~ Water Resources Association ~

Water Resource Associations of the Delaware River Basin

Jan '08

WRA Comments on the Flexible Flow Management Plan

The following letter was submitted to the Delaware River Basin Commission:
Dear Ms. Schmitt

DRBC and other organizations have done an admirable job working with various agencies and interests in the basin on a Flexible Flow Management Plan (FFMP) for the New York City Reservoirs.

In addition, the recommendations of the Interstate Flood Mitigation Task Force Report that deal with improved flood plain mapping, targeting of public land acquisition to properties prone to flooding, and improved management of future development on and in flood plains, are all reasonable and commendable. However, the following statement in the draft report is troublesome.

"Three major main stem floods between September of 2004 and June of 2006 have focused attention on the potential management of the basin's major reservoirs for additional flood mitigation. The reservoirs include the U.S. Army Corps of Engineer's five projects that were designed to maintain dedicated flood storage capacity, and other major reservoirs not specifically designed for flood control, including water supply reservoirs, hydropower reservoir, and reservoirs used primarily for recreation. There is a need to evaluate all of these reservoirs to develop plans in advance to minimize their total discharge (spills plus releases) during flood conditions."

Without detailed studies that incorporate the timing of large -scale rainfall and snowmelt, and routing through the stream systems, it is difficult to estimate the benefit achieved if any from lowering the levels of the reservoirs to provide flood protection. It is of concern that these releases will impact the ability of reservoirs to serve their intended functions. Especially in the face of severe droughts in Florida and Georgia, this reality should be clearly recognized and responsibly communicated to the public and policymakers. In advancing the Task Force Report recommendations. Simply stated trading off available water supplies for flood control benefits will increase the risk of potential water supply shortages. Neither of these potential benefits or risks have been evaluated to the point where it is known whether a tangible benefit can be realized, nor what the risks are to our water supply. The rights of all parties with interest in reservoir storage reserved or constructed for purposes of water supply, flow augmentation, power generation, or recreation must be honored and preserved. Further, continued evaluation of how much flood control benefit would be realized, and more importantly where no benefit could be expected is advised.

In addition to these comments we offer the following:

Drought occurrence- The Decree Parties stated their intent in devising the FFMP was to avoid increasing the occurrence of drought conditions, as defined by the Water Code. We have not seen data to show whether this objective was met.

Reduced river flows- The FFMP would reduce the flow objective at Montague during drought emergencies, especially when salinity conditions are most adverse. This seems contrary to long-standing Commission policy to manage river flows to prevent salinity encroachment. The water purveyors with intakes in the lower basin are very concerned about decoupling the Montague target and its affect on the salt line for their intakes. Their commenting letters describe this issue in detail and I will not reiterate them. Inasmuch as this is a critical issue, we strongly recommend that the models or computations used to determine that salt intrusion is not the issue it was once was and that you consider it be examined by a third party.

Montague objective- Is the intent during drought emergency that the reductions to the Montague flow objective would be offset by increased releases from the Lower Basin reservoirs? If so, is this practicable especially in light of limited storage and recreational use of the Lower Basin reservoirs? If river flows during drought emergencies indeed will be reduced, will this affect dischargers who rely on certain flows to comply with the provisions of their discharge permits?

Economic impacts- We have not seen quantification of either the benefits (reduced flooding) or the costs (reduced water supply) of the proposed discharge mitigation element of the FFMP to judge whether discharge mitigation is a viable economic alternative.

Additional water storage- We believe the parties, including New Jersey, should firmly commit to new flood control storage before the FFMP is put into effect.

Flooding Study – We believe that river model studies of the Delaware River and its reservoir system be continued to determine how effective flood control can be achieved evaluating all alternatives to include other needs for water supply and reservoir level management. An external independent review panel could be maintained as a check.

Public comments- We realize that DRBC and other agencies have been severely criticized for not “clamping down” on reservoirs water supply, release and storage issues. We are very confident that the best resolution will be achieved by a collaborative effort of all parties involved that have technical knowledge of this subject and that decisions will not be swayed by uninformed public outcry. Outreach to the public must continue.

We thank again for all your hard work in this area. Thank you for consideration of our comments.

Sincerely,
Dennis Palmer, Chairman