Susquehanna River Basin Commission

recommended that projects initiate renewal 

activities to allow time for a Plan or Waiver 

to be prepared, submitted, reviewed, and 

approved with sufficient time to prepare and 

submit the groundwater withdrawal 

application by the 6-month deadline. In 

the case of Plan submittal, additional time 

would also be needed to implement the Plan 

to complete the necessary testing before 

application submittal.

WHAT ARE COMMON 

DATA GAPS?

Some of the most common data gaps for the 

desired renewal rate are surface water 

monitoring, such as springs, streams and 

wetlands, as well as impacts to other users. 

For projects with usable historical data and/

or testing, supplemental operational testing 

may be the solution to collecting data to fill 

the gaps. The Commission has developed 

companion fact sheets that describe 

operational monitoring and water level 

monitoring, and how those can be used to 

By regulation, renewal 

applications need to be submitted 

to the Commission at least six 

months prior to the expiration 

date of the approval.

support a renewal application. Commission 

staff is available to assist projects in 

identifying and evaluating data gaps and 

options for resolving those gaps.

TWO-STEP PROCESS

For most projects, submitting a renewal 

application is a two-step process involving a 

Plan or Waiver (Step 1), followed by a 

groundwater withdrawal application (Step 

2). However, some projects may have 

already satisfied Step 1 and can proceed 

directly to Step 2. The Commission has 

been reviewing and approving aquifer 

testing plans for many years, and some 

projects undergoing the renewal process may 

have already satisfied the requirement to 

complete a Commission approved test. For 

those projects, submittal of a Plan or Waiver 

is not required and those projects may begin 

with Step 2. Projects should begin to 

assemble the data available early to help STEP 1

Approved Aquifer 

Testing Plan or 

Waiver

STEP 2 Renewal 

Application

This fact sheet is the first of a series of fact sheets intended to assist project sponsors with the 

Commission’s groundwater project renewal process. Each fact sheet can be used and reviewed on 

its own, but the combination of fact sheets provide a greater understanding of the Commission’s 

renewal process. Please reference the Water Level Monitoring and Operational Monitoring and 

Operational Testing fact sheets for additional information. 

GROUNDWATER PROJECT 

RENEWAL PROCESS

Susquehanna River Basin Commission n 4423 N. Front Street n Harrisburg, Pennsylvania 17110 n (717) 238-0423 n srbc.net

January 2021

BACKGROUND

Commission regulations establish project 

approval terms, including expiration dates 

and renewal application due dates. Projects 

are required to submit information and data 

for Commission review to demonstrate the 

continued sustainability of the withdrawal 

and to evaluate ongoing or potential impacts 

to other users and the environment. By 

regulation, renewal applications need to be 

submitted to the Commission at least six (6) 

months prior to the expiration date of the 

approval. However, because the renewal of 

an approval is a two-step process, 

preparation should begin well before the 

6-month renewal deadline. How early a 

project should start preparing information 

for a renewal application depends on 

availability of historical aquifer testing and 

monitoring data and if data gaps exist. For 

projects with minimal available data or 

potential data gaps, it is recommended that 

they contact Commission staff as early as 

five years prior to expiration to discuss 

actions that can be taken to gather data 

during normal operations. 

The typical and preferred order of 

preparation would be that an aquifer testing 

plan (Plan) or aquifer testing waiver be 

submitted, reviewed, and approved by staff. 

Once the Plan or Waiver is approved by 

staff, a groundwater withdrawal online 

application for that source will automatically 

be made available. Therefore, it is (continued on next page)
GROUNDWATER PROJECT RENEWAL PROCESS

2 Susquehanna River Basin Commission

Step 2: Renewal Application

Submittal of the groundwater withdrawal 

renewal application is required 6 months 

prior to the expiration of the approval. 

Provided that an application is submitted by 

the 6-month deadline, the existing approval 

is automatically extended and the project can 

continue to operate in accordance with the 

existing approval until the Commission acts 

on the renewal application at a quarterly 

Commission meeting. Please be aware that 

submittal of a Plan or Waiver does not satisfy 

the 6-month renewal application deadline. 

Projects with Previously Approved 

Aquifer Tests

A project with a previously approved Plan 

should prepare and include a summary of the 

results of previous testing with the renewal 

application. The project should also use 

operational monitoring data to assess how 

the aquifer and well are performing in 

comparison to how performance was 

predicted with the prior test results. Because 

nearby features may have changed since the 

test was done or critical features (e.g. surface 

water) were not monitored, data gaps may 

exist that would not allow the Commission 

to fully evaluate the project to current 

standards. For these projects, supplemental 

operational monitoring or testing may be 

needed.

Projects without a Previously Approved 

Test

The Commission prefers that projects use 

existing data as much as possible to support 

the renewal process while minimizing or 

avoiding new testing when appropriate. 

Many projects have historical testing results 

or prior waiver submittal that can be used to 

evaluate the aquifer, have been collecting 

useable operational monitoring data, and/or 

determine how Step 1 can be completed, or 

if the project can proceed directly to the 

renewal application under Step 2. Projects 

with previously approved aquifer tests 

should contact Commission staff for 

verification that a Plan or Waiver is not 

needed.

Step 1: Commission Approved Aquifer 

Testing Plan or Waiver

Commission regulations require project 

sponsors to perform a constant-rate aquifer 

test for collection of data to support a 

groundwater withdrawal renewal 

application. Project renewals can meet the 

aquifer testing requirement by meeting one 

of the following:

1. Demonstrate that the aquifer testing 

was completed in accordance with a 

Plan previously reviewed and 

approved by the Commission and 

the results of testing were provided 

with the original or prior 

application;

2. Submit a Plan for review and 

approval, implement an approved 

aquifer test and submit a 

hydrogeological report providing the 

data; or 

3. Prepare and submit a Waiver request 

that utilizes existing and, as needed, 

supplemental data, for Commission 

review and approval. 

Regardless of which option is chosen, the 

standard for review remains the same. The 

Commission evaluates the sustainability of 

the withdraw as well as impacts to other 

users and the environment. For some 

projects, historical testing and operational 

data may be sufficient. However, projects 

not collecting operational data, having 

limited historical data, or having other data 

gaps, may need supplemental operational 

monitoring or testing to support a Waiver 

request. See the Commission’s Water Level 

Monitoring Fact Sheet and the Operational 

Monitoring and Operational Testing Fact 

Sheet for additional information. 

have time to complete supplemental 

operational monitoring or testing, if needed, 

to fill in data gaps to meet current standards 

and a Waiver may be supportable. 

However, the Commission also realizes that, 

in some cases, aquifer testing may be needed 

because historical testing or prior waiver 

submittal was either not completed, was 

incomplete, does not provide necessary data 

to evaluate the well or the current conditions 

within the aquifer, the project has not been 

collecting useable operational monitoring 

data, or the project does not have sufficient 

time to collect useable operational 

monitoring data to support a renewal at the 

requested rate. Commission staff is available 

to assist projects in selecting an appropriate 

renewal pathway.

Other important references:

5 Water Level Monitoring Fact Sheet

5 Operational Monitoring and 

Operational Testing Fact Sheet

5 Online Application Instructions

5 Online Waiver/Plan Templates

5 Online Application Functional 

Template

5 Aquifer Test Guidance

Questions & Additional Information

If you have any questions or would like to 

request a free pre-application consultation, 

please contact the Commission’s Manager of 

Project Review at 717-238-0423.

...submittal of a Plan or Waiver 

does not satisfy the 6-month 

renewal application deadline.