk to the transport of the untreated, toxic wastewater from wells outside of the basin to the Delaware River Watershed for treatment and disposal. � Sampling and data-gathering by New York State detected radiological parameters in Marcellus Shale flowback, including Radium-226, the longest lived isotope of radium with a half-life of 1600 years. Gross Alpha, Gross Beta, Total Alpha Radium and Radium-228 were also found.62 This is a significant wastewater management issue because radioactivity poses human health risks. � A Duke University study of a stream in Pennsylvania below a frack wastewater plant found radium 226 levels in stream sediments at the point of discharge were <200 times greater (5448759 Bq/kg) than upstream sediments and background sediments (2244 Bq/kg) and above radioactive waste disposal threshold regulations. 63 � Although not directly addressed in the draft regulations, the rules may allow the injection of wastewater within the Basin. Injection of wastewater does not "treat" waste or remove contaminants, it simply moves the potential for the toxic wastewater to cause environmental and water resource pollution and water quality degradation from one place and time to another. It also risks the migration of untreated wastewater to aquifers and surface water through leaks from the injection well and spills and accidental releases while being handled.64 The draft regulations do allow the storage of wastewater and DRBC currently allows storage of untreated wastewater in lagoons. Injection wells are causing earthquakes in Ohio and Oklahoma as well as other locations and are not leak-proof, exposing groundwater 61 Resnikoff, Marvin, ""Review of Pennsylvania Department of Environmental Protection Technologically Enhanced Naturally Occurring Radioactivity Materials (TENORM) Study Report", Dec. 2015. 62 New York State Department of Environmental Conservation, Revised Draft Supplemental Generic Environmental Impact Statement on the Oil, Gas, and Solution Mining Regulatory Program, Well Permit Issuance for Horizontal Drilling and High-Volume Hydraulic Fracturing to Develop the Marcellus Shale and other Low-Permeability Gas Reservoirs, September 2011, Table 5.24. 63 Nathaniel R. Warner*, Cidney A. Christie, Robert B. Jackson, and Avner Vengosh, "Impacts of Shale Gas Wastewater Disposal on Water Quality in Western Pennsylvania", Division of Earth and Ocean Sciences, Nicholas School of the Environment, Duke University, Durham, North Carolina 27708, United States, Environ. Sci. Technol., 2013, 47 (20), pp 1184911857, DOI: 10.1021/es402165b http://pubs.acs.org/doi/abs/10.1021/es402165b 64 Akob, D.M., Mumford, A.C., Orem, W., Engle, M.A., Klinges, J.G., Kent, D.B., & Cozzarelli I.M. (2016). Wastewater Disposal from Unconventional Oil and Gas Development Degrades Stream Quality at a West Virginia Injection Facility. Environ. Sci. Technol. 50, 55175525 16 and aquifers to contamination from the toxic mix that constitutes untreated frack wastewater. Other considerations � Also not directly addressed in the draft regulations is the storage of natural gas liquids in the Watershed. These hazardous liquids cannot be stored safely in underground caverns, which are prone to leakage and are unstable. � A complete and permanent ban on natural gas drilling and fracking and all related activities (including wastewater processing and discharges from and water withdrawals for drilling and fracking operations) throughout the Delaware River Watershed is needed because the only sure way to prevent pollution from fracking and its activities is to totally ban it. It makes no sense to ban fracking but allow its toxic waste to be dumped in the Watershed and our precious fresh water to be depleted for fracking. We need a complete and permanent ban now. Available on line at: http://bit.ly/2AQLRvs For more information: Delaware Riverkeeper Network, 925 Canal St, Suite 3701, Bristol PA, 19007 [email protected] 215.369.1188

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Comment From: Kate Sherwood

2/15/18 @ 3:49 AM

The Delaware River was designated as a national Wild and Scenic River by Congress because of its outstanding features, irreplaceable resources, exceptional water quality and scenic and recreational value. These prized asset s provide important...↓

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Comment From: Ronald Gulla

2/15/18 @ 3:16 AM

It is time to fight for our environment and future. Also it is time to fight the corruption head on. Enough is enough the O&G Industry has destroyed water,soil and air everywhere they drill and frack. Why are there so many exemptions for this INDUSTR...↓

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Comment From: Silvio Fittipaldi

2/15/18 @ 3:15 AM

Fracking kills people and the earth. What we get from it is unnecessary.

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Comment From: Bonnie Pariser

2/15/18 @ 3:12 AM

I demand you set a complete ban on fracking in the Delaware River Basin. This procedure is dangerous and will cost lives- both human and non-human animals will be harmed. Please do not put money above safety and the rights of the people who depend o...↓

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Comment From: Mark and Judy Harvey

2/15/18 @ 3:12 AM

We want a complete ban on fracking!

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Comment From: Richard Hartman

2/15/18 @ 3:10 AM

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Comment From: kathleen rengert

2/15/18 @ 2:44 AM

There is NO safe hydraulic fracturing. From earthquakes, to polluted wells, to polluted watersheds and reduced air quality from methane emissions, not to mention fracking wastewater that often contains radioactive material (where do we put that?), pl...↓

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Comment From: Charles Peterman

2/15/18 @ 2:28 AM

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Comment From: Zoe Warner

2/15/18 @ 1:51 AM

We need a complete and permanent ban on hydraulic fracturing in the Delaware River Basin and all of its related activities. The new rules propose a permanent ban on drilling but allow for water usage from the DRB for non-drilling activity. It does no...↓

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Comment From: Gloria Picchetti

2/15/18 @ 1:47 AM

 There is a moratorium on all gas drilling, hydraulic fracturing (fracking), water withdrawals for and wastewater treatment and discharges from fracking throughout the entire Delaware River Basin today, since 2010.  The moratorium was put in pla...↓

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Comment From: Susan Kirk

2/15/18 @ 12:36 AM

The draft regulations to permanently ban fracking in the Delaware River watershed are great...BUT they don't go far enough! The proposal needs to offer more complete protection and therefore should include banning storage and disposal of fracking wa...↓

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Comment From: Austin Loyd

2/14/18 @ 9:42 AM

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Comment From: RICHARD KAPF

2/14/18 @ 7:20 AM

I JUST CAN'T UNDERSTAND WHY WAYNE COUNTY SEEMS TO BE ANOTHER COUNTRY. THESE REGULATIONS ARE REALLY UNBELEIVEABLE, WHEN ALL OTHER COUNTY'S IN PA. SEEM TO BE PROSPERING FROM NATURAL GAS . WHAT IS THE DRBC NEXT STEP?,CAN'T CUT TIMBER,CAN,T BUILD CERTAIN...↓

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Comment From: JEAN PUBLEEE

2/14/18 @ 4:32 AM

I AM TOTALLY OPPOSED TO ALLOWING HYDRAULIC FRACTURING ANYWHERE IN NEW JERSEY AT ANY TIME AND IN PENNSYVANIA TOO (SINCE YOU MADE THAT THE SITE OF HEARINGS THAT I CANNOT ATTEND) I NEED TO WRITE ON THIS ISSUE BECAUSE I CANNOT TRAVEL ALL THAT DISTANCE T...↓

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Comment From: Cooks Creek Watershed Associat... (Scott Douglas)

2/13/18 @ 10:21 AM

Comments in letter attached below

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Comment From: Susan Stoneback

2/13/18 @ 4:24 AM

Please, Please, Please do not ruin our precious waterways and water sheds with fracking and drilling. Too much is at stake. Too many people and wild resources are dependent on these waters to stay 'clean'.

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Comment From: Joan L Farb

2/13/18 @ 3:47 AM

It is imperative that there is a complete and permanent ban on natural gas drilling and fracking and all related activities which include wastewater processing and discharges from fracking and water withdrawals for drilling and fracking. Why a b...↓

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Comment From: Becky Savoie

2/13/18 @ 3:39 AM

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Comment From: Dorothy Cassimatis

2/13/18 @ 3:06 AM

I urge the DRBC to oppose all fracking operations in the Delaware Water Basin, including the discharge of wastewater and use of water for fracking in other areas. There is significant evidence that natural gas development has negative effects on pub...↓

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Comment From: Jennifer Sestito

2/12/18 @ 9:04 AM

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