The DRBC's mandate is to protect the integrity of the water supplies in the Delaware River Basin.  

Our contention is that in carrying out this mandate, the DRBC should adhere to the precautionary principle which states that if an action or policy has a suspected risk of causing harm to the public or to the environment, the burden of proof that it is not harmful falls on those taking the action.  The evidence that we have reviewed strongly suggests that the gas drilling industry in Pennsylvania has not only failed to meet this burden of proof, but has in fact demonstrated that water contamination issues related to gas drilling are a very real and significant concern.  

Environmental Protection Agency documentation has revealed that the wastewater produced by hydrofracturing contains radioactivity and other toxic materials at levels that are higher than can be safely handled at wastewater treatment plants.  As such, our contention is that hydrofracturing wastewater should be legally considered and treated as "hazardous waste" throughout all four states of the Delaware Water Basin, and that proper disposal methods and locations should be in place for this waste prior to allowing permits for the hydrofracturing of shale gas wells.

The recent exhaustive study in The New York Times article of 2/27/11 "unequivocally and definitively establishes that the danger to our health and our environment from hydraulic fracturing is much greater than previously understood; that government regulations have not kept pace with the natural gas industry’s expansion and that government on every level lacks the manpower to adequately police the industry."

The DRBC’s own hydrogeologist says that about 1 million gallons of wastewater is generated per well. The latest predictions are for 15,000 to 18,000 wells in our area, which would mean 15 BILLION TO 18 BILLION GALLONS OF FRACKWATER without proper treatment facilities in place.

As residents of Wayne and Susquehanna counties, we've needed to look no further than Dimock, Pennsylvania for confirmation that the practical application of the current regulatory framework has failed to be an adequate safeguard against water contamination due to hydrofracturing.

Our question for the DRBC is a very simple one.

How can the commission responsibly allow gas drilling and hydrofracturing to go forward in the river basin prior to making certain that we have the water treatment capacity necessary within four contiguous states of the river basin to handle the wastewater?

The above information is suitable for a copy and paste letter to the DRBC by electronic submission on your own or send a personalized letter to the address below.

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Please Send Written Comments Now to the Delaware River Basin Commission (DRBC) in one of two ways: (no direct emails will be considered!)

1. Electronic submission using a web-based form (preferred method). The National Park Service (NPS) has authorized DRBC to utilize its Planning, Environment, and Public Comment (PEPC) online submission system for accepting comments electronically**.  Please click here to go to the PEPC web page to comment on this proposed regulation. http://parkplanning.nps.gov/commentForm.cfm?documentID=37829

2. Paper submission mailed or delivered to: Commission Secretary, DRBC, P.O. Box 7360, 25 State Police Drive, West Trenton, NJ 08628. Please be sure to include the name, address, and affiliation (if any) of the commenter. 
Written comments accepted through 5 p.m. April 15, 2011 (was originally March 16)  

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FURTHER READING
Excerpts from the New York Times Article:

The Times reviewed thousands of internal documents from the Environmental Protection Agency (EPA) that revealed that wastewater, "the byproduct from hydrofracking, contains radioactivity and other toxic materials at levels that are frequently geometrically higher than the level that federal regulators say is safe for wastewater treatment plants to handle."

As part of their multi-month investigation, the Times reviewed thousands of internal documents from the Environmental Protection Agency (EPA) that revealed that wastewater, the byproduct from hydrofracking, contains radioactivity and other toxic materials at levels that are frequently geometrically higher than the level that federal regulators say is safe for wastewater treatment plants to handle. EPA and industry researchers say that the biggest danger of radioactive wastewater is its potential to contaminate drinking water and enter the food chain through fish or farming. Once radium enters a person’s body, by eating, drinking or breathing, it can cause cancer, asthma and a plethora of other health problems, many federal studies show. The Times also found never-reported studies by the EPA and confidential study by the drilling industry that all concluded that radioactivity in drilling waste cannot be fully diluted in rivers and other waterways.  The Times’ exhaustive study which included review of 30,000 pages of federal, state and company records relating to 200 gas wells in PA, 40 in WV and 20 public and private wastewater treatment plans found the following:

•   More than 1.3 billion gallons of wastewater was produced by Pennsylvania wells over the past three years, far more than has been previously disclosed. Most of this water — enough to cover Manhattan in three inches — was sent to treatment plants not equipped to remove many of the toxic and hazardous materials in drilling waste.
• Treatment plants in Pennsylvania discharged waste into some of the state’s major river basins including the Monongahela River, which provides drinking water to more than 800,000 people including Pittsburgh and the Susquehanna River, which feeds into Chesapeake Bay and provides drinking water to more than 6 million people.
• Drillers in Pennsylvania trucked at least half of their waste to at least 12 sewage treatment plants in three other states including two plants in New York that discharge into Southern Cayuga Lake near Ithaca and Owasco Outlet, near Auburn. 
• Of more than 179 wells producing wastewater with high levels of radiation, at least 116 reported levels of radium or other radioactive materials 100 times as high as the levels set by federal drinking-water standards. At least 15 wells produced wastewater carrying more than 1,000 times the amount of radioactive elements considered acceptable.
• Most wastewater facilities cannot remove enough of the radioactive material to meet federal drinking-water standards before discharging the wastewater into rivers, sometimes just miles upstream from drinking–water intake plants.
• Federal and state regulators have given nearly all drinking-water intake facilities in Pennsylvania permission to only test for radioactivity once every six or nine years and with the blessing of regulators, have not tested for radioactivity since before 2006, even though the drilling boom began in 2008.

For the complete article in the New York Times, go to: http://www.nytimes.com/2011/02/27/us/27gas.html?ref=us

There are many other areas of concern that have been addressed in depth by other organizations.

1. Many of the regulations rely on self-monitoring by the gas industry. (We all know how well that worked out in the Gulf.)
2. An adequate cumulative impact study needs to be done prior to any permitting.
3. There are no restrictions placed on the chemicals used in the fracking process, including the use of diesel fuel, which is prohibited but still in use
4. There are too many excessive waivers which offers too many loopholes
5. Open air impoundments and reserve pits for toxic wastewaters and reserve for hazardous solid wastes are permitted, both of which present serious risks of land and groundwater contamination from spills, overflows, leaks, etc.
6. There are no adequate spacing requirements for wells.
7. Delete "the wildcat exemption." Smaller companies with 5 or fewer pads or less tan 3000 acres would be exempt under section 7.5c. These may not have the sufficient resources, knowledge, expertise or assets to successfully and professionally carry out a drilling operation.
8. Toxic emissions from natural gas sites should be treated the same as other industries when regulators decide whether certain strict rules will apply. For example, the toxic fumes from various parts like the compressor station and a storage tank are counted separately at a natural gas site.

The NATIONAL RESOURCE DEFENSE COUNCIL NRDC www.nrdc.org is a great source, which has recently discussed more fully the first five issues above.

Go to their blogspot for more information http://switchboard.nrdc.org/blogs/ksinding/speak_out_against_ill-advised.html

Another great source of up-to date information is the site for PENNENVIRONMENT www.pennenvironment.org which features: Delaware River or 'Drill-a-wherever-you-want' River with an easy to use online letter https://secure3.convio.net/engage/site/Advocacy?cmd=display&page=UserAction&id=1366

Remember you can write a separate letter for each of your concerns. At least write one letter. We need to put the brakes on.