Tharp Testimony
Submitted by Diane Tharp
June 28, 2007
Veterans Affairs and Emergency Preparedness Committee

I would like to thank Chairman Melio, and Chairman Fairchild and Representative John Siptroth, and all the representatives here today for giving me this opportunity to speak before this assembly. I am Diane Tharp: a science and math teacher, a business owner, wife, mother, grandmother and a three time flood victim. As you are aware, the Delaware River Basin that includes 4 states, 42 counties and 800 municipalities has experienced the devastation of three catastrophic floods in a period of18 months. The massive devastation that occurred from these floods has taken the lives of nine people, destroyed fishing habitats, vegetation both in and on the banks of the river and its tributaries and has placed an economical disadvantage on the businesses and communities that depend on the river for their livelihood. Ironically, today is the one year anniversary of the June 2006 flood. The lives of many of your constituents have been changed in only ways that a flood victim can imagine. Today, up and down the Delaware, communities, homes and businesses continue to recover; many homes and businesses have simply disappeared and others lie in ruin. I have been researching this flooding issue for the past three years and have been given the opportunity to speak publicly before federal and state politicians, the DRBC and representatives from many state and federal agencies involved in this flooding issue.

The DRBC in the next few months will be adopting a Flexible Flow Plan which will effect the lives of every single person in the states of PA: NJ: NY: and Delaware either due to flooding, water supply or the cost to every taxpayer that must bear the burden of the massive clean-ups and rebuilding that occurs after each devastating flood. The proposed plan submitted to the public previously did not address the needs of the fisherman, the recreational industry and most importantly did not provide an adequate plan for flood protection. I commend the DRBC for taking the additional time to review and fully consider the public comments received on this plan and for contracting the USGS, Army Corps of Engineers, NOAA and the National Weather Service to develop a flood analysis modeling tool to replace the ineffective Oasis Model that is used now. I realize that one of the major problems facing this agency is that they must have unanimous agreement for all their plans. Today I would like to present to you information that will help you understand the problems facing the people of this commonwealth and all people in the Delaware Basin.

Flooding is caused by excessive rainfall, which is an act of nature. It occurs on rivers and streams with or without reservoirs. However, 100% full reservoirs spilling billions of gallons of water into our river system is an act of poor management, arrogance, and negligence by the owners and parties that have been entrusted with the protection of this river. The day before each of the floods, the New York City’s Reservoirs in the upper Delaware and Lake Wallenpaupack in PA were at or above 100% capacity. The New York Reservoir System at 100% capacity in its 19 reservoirs and three controlled lakes has a total storage of 580 billion gallons of water. The Delaware system contributes 270.8 billion gallons of storage and the Catskill reservoirs the remaining 309.2 billion. NY City’s gross consumption is approximately 1.1 billion gallons per day including the sale of water to many communities before it reaches the city. Ten years ago, there were over 60 communities. I have not been able to locate the current figures, but I am sure that it is many more. Thus, without a drop of rainfall for a year, mathematically, NY City has enough water for approximately 300 days on its Catskill system alone and over 500 in both systems. I realize also that 2.5 million Pennsylvania and New Jersey residents depend upon this river for their water supply; only this river. Therefore, it is imperative that it is managed in a fair and equitable way. In PA we also have seven multi-purpose reservoirs that may provide water during drought conditions. I realize the concerns for water when drought conditions exist, but New York has access to the reservoirs on both the Hudson River and the Delaware River. The risk of completely depleting these reservoirs is improbable. I believe that a realistic solution for flood control based on the year round capacity levels of the reservoirs can be reached in conjunction with diversions, voids and releases.

I have not come here today to only address the NYC Reservoirs. There is another reservoir on the Delaware River System that has also played an important role in releases of excessive water into the Delaware River increasing the height of the crests. PPL’s Lake Wallenpaupack has been under fire from local officials and residents also for causing increased flooding during the last three floods. Of major concern since the relicensing of Lake Wallenpaupack by FERC on July 8, 2005, under Section 10 of the settlement agreement the new target lake levels would be higher than current target levels. This is in collaboration with the DRBC and the Upper Delaware River Basin for drought conditions. The use of water from Lake Wallenpaupack to meet the Montague target of 1750 cfs results in even fewer releases by the NYC reservoirs. This not only allows the reservoirs to keep even more water, but provides for major concerns for the fishing habitats that depend on these cold water releases for survival. I will address the fishing issue in a moment. The Pike County Commissioners have written letters to FERC concerning the lack of any flood control elements in the Relicensing Settlement. Since Lake Wallenpaupack is now linked to the reservoirs by virtue of this relicensing, the DRBC must include in their new plan a comprehensive flood plan from PPL including voids. When Lake Wallenpaupack opens their flood gates for emergency spills when the river is already swollen and flooding it adds feet to the crest of the water. During last year’s flood, Lake Wallenpaupack was releasing over 8000cfs through its flood gates. To better understand how much water this is; it would be as if 32 Olympic size pools were emptying every minute. I do know that the Lake Wallenpaupack Advisory Committee has been working on a plan to avoid this type of catastrophic releases, but this plan must be included in the new Flexible Flow Management Plan and must be one that protects the people living downstream from this dam. All reservoirs along the Delaware need to have voids to help reduce flooding.

The DRBC in their latest publication entitled,” Water Supply Reservoirs and Flood Protection” presents a chart listing the top 10 flood crests at Trenton in the last 100 years saying that seven out of ten of the worst main stem floods in the Delaware recorded in Trenton occurred in the absence of reservoirs or in the absence of spills. As a science teacher I teach my students when you compare events you must record all the variables. This chart does not list the rainfall total and the number of days of rainfall of each event which obviously is the main predictor of flood crests and in the case of 1955 there were two hurricanes Connie and Diane in a period of one week depositing over 21 inches and also during that event smaller dams on tributaries broke during this flood. Also the flood control dams that effect Trenton were not in effect until after 1955. Therefore, after further analysis, if you look at the floods after 1955 since the flood control dams were put into place, the crests of the 2004, 2005 and 2006 floods are extremely high considering that the rainfall amounts were far less than in 1955. (5.24 inches-Sept 18 and 19, 2004; 7.46 inches- March 30-April 4, 2005; June 26-June 30- 7.67 inches.) Also if the DRBC had published the chart from the Tocks Island gauge on the main stem near the Delaware Water Gap where I live, the highest recorded crests are 1955,(37.40 feet); 2006,(33.87 feet); 2005(33.24 feet); and 2004(30.34feet) . Flood stage is 21 feet. How can they explain such high crests with rainfall being so much less when compared to the 1955 amounts? The DRBC using a hypothetical model has publicly said that the full reservoirs made a difference of only inches down stream from the dams. Tim Pryor a 21 year member of the American Society of Mechanical Engineers for the Greater Trenton Area did an analysis at the Trenton gauge for the 2006 flood and has concluded that the reservoirs contributed 2.5 feet to the crest height at Trenton or 17% and that these numbers will increase dramatically at each gauge up river. This does not include the momentous spills at Lake Wallenpaupack which have been estimated to have increased crests at least 2-3 feet during the highest flows. Roger Ruggles a renowned hydrologist at Layfayette College just honored as Engineer of the Year has concluded that a 20% void in the reservoirs would have lessened the crest at Belvidere by six feet. His final report is to come out tomorrow and will include Lake Wallenpaupack. So at my home it is conceivable that the spills from the reservoirs and Lake Wallenpaupack together could have made a difference of 6-7 feet or more. The DRBC needs to use the actual data to find the true effects of the reservoirs and not theoretical models. Spilling reservoirs cause millions of dollars of additional damage to homes and businesses that would have been spared had they not spilled and instead contained voids.

We all agree that rivers flood with or without reservoirs. However, the DRBC also acknowledges that ”Voids in the upper basin water supply reservoirs can reduce , but not totally, eliminate floods”(Water Supply Reservoirs and Flood Protection) It has often been said that the reservoirs actually help us, because they are releasing less water than the in- flowing volume. However, if you have a hole in your roof, you don’t really care that there were 10 inches of rain that fell on your roof. Instead you care that there is five inches of water in your living room. Thus, we care that there was billions of gallons of water funneled directly into the Delaware rather than a void that would have held back those billions of gallons of water. Also, as rainfall falls upon a full reservoir it acts almost like a paved surface and there is 16 times more run-off per acre from a paved surface than from one that allows absorption. Thus the reservoirs funnel the water directly into the tributaries or river rather than allowing the ground to absorb more rainfall and flooding creeks would take much more time for the water to find the main river tributary. During the flood last year from June 26th through the 30th; Pepacton spilled 30.609 billion gallons; Cannonsville 46.381 billion gallons and the Neversink; 5.161 billion gallons. The total spillage by these reservoirs was 82.151 billion gallons. This does not include the spillage from other PA reservoirs. To put this amount into perspective this would be the same as draining over half the Pepacton Reservoir or draining 90% of the Cannonsville in a period of 5 days. The DRBC goes to great lengths to make comparisons with or without reservoirs. We need to end this entire rhetoric and face the reality that the reservoirs do exist and indeed they can reduce flooding when voids are present.

In October 2005; we experienced excessive rainfall in our area. We recorded 11.5 inches of rain on October 8th- 11th. During this same time period, the upper Delaware River Basin received 4.77 inches of rain; a substantial amount of rainfall.(The same amount recorded during the September 2004 flood) Yet, the river rose 6 feet in front of our home. Not 34 feet as it did during the June flood. At this time the reservoir levels were Cannonsville (26.1%), Pepacton (56.5%) and Never sink (63.0%) and Lake Wallenpaupack’s levels also contained voids. No spills occurred. As you compare the Summary of Hydrologic Conditions for the months of the last three floods with the report for October 2005, you will find that even though October 2005 recorded a higher precipitation than any of the flood months, we experienced absolutely no flooding on the Delaware. I think that everyone agrees that when the reservoirs contain voids, rainfall is obviously retained and river and stream levels are also much reduced.

The NYDEP and the DRBC consistently separate the 11 reservoirs affecting the Delaware into water supply reservoirs and multi-purpose reservoirs. The flood control reservoirs operated by the Army Corps of Engineers in PA do maintain year round storage voids and also have additional releases for recreational activities such as rafting on the Lehigh.

The Delaware River Basin Compact which created the DRBC in 1961 was formed to establish a joint responsibility and control for the shared use of the Delaware River between the four states of Delaware, New Jersey, Pennsylvania and New York and the federal government. It originated from the Supreme Court decree to settle the case of the State of New Jersey v. The State of New York and New York City filed on May 4, 1931 and amended on June 7, 1954.

The New York DEP consistently states that the reservoirs are not designed for flood control, but for a water supply system. Yet, in Part 1 of the compact it does not differentiate between water supply reservoirs and other reservoirs.

“Whereas the public interest requires facilities must be ready and operative when needed, to avoid the catastrophe of unexpected floods, of prolonged drought, and for other purposes.”
Also in Article 6.1 Flood Protection it states:

“The commission may plan, design, construct and operate and maintain projects and facilities, as it may deem necessary or desirable for flood damage reduction. It shall have the power to operate such facilities and to store and release waters on the Delaware River and its tributaries and elsewhere within the basin, in such a manner, at such times, and under such regulations as the commission may deem appropriate to meet flood conditions as they may arise.”

This statement certainly and legally gives Pennsylvania the right to demand the acceptance of a plan to release water from the reservoirs at appropriate times and to reduce flooding through voids. The commission after the 2004 flood could have asked for more releases by the NYDEP, but did not act. They could have again asked for a change after the 2005 flood, but did nothing to add additional releases or require that NY divert water from the Delaware reservoirs to their Catskill reservoirs. From January 1, 2006 to June 30, 2006, the NY system never fell below 90% meaning that they had over 100 billion gallons of water stored above drought warning. Yet during this time no additional releases or diversions were made and thus on June 28th, the residents of the Delaware River Basin had to endure a third catastrophic flood with higher crests than the previous two. Why wasn’t action taken? It wasn’t until a letter from the four governors demanding that something be done, that an interim plan was put into effect in September 2006. Under this interim plan in place since September, we have experienced many days that the reservoirs have been 100% full even though releases were made according to the chart. But, no one calculated the amount of precipitation we received. If you have a full glass of water and pour out 1/3, and then pour _ back into the glass, it will obviously spill. Thus, there must be an additional release formula calculated in conjunction with the rainfall. For example, if a reservoir receives rainfall that increases its capacity by one billion gallons, an additional release of 800cfs for 48 hours would void those one billion gallons.) In this way reservoirs in times of above average rainfall would not get to the deadly levels of 95-100% or more. Besides releasing water into the Delaware, NYC can release water into its tunnels or aqueducts into the Catskill System. The proposed FFMP plan must include a flood mitigation plan by the city that includes mandatory diversions to its Hudson system to avoid spillage into the Delaware or its tributaries. The NY DEP at the Gilboa Dam on the Schoharie Reservoir in the Catskill Reservoir System did install four siphons that are capable of moving 500 million gallons of water per day from that reservoir. Next year they will begin a project that will include flood gates and other preventative measures. Why doesn’t the NY DEP give the same consideration to people that live in the Delaware River Basin as it gives to its own citizens on the Catskill System?

The Supreme Court Decree of 1954 allows NY City to divert an average of 800 million gallons a day from the Delaware Reservoirs to supplement its Catskill System. Historically, they average between 460mg to 630mg per day which is only 60 to 80 % of their allotment. They must also release enough water to keep the Montague gauge at 1750 cfs. It was never the intention of the Supreme Court in their decree that the DRBC’s job was to be responsible for the NYC water supply. The Supreme Court Decree was meant for the “Equitable apportionment of waters.” Consequently, in the original Supreme Court Decree of 1954 in Section IIIB1c, there were provisions provided for the release of excess water by the reservoirs in a period of 120 days called the “seasonal period” so that they would not be able to ‘bank” an excessive amount of water thus taking it away from the Delaware. (Excess release quantity was based on estimated consumption, actual consumption and safe yield.) However, the DRBC in the Delaware River Basin Water Code of 2001 through many resolutions and rules governing drought conditions and terminology such as “excess release quantity”, “excess release bank,” “conservation releases,” and excess release credits,” have given the NY reservoirs the opportunity to remain 100% full or higher. Spills are unauthorized releases into the Delaware. The Supreme Court does not mention the word spills because they assumed that there would be none. The NYDEP has the attitude that the water in the reservoirs at Pepacton and Cannonsville is their water to be controlled by them; however these dams are located at the head waters of the Delaware River which is a free flowing river to be shared by all four states. Another important fact to consider is that two thirds of the non-tidal Delaware River is designated as part of the National and Scenic Rivers System. Under this federal legislation, the Delaware River is to be protected for the benefit of future generations.

The DRBC in Resolution NO. 2007-7 adopted May 10th said that until September 30, 2007 or the adoption of the revised Flexible Flow Plan; we would continue Revision 9 the interim releases plan and Revision 7, the tailwaters fishery program which releases cold water for the fish. The amount of releases is spelled out specifically in this plan. Yet; an e-mail on June 11, 2007 from Rick Fromouth ( DRBC) states that the NYCDEC has decided not to follow this plan specifically in fear of lack of water in the thermal banks and has shut down 12 miles of prime wild rainbow trout water by moving a gage in Hankins and putting it at Lordsville. The DRBC said that we would follow the Revisions until September. How can the NYCDEC simply change the rules? There are four Release Banks set up in this revision for water to be released for the protection of the fisheries. Presently, there is 249 billion gallons of water in the three Delaware reservoirs. Why are the fish dying in the upper Delaware? Why are boaters carrying their canoes and rafts down many sections of the Delaware? Both the fishing and recreational industry brings in millions of tax dollars into this state and brings employment to otherwise economically disadvantaged areas. It is an important aspect of this state’s economy. It deserves the attention of this assembly.

It has been stated by Ian Michaels of the NYDEP that it would be negligent on their part to have permanent voids in the reservoirs in case of drought. Drought has always been the main focus of the decree parties since the inception of the DRBC in 1961. However on the NYDEP website in a chart labeled “History of Drought and Water Consumption,” the lowest percentage listed is 33 1/3 %. This means that the capacity of the reservoirs has never fallen below 190 billion gallons, still enough water for 190 days. Isn’t time to face reality and focus on the problem at hand: FLOODING? Also, isn’t it the epitome of negligence to have no back up water filtration in case the water system would become polluted .Since the decree of 1954, NY City has done nothing to supplement their water supply other than work on a third tunnel that is taking 50 years to build and will cost over $6 billion dollars and does not increase their water supply. The EPA has just granted them an unbelievable ten year extension on the filtration avoidance which I find to be quite suspicious. The state health department of New York has just declared on June 8th that the town of Newburgh who takes water directly from the Delaware Aqueduct (water coming from Cannonsville Reservoir and Pepacton Reservoir) must build a filtration plant. (Times Herald Record). Pregnant woman have been asked to consult their doctors before drinking. If this water coming directly from the Delaware System must be filtered then certainly the water from the Delaware System that eventually mixes in the reservoirs (Kensico and West Branch) close to New York which has had pollution problems for years due to the extensive development most certainly must be filtered. The EPA has already ordered NYC to build a filtration system on the Croton Reservoir System. Exactly what data did the EPA use to support this ten year extension? How can we trust the NYDEP when in the last two years three employees have been federally indicted for falsifying drinking water monitoring records? (Times Herald Record; June 6). Do the people of New York City and surrounding communities really understand the true quality of their drinking water?

The most alarming part of the proposed FFMP is the idea that the plan allows NYC to have additional storage in their Delaware Reservoirs. In January 2006, a Times Herald-Record investigation uncovered years of fabricated inspection reports at one or more of the reservoir dams. How safe are these dams? New York Senator John J. Bonacic introduced legislation and has questioned the high reservoir levels which caused flooding in New York and is questioning the safety of all dams. In a letter to New York’s two United States Senators and local representatives in February of last year said that it was outrageous that a year after the flooding (April 2005), reservoir levels were still at 100% capacity in advance of other expected spring rains and snow melt. “The DEP’s position is arrogant,” he wrote. “It is the most arrogant position by any agency I have seen in all my years of holding public office.” How can the DRBC in this plan simply allow reservoirs to have additional storage when they have not authorized a complete investigation by the Army Corps of Engineers into the safety of these dams? Does the DRBC even have the knowledge if these reservoir dams were built to contain additional storage? How exactly is this additional storage to be implemented? In their proposed plan “additional storage” is mentioned eight times. Yet, it was not mentioned even once in the interim plan and it was not a recommendation of the governor’s task force. How can the DRBC and our PA DEP with a clear conscience justify such a proposal and expect the governors of the four states to sign this plan without a detailed description of how NY City intends on implementing this additional storage. In a letter from William Gast of the PA DEP that I received in answer to an e-mail that I had sent to Governor Rendell, (dated March 12) Mr. Gast states that the “additional storage will require design and construction of modifications to the dams at Cannonsville and Pepacton. Those designs will incorporate the latest dam safety requirements.”
If modifications are being made to these dams then the DRBC should request that they become flood control dams by retrofitting larger capacity release valves. Also, who will determine that the ‘latest dam safety requirements” are implemented? The New York DEP with their history of deception? These are earthen dams placed into service in 1954, 1955 and 1964. How often does the DRBC receive dam inspection reports? How reliable are they? If the 8 inches of rain that fell in the town of Roscoe last week in two hours killing at least six people had fallen over the Pepacton Reservoir would the dam have held? That is a frightening question. If NY City wants to increase capacity, then it should do so on the Hudson reservoirs. Frankly, I am puzzled as to why the DRBC or the Department of Environmental Protection Agencies of this state and New Jersey does not require NY City and New York State to create the “additional storage” on the Hudson Reservoirs and then they would be able to increase the voids on the Delaware System; thus, keeping the water supply the same. The Delaware River has just experienced three of the most devastating floods in its history. If New York intends to spend millions of dollars for additional storage in reservoirs, it seems logical that it should be on the Catskill System that experiences very little flooding and is closer to the city and where reservoir spills can be directed into the Hudson if necessary. Why is this not being considered? Since NY City subscribes to the unrealistic and dangerous “filtration avoidance plan”, it is their responsibility to figure out ways to increase their water supply. Philadelphia filters the Delaware River. So too should NYC filter the Hudson. Both Poughkeepsie and Hyde Park filter the Hudson River now. Emily Lloyd, commissioner of New York City’s DEP states that a preliminary design for the filtration plant is ready and already sits in a drawer. It will cost six billion dollars. Ironically, the same amount as the fifty year tunnel project. It is to be located at Mount Pleasant and will cover fifteen football fields and be able to filter 2.4 billion gallons a day. NYC is being negligent for not beginning this plant today. This plant would provide protection from drought and pollution and additional storage would not be needed. It is the responsibility of the DRBC in the Delaware River Basin Compact to protect this river, the wildlife, recreational activities and the people who live in this Basin. The people and communities in this River Basin should not be placed in danger because of the NYDEP’s lack of management of their reservoir system and lack of a plan for their future needs.

Since the DRBC is a federal-interstate compact agency, this legislature has several legal avenues to pursue if you are not in agreement with the decisions made by this agency. The National Environmental Policy Act of 1969 calls for a detailed statement and analysis by the President of the DRBC explaining the environmental impact of the proposed action, any adverse environmental effects which cannot be avoided; alternatives to the proposed plan; the relationship between short term uses and long term productivity and comments from people with special expertise with respect to the environmental impact. Also the Administrative Procedure Act of 1946(APA) sets up a process for Federal Courts to directly review the agency decisions. The Proposed FFMP actually changes parts of the original Supreme Court Decree so it needs to be legally challenged as well as challenging adherence to the Delaware Basin Compact. Legal issues also arise with possible violations to the Wild and Scenic Act of 1968 and the Endangered Species Act concerning the dwarf mussel. Lastly, Pennsylvania can go back to the Supreme Court for a revision of the original decree for equitable apportionment of the waters of the Delaware.

Assume for a moment that the New York reservoirs and Lake Wallenpaupack are all at 100% or above capacity and it is announced that there will be 6-8 inches of rainfall in three days. What will happen differently today then before each of the last three floods? Absolutely nothing. We have had three years of public outcry, an interim plan that has proved itself ineffective, a four state governor’s flood mitigation task force with 40 recommendations; several of which call for releases sufficient to reduce the likelihood that the upper basin reservoirs will spill during a storm; hundreds of comments for changes on the proposed FFMP; letters from both federal and state politicians: and hundreds of newspaper articles written on the subject. Yet, at this point today, on the anniversary of the third devastating flood and with hurricane season just arriving we again are facing the possibility of yet another flood. The political appointees for PA on this commission are not representing the people of this commonwealth. They are allowing the NYDEP to dictate the contents of the plan. I am asking all of you and the governor of this state to demand that we the people of this commonwealth are fairly represented in this new plan with true flood protection for the reasons set forth in this testimony.

Summary of Crucial Concepts for the
Flexible Flow Management Plan.
A) The recommendations of the Flood Mitigation Task Force commissioned by the Governors of the Decree Parties must be included in this plan. Also the Flood Mitigation Task Force should be given the opportunity to evaluate this FFMP and send its recommendations to the governors.
B) The plan must provide releases based on reservoir capacity that will be sufficient enough to create the voids needed to lower the crest levels for flood mitigation all year round. Additional releases must be considered for rainfall when reservoirs are above adequate voids.
C) All reservoirs on the Delaware must submit flood mitigation plans that contain voids including Lake Wallenpaupack
D) Reexamination of the current drought operations plan. Also the drought rule curve is arbitrary and non-scientific. It must be more realistic.
E) To avoid spills into the Delaware NYDEP must have mandatory diversions to their Catskill System when storms are expected and voids are not sufficient enough to avoid these spills. Dams must be retrofitted with more flood control valves and/or siphons.
F) Dam inspection reports on all dams on the Delaware System should be included in this plan.
G) Any additional storage must be added to the Catskill System; not the Delaware System.
H) Data must be collected by independent organizations not by one of the Decree Parties to ensure honesty and accuracy.
I) The Oasis model must be replaced by a more effective modeling tool.
J) Fishing habitat and recreational releases must be increased to ensure the healthy continuance of these vital industries to the economic health of the state.If a fair plan is not presented to the public by the DRBC then it needs to be challenged in a court of law as to; its legality in replacing parts of a Supreme Court Document and adherence to the Delaware River Basin Compact; violations to the Wild and Scenic Act addressing a free flowing river; the Endangered Species Act concerning the Dwarf mussel; the Administrative Procedure Act of 1946, and the National Environmental Policy Act of 1969.

References
1. Supreme Court of the United States, State of New Jersey v. State of New York and City of New York, May 4,1931
2. Supreme Court of the United States, State of New Jersey v. State of New York
and City of New York, Amended Decree June 7, 1954
3. Delaware Basin Compact of 1961
4. DRBC Documents:
Water Supply Reservoirs and Flood Protection
History of the Reservoir Releases Program in the Upper Delaware Basin
Powerpoint of Public Comment on the FFMP
Resolution NO.2007-7
Reservoirs in the Delaware River Basin
NO.2006-Docket NO. D-77-20CP(revision 9)
Delaware River Basin Ware Code 2001
Proposed Flexible Flow Management Plan
5. NYDEP Articles:
Overview of the NY City Drinking Water Supply System
Current Reservoir Levels
City to Implement Reservoir Spill Control at Gilboa Dam
Croton Filtration Plant Project
History of Drought and Water Consumption
6 .Recommendations of the Delaware River Basin Interstate Flood mitigation Task
Force.
7. Lake Wallenpaupack Documents
8. Legal Documents:
The National Environmental Policy Act of 1969
The Administrative Procedure Act of 1946
The Wild and Scenic Act of 1968
9. Newspaper Articles