11/14/08 Homovich/NYSDEC letter

November 14, 2008

Mr. Mark Klotz
NYSDEC
Director, Bureau of Water Resource Management
625 Broadway, Albany, New York 12233-3508

Dear Mr. Klotz:

As per our previous correspondence and phone call the following summarizes the conversation, my concerns, my ideas and my questions.
First let me make it clear I understand that the NYCDEP operates its reservoirs on a ‘Drought paradigm”—the day after a flood is the first day of the potential drought. However, according to Dr. Jim Miller, a climatologist from Rutgers, this does not make sense. During the Radio Forum on Delaware River Flooding (WJFF, Jeffersonville) moderated by Anthony DePalma of the New York Times and broadcast by several NPR stations, Dr. Miller stated that the reservoir system should be operated in a manner that accurately reflects current weather patterns—i.e. a Flood/Drought paradigm. After three terrible floods this would seem to make sense.
The Public Safety in the lower DRBC states has to be included in reservoir management policy. I know that the fish are part of the picture and that NYC’s water supply has to be assured. I also know that NYCDEP has the right to perform maintenance of the R-WB Tunnel and that any change that I suggest has to work its way through the process of the DRBC. I am addressing my concerns to you as my advocate for the most amount of protection that is available without endangering any of the previous mentioned items. New York City has it’s own powerful advocates. Is it not part of your job description to represent and protect the interests of upstate residents?
My plea has always been for preventative measures to alleviate the flooding from the Pepacton Reservoir. All my presentations concerning Resolution 18 and FFMP have been focused on this idea with emphasis on the uniqueness of each reservoir. With the closure of the R-WB Tunnel for a long duration I have gone back to the statistics and arguments for an immediate change to prevent/alleviate winter/spring flooding since the reservoirs will be soon at 100% or far too high for the time of year. The temporary release program is inadequate for all the reservoirs but especially Pepacton.
In your letter of November 6, 2008 you cite the 3 inches of precipitation for October 25-27 for significant increases in Pepacton. Using the DRBC River master charts, the closure of the R-WB Tunnel occurred on 10-25-08. The height of the Pepacton on that date was 1257.11’ with 63 cfs (39mg) at the USGS Downsville gage. The precipitation for October was 4.44”(DRBC website) or 3.69”(NYCDEP website). As of 10-31-08 Pepacton was at 76.6% and the total for the NYCDEP system was at 76.9% when it is normally at 69.1%. With this significant increase the Pepacton will be overflowing by November 30, 2008 if November precipitation figures hold true. The whole system is noticeably above its normal storage.
In six days the Pepacton levels changed as follows:

10-25-08 10-31-08 Sources

Height 1257.11’ 1260.95’ NWS hydro prediction Website
% of capacity 72.2 76.6 NYCDEP Website*
Precipitation .04” 4.44” DRBC Website
Precipitation .44” 3.69” NYCDEP Website
Ratio** 72.8:69.8 76.9:69.1 NYCDEP Website
*(10/24/08 post)
**Current: normal
If you now consider the November precipitation statistics for the last 8 years the flooding potential becomes more evident:
2000 2.5”
2001 1.32”
2002 3.67”
2003 3.98
2004 3.64”
2005 3.91”
2006 4.31
2007 4.15” source: DRBC River master charts
If three inches of precipitation can raise the Pepacton 3’ in 6 days what will the precipitation in November raise it? One inch of rain will raise Pepacton about a foot. As of 11-12-08 the Pepacton is at 1266.49’ with almost 1” of precipitation predicted Thursday-Friday.
This amount of precipitation potential brings about the next area of the concern. Pepacton at 100% creates a 7,000-acre impervious surface that creates flooding rapidly at Downsville.
Example 1: December 2003
By 12-1-03 the Pepacton was spilling. The total precipitation for December up to 12-24 was 3.46”. On 12-24 the precipitation was .43” and on 12-25 it was .58--not a large amount of rain. The spill was 174 mg on 12-23. By December 25 the spill was 3,349 mg and it produced a flood. (Airport Road had to evacuate with canoes).
NOTE: The reservoir was never lowered from the flood of October 2003.
Example 2: December 2004
By 12-06-04 the Pepacton was spilling. The Pepacton spilled on 12-24 with 1,303 mg with the ground saturated from the constant spilling. It was not as severe but it did flood some of the homes. The precipitation up to December 23 was 2.67” and on the 24th it rained 1.30”.

The point is that the amount of precipitation in each instance was NOT excessive and should not have caused flooding. However it did as it does for Downsville and the residents below the Pepacton when the reservoir is allowed to fill and hold at 100%. If Pepacton reaches 100% for winter 2008-2009, there will again be a series of floods. If all three reservoirs are at 100% the releases cannot be made all at once. Once Pepacton spills the release is dropped to 23 mg anyway. The release chamber for Pepacton is so small, 450-500 mg (700cfs) that it cannot be lowered rapidly. (Cannonsville has a 2000 cfs release capacity.)
Now consider Temporary FFMP Release 2008 in light of the data presented above. The 45 million gallons is inadequate on two counts. The first inadequacy is the small amount of release compared to the inflow to each reservoir with no diversion to the city. The second inadequacy is the inequity of the allotment to each reservoir due to the tremendous size differences. Pepacton should have the greatest release since the cfs at Montague is no problem at this point.
Supporting data: The established releases for the three reservoirs…
Pepacton Cannonsville Neversink
FFMP 39 mg 58 mg 29 mg
2008 Temp 56 mg 73 mg 39 mg
Capacity 140.19 bg 95.706 bg 34.941 bg
If Pepacton is the largest why at this time of year does Cannonsville have the highest release? Neversink is the smallest, one-fourth the size of Pepacton, so why are releases from Pepacton only 17 mg more? Pepacton is being managed so as to fill and thus pose a danger to downstream residents. A simple adjustment in the release of two or three times Neversink for Pepacton would create equity.
In your letter you state that making the releases equal to inflow is impossible and I agree. The release of 45 million gallons divided between the three Delaware Reservoirs also creates an impossible situation. Each reservoir receiving 15 million gallons (23 cfs) extra per reservoir fills each rapidly because of not adjusting some way to the inflow. Using one of the five gages in the Margaretville area the flow 11-13-08 is 318 cfs. That is 18 days after the last significant rainfall and the flow is still high. The high point on 10-26-08 was 1410 cfs and it has taken all those days to reach 318 cfs. In the summer the decline would have gone much faster. It is the soil conditions and no vegetation that adds to the accumulation. This accumulation, with no diversions, has been tremendous for residents below the reservoirs.
Reservoir height change due to the 3.5” for October
Pepacton Cannonsville Neversink
10-25-08 1257.11’ 1117.31’ 1412.15’
11-13-08 1266.23’ 1127.26’ 1423.67’
Increase 9 feet 10 feet 11 feet
**Feet to spill 14 feet 23 feet 17 feet
Flood Stage 1 foot 3 feet 1 foot
With no significant rain since October, these increases have occurred. If the November precipitation equals any of the last five years, the three reservoirs will be full by November 30, 2008. Once full, an analysis of past lowering shows that all three cannot be lowered rapidly. Even if you divert and release per previous emergency (April 2008) programs, the disaster is sitting in wait all winter long. The usual January thaw will produce even more flooding. Releasing at 100% of capacity takes too long (Pepacton 6-7 days for 1’, Cannonsville 4 days for 1’ and Neversink 2 days for 1’).
In essence the statistics, (and I could add more,) indicate that all three areas face a long, wet winter with the closure of the tunnel. Just as the repairs are needed for preventive failure of the tunnel, a re-examination of the inadequate release figures are needed to prevent major flooding for the residents of New York State. The NYCDEP need not release the full capabilities at this time but some adjustments could be made that would consider all parties. Just as I get a flu shot for preventative measure, these changes would be so simple and preventive.
In summary, I feel that more could be done with no danger to the NYC water supply. The reservoirs are well above normal storage. The level of Pepacton is approaching 90%. The data for lowering Pepacton quickly indicates a slow process. The Downsville area since 2003 has seen 10 floods. Penn State Weather predicts more snow than last year with a major, long thaw for January through March. At 100% capacity Pepacton floods rapidly.
The points are clear. I ask you to be an advocate for the residents of Delaware County and see if more modifications could occur. The Temporary Release does state “…,enhanced release rates above FFMP L1 may be considered individually for each reservoir.”
We live in a time, post-Katrina and the great financial meltdown, when responsible public officials are being held accountable for their failure to protect the public. I am asking, respectfully, Mr. Klotz, is it your job to act to ensure the public safety when these reservoirs are being mismanaged? If not, whose job is it?
Thank you for your attention to the problem.
Sincerely,
Joan Homovich
PO Box 387
22 Bridge Street
Downsville, NY 13755