FFMP: point of view from a downstream neighbor

There are seven issues on which progress must be made with regard to managing flows in the Delaware River.

1. New York City (NYC) must optimize its entire water system. It must stop the “yo-yo” diversions that are causing alternating man-made flooding with artificial drought conditions.

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

Today, the non-normalized operation of the NYC Water System renders the Delaware River Basin Commission’s proposed release schedule under its flexible flow management plan (FFMP) irrelevant. Without an overhaul of the entire water system, we will continue to experience the unending cycle of alternating flooding with “declared” droughts. Because of this, the DRBC is failing in its duty, declared by Congress, to ensure that NYC’s operation of its reservoirs do not harm the lower basin state communities.

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

The FFMP is based on the ineffective Oasis Model for flood modeling. Sound public policy requires that 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, safety voids are necessary to ensure heavy rain and snow thaw do not result in more tragic floods.

3. A full, NYC water system-wide re-assessment, based on actual usage and not perceived need, must be undertaken.

Many have concluded that the DRBC favors NYC in its rule making. Consequently, the FFMP contains a greater emphasis on NYC’s possible next “drought” rather than on Delaware River flooding. Yet, it is quite clear that a drought is unlikely to affect NYC’s water supply.

NYC, today, can satisfy the water needs of 11 million people—more than its total population of about 8.5 million. And NYC’s daily water consumption is about the same as it was in 1946—or about 1.1 billion gallons a day. A reassessment based on these actual facts would provide more flexibility in strategizing flow management.

4. The FFMP rescinds NYC’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 valves of the Philadelphia Water Department. The DRBC has not commissioned engineering studies to prove that removal of this mandate will not jeopardize Philadelphia’s water supply. This action is reckless—especially given the overabundance of water in the NYC system.

5. Informational workshops need to be held so that the needlessly confusing and complex changes can be reviewed by all stakeholders in detail. These workshops need to be held, one in each of the five sections of the river, on Saturdays, so that people who work regular hours can attend.

6. After the workshops are held, a set of public hearings need to held, again; one in each section of the river and on Saturdays.

To maintain a transparent, fair and open process, the DRBC must hold additional public hearings for oral testimony after the 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.

7. The public must reject the proposed “additional storage” that is included in the FFMP. Neither the FFMP nor REV 1 is okay. The FFMP allows for additional reservoir storage without the requirement of a mandatory environmental impact study. And a five-year study completed in 1982 concluded that additional storage was not economically or environmentally feasible.

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, Ph.D., is a licensed psychologist with a special interest in trauma-related disorders occurring after natural disasters who has a Masters in Public Administration. As a flood victim living in Lambertville, NJ, he has a personal, as well as a professional, interest in matters related to the Delaware River.)