Great Letter from PA Fish Comm. on FFMP

Letter from Leroy Young of PA Fish and Boat Comm.

Very well written!!!


Commission Secretary
DRBC
P. O. Box 7360
West Trenton, NJ 08628-0360

FFMP comments

Dear Commission Members:

The Pennsylvania Fish and Boat Commission (PFBC) would like to provide
writtencomments on the Delaware River Basin Commission's (DRBC)
proposed rulemaking to implement a Flexible Flow Management Program
(FFMP) for the New York City Delaware Basin Reservoirs. We appreciate
the opportunity to provide comments to DRBC. We have carefully
evaluated how the FFMP may affect aquatic resources and recreation and
offer the following position for DRBC to consider.

1. The PFBC supports the Flexible Flow Management Program in principle
and concept. Nevertheless, we have concerns, with the current version
ofthe plan advanced by the Decree Parties and proposed by DRBC as
policy. There is uncertainty associated with the Tailwaters Habitat
Protection and Discharge Mitigation Policy's (THPDMP) ability, as
currently proposed in the FFMP, to protect and enhance the fisheries in
the West Branch and Delaware main stem. Other alternatives may be
superior. For example, there has been some suggestion that more water
is available in New York City's reservoirs than is currently being used
by the City and this may be available for down basin uses. We are also
aware that a basin-wide reassessment of water availability, use, and
needs is being pursued by Decree Parties. This information is
critically important since it can be used to examine alternatives for
fishery protection. We believe that higher more consistent releases
would benefit the fishery. Therefore, we ask DRBC to determine actual
water availability based on this information and explore other
alternatives during
the three year period before the current version of the FFMP expires on
May 31, 2011.

We strongly encourage DRBC and the Decree Parties to remain open to
revisions to the FFMP during this interim period. If further analyses
by way of the DSS and OASIS models or other models that might be
developed show that other alternatives better optimize the multipurpose
needs of the system we would hope that DRBC would be open to
incorporating these as early as the summer of 2008.

2. We see the following benefits from the FFMP as currently proposed:
· The THPDMP should perform operationally better than Revision 7.

The THPDMP protects the fishery better at lowest flows compared to
either
Revisions 7 or Revision 1, the flow management plan what would be
reverted
to if the FFMP is not implemented.

Better flows should result in the East Branch and Neversink under
the
THPDMP

3. Some of the limitations of the FFMP are as follows:

The DSS model, which has been developed as a result of the recent
DRBC
funded study led by Ken Bovee of USGS, makes evaluation of many
alternatives to flow management on the biological resources of the
river
possible. We believe additional alternatives should be evaluated with
the DSS
and OASIS models that attempt to better optimize conditions for the
river's
biota, while at the same time taking into consideration the other needs
of the
system such as water supply. For example, the Bovee study shows that
the
habitat provided at the 225 cfs release rate from Cannonsville, a
release that is used in the current version of the THPDMP, is only a
fraction of the potential habitat available under optimal releases. At
the WBOsite only about 38% of the adult brown trout habitat will be
provided compared to a Bovee optimal flow of 717 cfs, while at WB1 only
about 55% and 49% ofthe habitat will be provided when compared to
releases of 706 cfs and 953 cfs, respectively. It appears that the 225
cfs flow and other flows in the THPDMP for the West Branch may be based
in part on the 1983 Sheppard study while the current Bovee study is
based on better science than was available in the early 1980's. We
believe more alternatives need to be considered in light of the new
information and methodologies that are available to us through the DSS
and OASIS models.

Despite the difficulties that were historically apparent in operating
the system under Revision 1, the PFBC believes that a significant
portion of the time Revision 1 actually would provide significantly
greater flows from
Cannonsville than the THPDMP. Flow duration analysis developed by the
PFBC from data provided by DRBC from OASIS modeling and attached as
Figures 1 and 2 shows that for flows exceeded approximately 65 to 70
percent of the time in the months of May through September, which are
most critical from a thermal standpoint, Revision 1provides higher
releases for the
modeled period of record, 1928-2000.

The similarities of flow duration curves under the three alternatives
shown in
Figure 1 lead us to believe that the level of additional protection
afforded by
the THPDMP is similar to Revision 7 and potentially less than Revision
1.

The lack of analysis of a range of diversion quantities, especially
considering
suggestions of additional water availability for downstream uses,
causes us to
recommend a more thorough evaluation of fishery protection alternatives
over
the next three year period.

Table 3 in the FFMP proposal for Cannonsville shows a decrease in
flows for
the period April 1 through May 31. These decreases are from 1500 cfs
down
to 110 - 225 cfs, which would not be protective of trout habitat during
hot
days. Alternatives to these sudden and drastic reductions in flow
should be
evaluated.

The Decision Support System (DSS) Model developed by DRBC to
evaluate
ecological impacts of different flow programs indicates that the
THPDMP
provides better protection of the fishery during low flows in the
summer
period than Revision 1 or Revision 7. This better protection can
disappear in
the fall compared to Revisions 1 and 7 and when the Montague Target is
reduced from 1850 to 1750 cfs on September 16.

4. The PFBC believes that the main stem Delaware River Trout Fishery
could be protected more effectively.

The PFBC is concerned that flows and temperatures under FFMP do not
optimize the Delaware River mainstem trout fishery as it has
historically
existed. The attached Figure 3 shows a new analysis of historical data.
This
shows that 60% of the time, Cannonsville flows modeled under Revision
1by
OASIS actually make up a higher percentage of Montague flows than the
THPDMP, inferring a greater amount of temperature benefit at all points
at
least from Montague upstream. It is also clear from both Figures 1 and
2 that
some ofthe time Revision 1 could result in more benefit to the main
stem
Delaware River than the THPDMP. We believe that in periods of low flow
and thermal stress, more stress will occur to the main stem fishery
under the
THPDMP than would likely be possible if other alternatives were
considered,
as discussed previously with minimal to no impact to the New York City
water supply.

The DSS temperature data inputs are weak and the DSS model cannot
tease
out these subtle, but important impacts.

5. Recommendations: The PFBC recommends that the adaptive management
provision of the FFMP be implemented so that some recognized
shortcomings in the current version of the THPDMP can ~e addressed. The
Subcommittee for Ecological Flows, which includes our agency, has
already advanced most of these recommendations.

Divide the L2 zone in the storage curve into two or more subzones.
Provide
higher releases in the upper L2 subzone and lower releases in the
lower
subzones. This provision would moderate impacts as we enter the first
phase
of drought watch.

Expand the use of the OASIS and DSS Models to include a broader range
of
withdrawal and release options.

Develop better estimates of unregulated flows.

Improve the weakest link in the DSS, which is temperature data and
modeling, so that we can better discern benefits and impacts of altered
flows on temperature. This is particularly critical in the mainstem
Delaware River.

Improve reservoir ramping rates to moderate rate and extent of
changes.

Change the Montague target to a weekly or similar time frame average
to limit within-week flow fluctuations.

Commit to reassess FFMP when a basin-wide reassessment study is
complete and incorporate new data as it becomes available.

The PFBC wholeheartedly supports a basin-wide reassessment of water
availability, use and needs. We understand that the Decree Parties are
pursuing a reassessment study and our agency looks forward to being a
partner in using results and available tools to optimize ecological
flows in the basin.

The PFBC recommends that the points of uncertainty identified in our
comments be addressed before final action is taken by DRBC on a flow
management program. Please contact Mr. Mark Hartle at (814) 359-5133 or
e-mail mhartle(ci).state.va.us if you have any questions or
require additional information associated with our comments.

Sincerely,


Leroy M. Young, Jr.


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