Thank you for your letter of August 12, 2013 in response to a letter (sent on July 17, 2013) by the undersigned and other organizations. In that letter, we requested that the Susquehanna River Basin Commission (SRBC) consider an investigation to determine whether Pennsylvania is complying with its obligations as a member jurisdiction to prohibit, control, and abate pollution of the Basin.
We appreciate your response regarding the need for sufficient “credible, factual evidence” in order for the Commission to consider initiating such an investigation. We also appreciate the detailed information on Pennsylvania’s regulatory program provided by Scott Perry of the Pennsylvania Department of Environmental Protection (DEP) in a letter dated July 19, 2013, as well as the interest by the agency in discussing their work and our concerns directly.
With both response letters in mind, we offer the following information about the aspects of DEP’s water quality program outlined in Mr. Perry’s letter. As discussed below, we are concerned not only with what is and is not codified in regulation—but also with the actual environmental impacts of shale gas development on the water resources of the Basin and whether sufficient action is being taken to prevent and address them.
We hope that the following discussion of environmental problems associated with shale gas development and specific regulatory issues apparent in Pennsylvania will be useful to SRBC officers and staff—particularly in New York and Maryland, member states that have not yet decided whether to proceed with shale gas development and are developing guidelines to protect against harm to the environment and public health.