Watershed Wednesdays – Week 3

Welcome to Watershed Wednesday #3

December 29, 2021

Each week, the Delaware River Frack Ban Coalition Organizing Committee will focus on a different aspect of the DRBC draft regulations pertaining to the import of wastewater produced by fracking and the export of water from the Delaware River Watershed for fracking outside of the Basin. (email for coalition: DRFrackBan@gmail.com) The public comment period is open now and will close February 28, 2022.

To comment: Go to the DRBC online portal, fill in the form and cut and paste some or all of these suggested points into the template, adding a line about your personal interest in a full ban. Alternatively, you can write your own comment and insert it or attach a document. Personalizing your comment is always the most powerful; it’s best to put the sentences that are in your own words FIRST. Make certain that you review your submission when prompted and click the final button that delivers your comment. You should receive a delivery receipt from DRBC.

Each week, the Watershed Wednesday from the prior week is added to a public google doc. In case you want to comment using a past topic or get references we have provided, you can get access here: http://go.pardot.com/e/176172/3siWvcN/wzny6/276579019?h=NuxnfdKWZlhR1ijyrthr1OS5OW-k7SxlRR26PHY__c4 The materials can be copied and are there for your use. AND remember you can make as many comments as you want!

Go here to submit a comment: http://go.pardot.com/e/176172/-id-x2K8A/wzny8/276579019?h=NuxnfdKWZlhR1ijyrthr1OS5OW-k7SxlRR26PHY__c4

This week’s comment examines the climate effects of the proposed regulations. The importation into the Delaware River Watershed of wastewater produced by fracking satisfies the fracking industry’s acute need for a dumping ground for its toxic and radioactive wastewater. The industry has been pushing to get their foot in the door here in the Delaware River Basin so they can have a convenient location to get rid of their growing glut of wastewater. DRBC has denied permits for fracking wastewater imports and disposal here for over 10 years. Now they are getting ready to open those floodgates. Additionally, it gives the industry a source of desperately needed water to which they didn’t have access due to the long-standing moratorium on water withdrawals for fracking in the Basin. What does this mean? It means more fracking in Pennsylvania, which damages public health and the environment and increases the emissions of the powerful greenhouse gas methane.

The development of natural gas digs the planet further into a hole, with methane exacerbating the climate crisis. The composition of natural gas is about 95% methane. Methane leaks or is vented or flared at all stages of the natural gas process (extraction/production, gathering, processing, transmission, storage, local distribution and consumption). Methane is 86 times more powerful than carbon at heating the atmosphere on a 20-year time scale, 104 times more powerful than carbon over a 10-year period. That’s more potent than the carbon emissions from coal or oil, cradle to grave. DRBC should not be taking action that props up the drilling industry and its unmitigatable greenhouse gas emissions, especially at a time when scientists and global leaders are warning that we must REDUCE our greenhouse gases by 50% by 2030 to fight the climate crisis.

Suggested Comment:

  • The DRBC recognized the importance of climate change to the Delaware River region and its water resources in December 2019 when it fformed the Advisory Committee on Climate Change. It highlighted that rising temperatures and sea level rise were already occurring and that one measurable effect was increased salinity in the Upper Estuary, threatening water supplies for millions in the Greater Philadelphia region and south Jersey. DRBC also projects on their website that future local impacts include “increased temperature, changes in precipitation patterns, and sea level rise, all of which affect water supply and water quality.” However, you are proposing to allow the importation of wastewater produced by fracking and the export of water to enable fracking outside of the Delaware River watershed. These allowances will induce more fracking because it will allow them access to water supplies for their water-intense depletive use to frack wells. It will also help them to avoid any holdup in their forward march for fast fracking by solving their current dilemma of too much waste to manage or dispose properly. DRBC, the result of granting this to the industry will be increased fracking and the resulting release of the powerful greenhouse gas methane. Recent scientific reports, including the IPCC 2021 Working Group Report, warns that we must not only stop but must REDUCE greenhouse gas emissions to keep the atmosphere from warming past critical meltdown. Rules that ease the way for fracking will work at cross-purposes with your and our nation’s efforts to stem sea level rise and rising temperatures from climate change that pose such grave threats to our watershed’s water resources. I urge you in the strongest possible terms to categorically ban the import of fracking wastewater and the export of water for fracking if you want to be part of the solution, not part of the problem. See Reference #1.
  • The Delaware River Watershed is already experiencing the effects of climate change and is one of the most impacted regions in the nation due to rapid river level rise, sea level rise, sinking land mass, and the onslaught of storm surges with violent weather patterns. More intense and frequent extreme weather events, together with trends in coastal development, will increase expected annual flood damages by 2-3 orders of magnitude by 2100. A recent New Jersey report by Rhodium Group shows that the Delaware River’s impacts from climate change include more hurricane-force wind damage and flooding, and increases in building damage from rising tidal waters. The economic impacts are mounting each year and we can expect a crippling effect as the frequency and severity of storms accelerates. DRBC, this economic damage is being born by the residents and workers of the Delaware River region, with some of the highest levels of danger in Salem and Cape May Counties. The livelihood and sustainable economy in the Bay region are in grave danger of collapse if these harms continue as expected. By playing a part in accelerating greenhouse gas emissions for fracking, you are feeding the climate crisis and threatening to ruin our economy. I ask that you completely prohibit the import of fracking wastewater and the export of water to fuel fracking. See Reference #2.
  • The damage to ecosystems and the living resources of the Delaware River Watershed is expected to be transformative, and not in a good way. Scientists report: almost all of Pennsylvania’s tidal wetlands will be inundated by sea level rise; the salt line will move closer to the Delaware River’s upstream water supply intakes in PA and NJ; contaminated sites will be compromised, potentially releasing toxic pollutants. Additionally, seasons are becoming less distinct, altering ecosystems and environments. This adversely impacts tourism, farming, forestry, and other nature-based economies. Furthermore, ocean, bay, and estuary habitats are being harmed by warmer ocean temperatures, sea level rise, and ocean acidification. Biodiversity is being impacted by migration of native species to new areas and the spread of invasive species, upsetting ecological balance. DRBC, do not let our watershed be used by the fracking industry so that fracking is accelerated and methane emissions speed us towards climate catastrophe. I request that you ban categorically the import of fracking wastewater and the export of water for fracking. Do your part, please, to tackle climate change right here in the Delaware River Watershed. Our natural world and ecosystems depend on you.
  • It is imperative that we, as a society, address greenhouse emissions if we are committed to tackling climate change, both here and globally. Both carbon and methane concentrations continue to increase in the atmosphere, caused by human activities, according to the 2021 IPCC report “Summary for Policymakers”. Natural gas systems emit more anthropogenic methane than any other source in the United States, and are the third highest source for carbon dioxide emissions nationally, according to the US EPA. Methane is 86 times more powerful than carbon at heating the atmosphere on a 20-year time scale, 104 times more powerful than carbon over a 10-year period. That’s more potent than the carbon emissions from coal or oil, cradle to grave. The key to quickly reducing atmospheric warming is the flip side of the methane coin. According to Dr. Howarth of Cornell University, the planet is going to continue to warm to 1.5 degrees C in 12 years and to 2 degrees C in 35 years or less unless we substantially cut methane emissions. He points out that the planet responds much faster to methane than carbon dioxide. There is already so much carbon in the atmosphere that the ONLY hope of meeting global climate targets is to address methane because that can quickly reduce greenhouse gases and slow the warming of the atmosphere. DRBC, it is urgently important that you do not allow fracking wastewater to be imported here or allow water to be exported for use in fracking, and I urge you to make that change in your proposed regulations. You have tremendous power in your hands because you can choose not to enable or induce fracking, thereby accomplishing what climate scientists are saying is the most influential action to combat atmospheric warming – preventing methane emissions.


Reference 1: Talking Point #8. See DRBC web page on climate change: http://go.pardot.com/e/176172/ams-flow-climate-change-html-2/wznyg/276579019?h=NuxnfdKWZlhR1ijyrthr1OS5OW-k7SxlRR26PHY__c4. See the IPCC Working Group I Report, Climate Change 2021: the Physical Science Basis, July 2021: “The report provides new estimates of the chances of crossing the global warming level of 1.5°C in the next decades, and finds that unless there are immediate, rapid and large-scale reductions in greenhouse gas emissions, limiting warming to close to 1.5°C or even 2°C will be beyond reach. The report shows that emissions of greenhouse gases from human activities are responsible for approximately 1.1°C of warming since 1850-1900, and finds that averaged over the next 20 years, global temperature is expected to reach or exceed 1.5°C of warming. This assessment is based on improved observational datasets to assess historical warming, as well progress in scientific understanding of the response of the climate system to human-caused greenhouse gas emissions.” http://go.pardot.com/e/176172/021-08-09-ar6-wg1-20210809-pr-/wznyj/276579019?h=NuxnfdKWZlhR1ijyrthr1OS5OW-k7SxlRR26PHY__c4

Reference 2: See IPCC, “Special Report on the Ocean and Cryosphere in a Changing Climate”, originally pub. 2019, at 6-3. Retrieved from http://go.pardot.com/e/176172/srocc-/wznyl/276579019?h=NuxnfdKWZlhR1ijyrthr1OS5OW-k7SxlRR26PHY__c4 

“The damage to buildings in all the counties along Delaware River tidal waters has increased due to climate impacts since 1980 according to the Rhodium Group study.  Mapping shows the greatest increases for the Delaware estuarine waters to be Cape May County (from 20.9% to 27% – both from the Delaware Bay and the Atlantic Ocean) and Salem County (12.5% to 15.3%).” The “increase in expected average annual loss, as a percent of county output, due to changes in sea level and expected hurricane activity since the 1980s” is greatest in Cape May, Hudson, and Salem Counties of all New Jersey counties, according to the Rhodium study. This is a significant cost for these two Delaware River Basin counties. See: RHODIUM GROUP, “NEW JERSEY’S RISING COASTAL RISK”, October 2019. Pages 2, 3, and 4. http://go.pardot.com/e/176172/NJCoastalRisk-Oct2019final-pdf/wznyn/276579019?h=NuxnfdKWZlhR1ijyrthr1OS5OW-k7SxlRR26PHY__c4

Reference 3: See the DVRPC report on sea level rise: “The study concludes that a three- to four-foot rise in sea level during the next 100 years will have a wide range of impacts. Rising seas will inundate almost all of Pennsylvania’s 1,500 acres of tidal wetlands. The salt line in the Delaware River will migrate further upstream, threatening Philadelphia’s drinking water supply. The pollutants found in contaminated sites may be released into estuary waters. Efforts to increase public access to the waterfront may be jeopardized by rising waters.” DVRPC, “Sea Level Rise Impacts in the Delaware Estuary of Pennsylvania”, Product No.: 04037, 6/2004, Abstract. http://go.pardot.com/e/176172/Products-04037-/wznyq/276579019?h=NuxnfdKWZlhR1ijyrthr1OS5OW-k7SxlRR26PHY__c4

In a NOAA Technical Report the impacts of climate change include: “Significant, direct impacts of long-term [relative sea level] (RSL) rise, including loss of life, damage to infrastructure and the built environment, permanent loss of land (Weiss et al., 2011), ecological regime shifts in coastal wetlands and estuary systems (Kirwan et al., 2010), and water quality impairment (Masterson et al., 2014), also occur when key thresholds in the coastal environment are crossed (Wong et al., 2014). National Oceanic and Atmospheric Administration, U.S. DEPARTMENT OF COMMERCE, National Ocean Service Center for Operational Oceanographic Products and Services, “GLOBAL AND REGIONAL SEA LEVEL RISE SCENARIOS FOR THE UNITED STATES”, NOAA Technical Report NOS CO-OPS 083, Silver Spring, Maryland, January 2017. Page 1.

The Fourth National Climate Assessment reports these near-term climate impacts on natural ecosystems in the Northeast region: “Less distinct seasons with milder winter and earlier spring conditions are already altering ecosystems and environments in ways that adversely impact tourism, farming, forestry, and other economies; warmer ocean temperatures, sea level rise, and ocean acidification threaten ocean habitats, ecosystem services, and livelihoods.” They also report negative impacts on biodiversity due to the migration of native species to new areas and the spread of invasive species, upsetting ecological balance. USGCRP, 2018: Impacts, Risks, and Adaptation in the United States: Fourth National Climate Assessment, Volume II: Report-in-Brief [Reidmiller, D.R., C.W. Avery, D.R. Easterling, K.E. Kunkel, K.L.M. Lewis, T.K. Maycock, and B.C. Stewart (eds.)]. U.S. Global Change Research Program, Washington, DC. Retrieved from http://go.pardot.com/e/176172/2021-12-29/wznys/276579019?h=NuxnfdKWZlhR1ijyrthr1OS5OW-k7SxlRR26PHY__c4 at 16.

Reference 4: Natural gas systems emit more anthropogenic methane than any other source in the United States according to EPA: EPA 2016, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2014. http://go.pardot.com/e/176172/gas-inventory-report-1990-2014/wznyv/276579019?h=NuxnfdKWZlhR1ijyrthr1OS5OW-k7SxlRR26PHY__c4. For greenhouse gas tracking see: IPCC Sixth Assessment Report (AR6)1, Working Group I Summary for Policymakers, Section A. The Current State of the Climate, 2021. At A.1.1, SPM-5. http://go.pardot.com/e/176172/report-ar6-wg1–SPM/wznyx/276579019?h=NuxnfdKWZlhR1ijyrthr1OS5OW-k7SxlRR26PHY__c4

“Methane is far more potent than carbon dioxide in contributing to climate change. That makes it particularly harmful to the environment when it is discharged into the atmosphere. In the U.S. alone, the methane that leaks or is released from oil and gas operations annually is equivalent to the greenhouse gas emissions from more than 69 million cars, according to a Wall Street Journal analysis using conversion formulas from the Environmental Protection Agency and emissions estimates for 2015 published last year in the journal Science.” Wall Street Journal, The Leaks That Threaten the Clean Image of Natural Gashttp://go.pardot.com/e/176172/age-of-natural-gas-11565280375/wznyz/276579019?h=NuxnfdKWZlhR1ijyrthr1OS5OW-k7SxlRR26PHY__c4.

For the key to reducing greenhouse gas emissions within the time frame we must if we’re to meet global climate goals see: Dr. Robert Howarth, Cornell University, “COP21 Reflections on the Historic Paris Climate Agreement”. http://go.pardot.com/e/176172/the-historic-climate-agreement/wznz2/276579019?h=NuxnfdKWZlhR1ijyrthr1OS5OW-k7SxlRR26PHY__c4.

Check out Watershed Wednesdays, Week 1 and Week 2 and submit comments on those topics too! Comment early and often!!