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| February 17, 2007
Ms. Carol Collier Executive Director Delaware River Basin Commission Dear Ms. Collier, I am writing in the hope that you will help us better understand the rational for the often cited argument that increased reservoir releases for the upper Delaware’s wild trout fishery would heighten the risk of drought and/or the number of days “in drought” to the City of New York. It is our impression that the drought curves that govern releases from the Delaware reservoirs were NYC versions of less stringent curves offered by the DRBC. Whatever their origin, however, it is our further impression that the curves in use have not been validated scientifically, and we wonder why not. While FUDR would not support an action that would realistically increase the risk of the City’s experiencing a drought, the existing curves do serve as a limiting influence – a “cap” if you will – to the volume of water that can and will be released for the protection and enhancement of the River’s fishery and aquatic insect life. A “cap” at some level is entirely appropriate. However, as noted above, the currently employed drought curves have not been scientifically validated and are widely held to be far more conservative than necessary. For example, the USGS scientist in charge of the DRBC sponsored Delaware River flow modeling study stated publicly (at a meeting of a DRBC subcommittee responsible for recommending reservoir releases) that the curves were too conservative and needed to be revised. Adding to our confusion is why the drought curves do not include the Rondout Reservoir (capacity of 49.6 billion gallons drawn almost exclusively from the three Delaware reservoirs). Rondout is maintained at or near capacity, and its water is dedicated for NYC usage. At current City usage levels, Rondout, taken by itself and with no credit for refill, could sustain the City for some seven weeks without invoking any water conservation measurers. Why is this considerable storage not included in the current drought curves? Notwithstanding the foregoing, it does seem that objective, scientifically based drought curves are, or should be, requisite not only for the fishery, aquatic insect life and related ecology, and the regional economies, but also, in these unnerving times, for the residents of the City of New York. We would think that City officials would find fact based, scientifically developed drought curves an absolute necessity as would residents and public officials within the watershed who are still struggling to develop effective flood mitigation practices since the amount of reservoir storage is a key factor in mitigation. We’re aware, of course, that the New York City DEP exercises its influence within the DRBC; however, we also recognize that the DRBC is the federally constituted regulatory agency responsible for the Delaware. And we realize that while the DRBC has undertaken a number of worthwhile studies, at a cost of millions of dollars, no studies have been commissioned to scientifically determine exactly what the drought curves should be – a paramount environmental concern that is decades old. We are hoping that you could give us some idea of when the DRBC will be commissioning an objective, scientifically based study of the drought curves? Carol, in conclusion, your help in answering our questions would be greatly appreciated. Sincerely Yours, Craig Findley President Friends of the Upper Delaware River |
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| FUDR :: 1148 5th St., New York, NY 10128:: email: catskilldan@mac.com :: 607-363-2001 | ||||||||||||