It is vitally important for Pennsylvania to have effective policy standards for the discharge of total dissolved solids. However, we really need to rethink our approach to clean water regulatory law. Clean water is one of our fundamental assets for a healthy environment and a positive quality of life for our communities. Our groundwater, rivers, and streams should not be viewed as easy unlimited waste disposal systems. I serve on several boards of directors alongside astute, successful business leaders. I hear their concerns that Pennsylvania appears to give preferential treatment to the oil and gas industry. From my direct involvement in the planning, design, development, and operation of the Lycoming County Landfill leachate management liner, lagoon, and leak detection monitoring system, I am aware of the PA DEP municipal waste facility design standards. The entire landfill was required to excavate all deposition area and compact it to a smooth surface with a system of perforated pipes under the double-lined 100 mil HDPE liner draining to a system of sampling wells, to enable monitoring of any leaks in the liner and to enable the capture of any leaking leachate, draining it to a doublelined lagoon. Frac-flowback fluid impoundment

lagoons have no such standards. That equals preferential regulatory treatment for the natural gas industry.

When are we as a public, the PA General Assembly, our Governor, and governmental leaders at all regional, county, and municipal levels going to learn that the latent costs of pollution cleanup far exceed

the costs of responsible environmental management and pretreatment at point of generation? When are we going to take a lesson from our own Pennsylvania resource extraction history in coal mining—that pollution cleanup becomes a public cost long after the private enterprises which gained the profits

of resource extraction have ceased to exist? And that it costs far more to do the cleanup later and downstream than at point of generation or discharge?

Some natural gas companies appear to be changing their mode of handling frac flowback fluids to recycle and reuse in further drilling. Whether they are motivated by the pending TDS standards or just the sound

economics of recycling and reuse, it makes good sense to have TDS standards that incentivize that practice.

I believe strongly in our American free enterprise system! Free enterprise does NOT mean a license to pollute. We do have plenty of socially responsible and environmentally responsible private companies that

pay their way as they go and help produce a healthy community. Other private companies do depend on a system of regulatory fairness and depend on having uncontaminated water available to them. Public water

supply systems, including both publicly and privately owned systems, also depend upon pollution-free groundwater and surface water. Otherwise, the cleanup needed to utilize those water resources for public consumption equals a cost transfer from polluters to public consumers. Jerry S. Walls’ career in public-sector community and county planning has spanned some 45 years working at the state, city, and

county government levels in Maryland, Michigan, and Pennsylvania. He is a professional planner certified by the American Institute of Certified Planners. This article was adapted from his testimony before the Pennsylvania Environmental Quality Board regarding standards for total dissolved solids.