FUDR PROPOSAL- THE CORRECT SOLUTION.

To the Editor:

Management of the Upper Delaware watershed has long been questioned by natural resource advocacy groups, particularly by members of the trout fishing community, and most especially by the Friends of the Upper Delaware River. However, the massive personal and public damage caused by flooding and the recently revealed independent scientific studies have caused a severe embarrassment to the Delaware River Basin Commission. Public outcry has forced the Commission to reconsider its recently proposed Flexible Flow Management Plan (FFMP). An alternative approach, the CP2 submitted by the “Conservation Coalition”, shows that using the same DRBC modeling and criteria, the average cold water releases from the Cannonsville Reservoir could be 50 per cent higher than those incorporated into the FFMP with no statistically significant increase in the risk of drought. Of course, neither the FFMP nor the CP2 address flood mitigation. In fact, they call for a full reservoir June 1 (only days prior to the date of the worst flood in recent Upper Delaware history).

The public outcry has greatly intensified the scrutiny of the DRBC and its management criteria. The alternate independent plan (the CP2) offers some token improvement to the ecology of the Upper River. Its authors, the so-called Conservation Coalition, attempted to cooperate with the DRBC so that failure to adopt the CP2 plan would make the DRBC and all parties to the Decree appear committed to a scientifically irresponsible course of action. However, even members of the Coalition have suggested that the DRBC’s guiding criteria (the OASIS Model and the DRBC’s drought curves) should be carefully revisited and that more appropriate criteria would show that there is much more water available.

The Coalition’s work succeeded in demonstrating the obvious fact that the DRBC is interested only in hoarding water for New York City. (Why else would the agency suggest a 250cfs release when its own model indicates that at least 350 cfs are available?)

However, the key point to keep in mind is that both the FFMP and CP2 fail to protect the trout fishery and afford virtually no flood mitigation benefits. In fact, the only plan presented so far that does address these critical issues in a meaningful way is the Void/Graduated Release Plan put forth by Friends of the Upper Delaware.. As the facts unwind, it becomes increasingly clear that serious independent studies need to be initiated to develop proper modeling tools and more realistic drought curves – something that all parties appear to agree. Meanwhile, the DRBC has many unanswered questions in spite of multiple public fact finding meetings:

Its OASIS updates appear at first glance to involve only token additions of data and various pieces of software. Are its models agenda driven to minimize the amount of available water? Has the real formula changed since its inception in 1981? The drought curves appear untenable and have remained the same for years.

New York City diverts about half of its allotted water of 800 million gallons per day from the Catskill Reservoirs and sells 25 per cent of that leaving about 40 per cent for daily use. This does not include that wasted by known leaks in the aqueducts feeding the city.

The difference between this allocated use (approximately 800mgd) and the actual diversion is about 350mgd. However, for data submission only 35 mgs is used for convenience purposes. The remainder is unused

Even with this amount available, the modeling is based on an anticipated use of 786 mgd (170 percent of actual use). What happened to the remaining water?

Rondout reservoir (49.6 billion gallons) has been conveniently eliminated from the formula, presumably because it cannot return water to the Delaware watershed and it is used a mixing basin for water quality. Is it still designated as storage?

Environmental modeling shows an increase in habitat with both the FFMP and CP2. However, neither plan would produce the massive potential increase to be expected given the greater amounts of water believed to be available. What amount would be necessary to maximize the habitat not only in the West Branch of the Delaware but in the Upper Main Stem?

The Montague targets have been increasingly met with releases from Lake Wallenpaupack. Doesn’t this mean that more water is available from the Cannonsville Reservoir to maintain the health of the fishery?

The more one studies the situation the more obvious it becomes that large amounts of water are being wasted. This means that the wild trout fishery on the Upper Delaware is being threatened for no good reason and that property owners are being unnecessarily exposed to the risk of devastating floods that could be eliminated or substantially mitigated given a more enlightened management regime. Friends of the Upper Delaware has proposed a regime that (1) would address the problems created by the DRBC’s reliance on faulty criteria to justify a failed management scheme and (2) would do so without penalizing any of the River’s various constituencies. In years of very low rainfall, curtailments would, of course, be needed. But the burden should be borne by all the River’s users not just the fishing and ecological interests and the local economies along the River’s banks

It is time to hold the DRBC accountable for its indifference to so many of the River’s constituencies. Significant (not mildly ameliorative changes) are long over-due and should be made as soon as possible. In spite of being a four state organization, the Delaware River Basin Commission has long been a culture of New York City advocates and has done nothing to significantly promote the Down River needs or to even explore the potential of proper water management.

Sincerely,
Dr. Peter Bousum
The FUDR Plan provides real relief for real people; a graduated release, more cold water when there is plenty of water to give and less when the water levels in the reservoirs are reduced without jeopardizing any of the users rights. What could be simpler! See the FUDR Plan at www.FUDR.org. The Executive Committee Friends of the Upper Delaware River

Dan Plummer, Chairman
And Executive Committee
Friends of the Upper Delaware River