On behalf of the undersigned organizations, we thank you for the opportunity to submit comments on proposed amendments to the Susquehanna River Basin Commission’s (SRBC or Commission) regulations at 18 C.F.R. §§803 and 806. The amendments were made available to the public via public notice in the Federal Register.1 The Commission is accepting comments through November 17th, 2014.2
On the whole, we support and welcome regulatory amendments that clarify the Commission’s legal and practical oversight of public water resources that are utilized by industrial operators, particularly for the purposes of hydrocarbon and unconventional natural gas development. However, we strongly oppose the Commission’s proposal to triple the length of Approval By Rule (“ABR”) authorization terms from five to fifteen years
