FFMP: the devil’s in the details

Trout Unlimited (TU), an organization dedicated to the ecological preservation of the Upper Delaware River environment and its trout fisheries, cannot support the reservoir release schedules that are contained within the interim Flexible Flow Management Program (FFMP) due to the significant damage these releases will bring to the Delaware River’s cold-water ecosystem. TU does support in principle the FFMP adaptive release concept to address the flow management issues in the Delaware River basin. The current constraint under which the FFMP is modeled, however, is invalid, biased, and inflexible:

• New York City’s annual diversions from Neversink, Pepacton, and Cannonsville reservoirs over the past 10 years have averaged 508 mgd. Yet the Delaware River Basin Commission (DRBC) has consistently required that all OASIS modeling of future scenarios consider an annual New York City diversion of 765 mgd. This means that over 290 mgd is available for ecosystem benefits downstream of the reservoirs, not the 35 mgd that the DRBC is currently modeling.

• By imposing a release schedule calculated for extreme water supply diversions when the actual annual average diversions are much lower, the DRBC’s interim FFMP will result in far more reservoir spills and significantly higher reservoirs each year than the OASIS model currently predicts.

• New York City’s annual average diversions have been decreasing over the past 15 years, and they are not projected to increase for the foreseeable future. Given the resulting additional water in the Upper Delaware River, the following changes will correct the deficiencies of the FFMP with no risk to any of the Decree Parties’ water rights and availability.

1. The releases in the interim FFMP must be increased, in light of the large quantity of available water that will not be diverted to New York City and will eventually find its way downstream as spillage over the dams. The OASIS model can substantiate this, and the DSS model verifies the considerable habitat gains for the rivers.

2. More release levels and seasons are necessary in the interim FFMP. The interim FFMP structure is very inflexible; during most summers, releases will remain in L2 more than 75 percent of the time. At a minimum, additional graduated levels need to be added to both the L1 and L2 Storage Zone. The FFMP will also benefit from additional seasons, particularly because of traditional water temperature and flow problems in mid- to late-May, early-June, and the summer period through mid-September whenever Montague flow target releases are not made.

3. The wildly fluctuating releases that result from the efforts to meet Montague flow target shortages must be eliminated by using weekly averaging. Using anticipated water diversions, anticipated Montague target releases, and projected hydropower releases, the Rivermaster can institute a weekly Montague release that accounts for these factors and eliminates these harmful and unnecessary daily fluctuations.

4. Directed releases for the Montague flow target must be balanced from the reservoirs. Some portion of the Montague releases should be apportioned as necessary to the East Branch and Neversink rivers when the Rivermaster requires water releases for the Montague flow target. Such an allocation in releases will provide more aquatic habitat to the three tailwaters and help avoid draining Cannonsville during dry years.

5. A formal annual review of the FFMP is mandatory. Any formal process to review and respond to new information or environmental conditions must include the stakeholders and not be unnecessarily hindered by the bureaucratic process.

By implementing the above courses of action to correct the deficiencies of the interim FFMP, the DRBC and the Decree Parties can use their power to significantly improve the health of the Delaware River and its treasured trout fisheries—and with no risk to New York City or any other Decree Party’s water supplies or rights.