NYC Must Maintain the Supreme Court Decree Obligation of maintaining the Montague and Trenton Target River Flows.
 
 
As a Delaware River riperian landowner residing in Columbia,  Knowlton Township, Warren County, New Jersey, I am writing to the Commission regarding the Delaware River Basin Commission’s (DRBC) proposed Flexible Flow Management Plan (FFMP).
 
Part of the Supreme Court Decree of 1954 ensured that a certain flow level  be maintained at both the Montague (NJ) Delaware River Gauge and the Trenton, NJ Delaware River Gauge by NYC Delaware River Reservoirs. The proposed FFMP abolishes these provisions. This is a mistake.  These safeguards are the only protection the Below Reservoir Communities have against NYC’s continual decline of sharing the Delaware River Aquatic Resource. The abolishment of these provisions completely and utterly destroys the Doctrine of Equitable Apportionment and should never take place.
 
The DRBC must protect the Lower Basin water supplies and safeguard against the salt line intrusion moving up the Delaware River.  The uncoupling of the Flow targets from NYC’s responsibility jeopardizes a healthy flow of the River, especially when NYC over-uses the Delaware River Reservoirs or when there is a real, bona fide drought in the Lower Basin. 
 
Furthermore, I reject the validity of both the current FFMP and Revision 1 as adequate plans to maintain the safety of the below reservoir communities. I demand, and urge elected officials to join me in insisting, that you develop an interim plan that adequately protects our community and all the other below reservoir communities from NYC disregarding its Supreme Court Decree obligations.
 
Thank you for the opportunity to comment on the proposed FFMP.
 
Respectfully submitted,
 
John G. Webb, III
P.O. Box 336
Columbia, NJ 07832
Affiliation:  Owner of property beside the Delaware River that has been flooded 3 times since I've owned it and member, Delaware River Conservancy, Inc.