Mr. Richard A. Cairo
Susquehanna River Basin Commission
1721 N. Front Street
Harrisburg, PA 17102-2391

Re: Proposed Rulemaking, 76 F.R. 41154, July 13, 2011

Dear Mr. Cairo : Lehigh Valley

Clean Water Action is writing today to request an extension of the comment period for the SRBC's proposed rulemaking, which redefines the scope of Approvals by Rule and streamlining the process around recycling wastewater. We would like to support the calls
of other environmental organizations in requesting thirty additional days to review the implications of these rules.

On the face of it, we applaud the SRBC's stated goal to increase the use of recycled water. That said, we do not believe the Commonwealth is ready for administrative approvals of produced or flowback water in stimulating new well sites. We do not believe the PADEP has protocols in place to reliably insure that "water is handled in a manner that isolates it from the waters of the basin." In fact, reporters at the Times¬Tribune have found not only that spills of water used in hydrocarbon drilling is common, but that the contaminants in the water are often a mystery to the regulators attempting to manage clean¬ups. Further, we are persuaded by the research of Prof. Boufadel, of Temple, that spilled flowback water may behave differently once spilled and take much longer to detect in groundwater than other spilled fluids. Caution, not haste, is in order here.

Until there is a reliable system to track water and chemicals from withdrawal to disposal and adequate regulations to insure secure transport of this very contaminated waste, it is much too early to approve transfers of water administratively.

Further, we have made it our mission to make democracy work for environmental policy. It is still too early in the Marcellus Shale Play's development to begin making new projects, discharges, withdrawals and disposal routine. We are not ready to increase the scope of Approvals by Rule. As it stands, Clean Water Action does not support any increase in the expansion of administrative permits. The public needs a chance to weigh in. Please grant a 30 day extension while we and other environmentalists can consider these important matters more fully.

Best,

Brady Russell Eastern Pennsylvania Director

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