Plan needs seven steps to ease flooding
Thursday, February 21, 2008 11:46 AM EST

Richard Green of Lambertville

The Delaware River Basin Commission has proposed two plans — the Flexible Flow Management Plan and REV 1 — both of which are unacceptable to those of us affected by Delaware River flooding.
The plans regulate the three Delaware River basin reservoirs and how they are operated, specifying capacity levels that affect downstream flooding.

The DRBC’s Flexible Flow Management Plan, which is temporarily in place, calls for 100 percent full reservoirs by April 1 with provisions for the reservoirs to remain full until July 1. This is not acceptable!

Seven issues where progress must be made are:
New York City must optimize its entire water system. It must stop the “yo-yo” diversions that are causing alternating manmade “flooding” with “artificial drought” conditions.

Because the three reservoirs contributing to Delaware River flooding are managed by the City of New York, the city has put its needs first. And it has persuaded the Delaware River Basin Commission and its commissioners to do the same, to the detriment of everyone living below the three reservoirs.

It is time for New York City to optimize its entire 580-billion-gallon water system. Today, the non-normalized operation of the New York City water system renders the Delaware River Basin Commission’s proposed release schedule under its FFMP irrelevant.

Without an overhaul of the entire water system, we will continue to experience the unending cycle of alternating flooding with “declared” droughts.

The DRBC has a duty, as declared by Congress, to ensure that New York City’s operation of its reservoirs do not harm the lower basin state communities. Today, sadly, this is not the case.

• Safety voids of 20 percent need to become part of Delaware River reservoir operating policy until their definitive analysis is completed.

The DRBC’s Flexible Flow Management Plan is based on the ineffective oasis model for flood modeling.
Sound public policy requires we wait until a fact-based model, called the Delaware River Basin Flood Analysis Model, is completed before enacting the provisions proposed by the DRBC in the FFMP.

In the interim, for public safety, we must have “safety voids” in the reservoirs of at least 20 percent to ensure heavy rain and snow thaw do not result in more tragic floods.

• A full New York City water system wide reassessment — based on actual “usage” and not perceived “need” — must be undertaken.

Many have concluded the DRBC favors New York City in its rule making.Consequently, the DRBC’s Flexible Flow Management Plan contains a greater emphasis on New York City’s possible next “drought” rather than on Delaware River “flooding.”

Yet, it is quite clear a drought is unlikely to affect New York City’s water supply.New York City today can satisfy the water needs of 11 million people — more than its total population of about 8.5 million. And New York City’s daily water consumption is about the same as it was in 1946 — about 1.1 billion gallons a day.
With conservation and an overhaul of its entire water system, New York City can easily accommodate population growth and cyclical droughts. A full New York City water system wide reassessment, based on “usage” and not “need” must commence without delay.

• The DRBC must protect the lower basin water supplies and safeguard against the salt line intrusion moving up the Delaware River.

The DRBC’s proposed Flexible Flow Management Plan rescinds New York City’s responsibility to maintain the flow of water at the Montague and Trenton gauges, thereby jeopardizing a healthy flow of the river.

This take-away may result in “salt line” intrusion, which will affect the water intake vales of the Philadelphia Water Department. The DRBC has not commissioned engineering studies to prove removal of this mandate will not jeopardize Philly’s water supply.

This action is reckless — especially given the over-abundance of water in the New York City system.

• Informational workshops need to be held so the needlessly confusing and complex changes can be reviewed by all stakeholders in detail.

These workshops need to be held in each of the five sections of the river — tailwater section, upper section, midsection, lower section and estuary section — on a Saturday so people who work regular hours can attend.
After the workshops are held, a set of public hearings need to be held; one in each section of the river and again on Saturday.

To maintain a transparent, fair and open process, the DRBC must hold additional public hearings for oral testimony after the informational workshops have been held.
These hearings should be held at locations that are easy to get to and within the five Delaware River sections on weekend days.

The DRBC is proposing so many changes as to how the river is to be managed that public education is critical. The new provisions need to be understood by everyone in a format that can be easily grasped.

• The public must reject the proposed “additional storage” that is included in the Flexible Flow Management Plan.

The DRBC must reject additional storage that is being proposed for the reservoirs. Neither the FFMP nor REV 1 is okay. The FFMP allows for additional reservoir storage without the requirement of a mandatory environmental impact study.

Also, a five-year study completed in 1982 concluded additional storage was not economically or environmentally feasible.

Any clause that talks about additional reservoir storage must be removed from any plan the Delaware River Basin Commission wishes to adopt.

Finally, the DRBC must be made to comply with the governors’ request that it include a basin-wide flood management plan in the FFMP for all reservoirs.

This plan would coordinate emergency actions and release schedules for all Delaware River basin reservoirs during flooding events. Without such a plan, the lives of all who live in the Delaware River basin are at risk.

Richard Green
Lambertville _