Letter supporting a full fracking ban to the Delaware River Basin Commission

To: DRBC Commissioners –

You adopted a permanent ban on fracking throughout the Delaware River Watershed last year, a historic and righteous decision by the DRBC. The public has been clamoring since then for you to complete the job and prohibit the pollution and depletion caused by fracking taking place elsewhere by revising the pending fracking regulations and voting for a full ban.

This will protect both the Watershed’s communities – human and nonhuman – and its irreplaceable water supplies for up to 17 million people by prohibiting the fracking industry’s effort to dump its toxic and radioactive wastewater in the Basin and preventing their use of Delaware River water for water-intense, wasteful and destructive fracking processes. In 2018, the fracking industry produced 2.9 billion gallons of wastewater[1] in Pennsylvania alone, and the longer well bores being drilled since 2018 mean even higher volumes of both water use and resulting toxic wastewater.[2] The industry is searching for new places to exploit, which is why they are knocking on the Delaware River Basin’s door.

A full ban will also ensure that the DRBC’s regulations do not enable the industry to emit considerable greenhouse gasses by continuing to frack without restraint. DRBC must do its part to restrain the polluting fracking industry and the spewing of methane, the most powerful of greenhouse gasses on the all-important 10- and 20-year time scale.[3] In other words, we need to reduce greenhouse gas emissions today! And this is part of DRBC’s mission.

The climate crisis appears unrelenting as we face record-breaking heat waves, storms, fires, droughts and flooding, nationwide and globally. People are demanding an all-out offensive by leaders and all branches of government to fight climate change. To reach goals that scientists say we need - like 50% reduction of GHG by 2030 – decisive action at the regional and state level is more important than ever to move us away from polluting fossil fuels and towards clean renewables.

This is where you come in, Commissioners. The DRBC has recognized that climate change is directly affecting its water resources program.[4] 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 rise.[5]

Reports covering the specific impacts of climate change on the Delaware River, Estuary and Bay back up this conclusion. A 2019 report from Rhodium Group ranks Salem and Cape May counties among the 3 NJ counties that are expected to experience the highest increase in average annual damage costs due to changes in sea level and hurricane activity since the 1980s.[6] A Delaware Valley Regional Planning Commission report found that sea level rise would result in rising water levels in the Delaware Estuary, causing permanent change to the landscape and new flooding.[7] In an earlier DVRPC report, the study concluded that sea level rise over the next 100 years will inundate almost all of Pennsylvania's 1,500 acres of tidal wetlands along the Delaware, the salt line in the Delaware River will migrate further upstream (threatening Philadelphia and South Jersey’s drinking water supplies), and pollutants in contaminated sites could be released into estuary waters.[8]

Will DRBC allow the fracking industry to take advantage of the Delaware River watershed to get rid of its polluting wastewater and deplete our water by fracking, all the while emitting climate-killing methane? Or will DRBC do the right thing by prohibiting this abuse?

Here in the Delaware River Watershed, our future hangs in the balance as you decide on final regulations regarding fracking wastewater and water operations in the Basin. We, the undersigned, ask you, the voting members of the DRBC, to revise the draft regulations to completely ban imports of fracking wastewater and exports of water for fracking, to protect the public, water supplies, the watershed’s ecosystems, and to help alleviate the climate crisis.

[1] https://www.fractracker.org/2019/10/want-not-waste-not-fracking-wastewater/

[2] The supersized gas wells being drilled today in the Marcellus and Utica shale formations use 10-20 million gallons of water per well. According to FracFocus data, the average well in Pennsylvania’s Marcellus Shale used 11.4 million gallons in 2017, up from 4.3 million gallons reported by agencies in 2011. This means not only more water is needed to fracture the extended horizontal well bores but also means there are greater volumes of wastewater produced by these wells - between 1-1.5 million gallons of wastewater (for 10 M gallons of water used in fracking a well), increasing the volumes many times over the amount typically produced previously in Pennsylvania. FracTracker Alliance Issue Paper, “Potential Impacts of Unconventional Oil and Gas on the Delaware River Basin”, March 20, 2018. Main Author: Matt Kelso. https://www.delawareriverkeeper.org/sites/default/files/FT-WhitePaper-DRB-


[3] Natural gas is primarily methane, a greenhouse gas 86 times more efficient at warming the atmosphere than carbon over a 20-year time frame (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) and its effects persist for hundreds of years (http://www.pnas.org/content/early/2017/01/03/1612066114.full) The well documented vented and fugitive losses from natural gas systems contribute to atmospheric warming; current technology and practices have not controlled these releases.

[4] https://www.nj.gov/drbc/library/documents/Res2019-08_EstablishesACCC.pdf

[5] https://www.epa.gov/climate-impacts/climate-impacts-water-resources

[6] RHODIUM GROUP, “NEW JERSEY’S RISING COASTAL RISK”, October 2019. p. 2 https://rhg.com/wp-content/uploads/2019/10/Rhodium_NJCoastalRisk_Oct2019final.pdf

[7] DVRPC, Coastal Effects of Climate Change in Southeastern PA, Introduction and Project Background, November 5, 2019. https://www.arcgis.com/apps/MapSeries/index.html?appid=8080c91a101d460a9a0246b90d4b4610

[8] DVRPC, “Sea Level Rise Impacts in the Delaware Estuary of Pennsylvania”, Product No.: 04037, 6/2004, Abstract. https://www.dvrpc.org/Products/04037/