SRBC Grandfathered Water Use Registration Guide

Susquehanna River Basin Commission (SRBC) Grandfathered Water Use Registration Guide

From the desk of Katie Cirone, PE

The Susquehanna River Basin Commission (SRBC) recently completed a study where it was revealed that up to one billion gallons of water used in the basin per day is not under SRBC oversight. To rectify this issue, grandfathered water uses must register with SRBC by December 31, 2019 in order to preserve their grandfathered status and avoid obtaining an approval in the future. SRBC is an interstate agency that covers parts of New York, Pennsylvania, and Maryland, and operates independently of the environmental agencies in these states.

What is a grandfathered water use?

SRBC regulations state that certain water uses that are in excess of the regulatory thresholds do not require approval if those activities predated applicable regulations, provided there is no environmental harm. The type of water use, regulatory threshold, and effective date of regulations are summarized below:

Type of Water Use	Regulatory Threshold (gallons per day)	Effective Date of Regulation
Consumptive Use	20,000	January 23, 1971
Groundwater Withdrawal (onsite wells)	100,000	July 13, 2978
Surface Water Withdrawal	100,000	November 11, 1995

How do I know if my facility is considered a grandfathered water use?

If a consumptive use or withdrawal was initiated prior to the effective date of regulation and exceeds the regulatory threshold volume listed above, then your facility is considered a grandfathered water use and must register with the SRBC. If your facility has an existing approval issued by the SRBC, you must still register any grandfathered sources.

The regulatory threshold volume is determined by summing the actual daily withdrawal or consumptive use over the peak consecutive 30-day period from the past five years, then dividing by 30. If that number meets or exceeds the regulatory threshold, then your source must be registered with SRBC.

What is a consumptive water use?

Consumptive use is defined by the SRBC as the loss of water due to transpiration by vegetation, incorporation into products, evaporation, injection of water or wastewater into the subsurface, or any other process by which the water is not returned to the waters of the basin undiminished in quantity. This applies to all incoming water sources, including surface water or groundwater withdrawals, stormwater capture, or public water supply. If your facility is taking in more water than it is discharging, then it is considered a consumptive use.

The simplest calculation for consumptive use is the difference between metered inflow to the facility and metered outflow from the facility. Common consumptive uses include cooling towers for power generation, commercial, or institutional use; steam vented during a manufacturing process; and incorporation of water into final products.

How do I register my facility?

Registration of a grandfathered water use is completed online and requires submission of the following information and a $1,000 registration fee.

• Basic information about the facility and its water sources
• The method of tracking or metering quantities of water
• Historical withdrawal and/or consumptive water use quantity data

What happens after I register my facility?

After you register your facility as a grandfathered water use, SRBC will ensure that your facility will maintain the existing exemption from project review and approval moving forward. Your facility will be subject to annual reporting of the water use once registration is completed.  At this time, there is no ongoing annual fee for registered sources.

What if I don’t register my facility?

If you neglect to register a grandfathered water source on or before December 31, 2019, the facility loses its exemption from SRBC review and approval. A formal application will have to be submitted to SRBC for review, and the source will be subject to all SRBC rules and regulations.

To speak with an experienced environmental permitting consultant, please call us at (800) 305.6019.