An Independent Validation Of The Drbc’s “ffmp” Is Called For

[jaydub]

FRIENDS OF THE UPPER DELAWARE RIVER
MARCH 1, 2007

AN INDEPENDENT VALIDATION OF THE DRBC’S “FFMP” IS CALLED FOR


On February 20th, the Delaware River Basin Commission (DRBC) proposed its newly formulated, environmentally damaging, “Flexible Flow Management Plan” (FFMP) for the Upper Delaware River’s wild trout fishery. The proposed FFMP, thought by many to be “Revision VIII,” will not be the last of the Agency’s assaults on the Upper Delaware’s wild trout fishery, on the fishery’s related environment, on flood mitigation, or on the local economies. There is yet another Revision scheduled for this coming October – the purpose of which the DRBC has not, as yet, disclosed to either the general public, or to the elected officials whose districts are contiguous to the River.

While it may be difficult for some to understand the motives behind the DRBC’s prolonged and complicated anti-environmental strategy – given the Agency’s public displays of concern for the upper Delaware’s wild trout fishery - it is not difficult to understand a few facts: (1) The DRBC requires the use of their computer model (OASIS) for passing judgment on the validity of any new reservoir release proposal and it is the model consistently relied on for determining – and cited for validating - virtually all reservoir release and River flow calculations. While the OASIS model is an accepted hydrological tool, there are critical concerns that the DRBC never input the past twenty years of data, that there are data entry errors, missing data and data that cannot be sourced in what has been input. There are concerns that the program’s original logic has been tinkered with, and that some of the basic assumptions the Agency installed in the model are skewed. Given the critical applications of this model, the DRBC should publicly and conclusively prove - subject to independent validation - the reliability of their OASIS. (2) Although the DRBC commissioned the highly reputable USGS, at a cost of hundreds of thousands of dollars of public money, to conduct studies of the Delaware fishery and to develop a computer habitat model (DSS) for the fishery – the use of these studies and this new model is not readily apparent in the proposed FFMP. The DRBC should publicly highlight, with supporting documentation, where, how and the extent to which the USGS work (and all of the other recent fishery related studies conducted by the DRBC, or by agencies in concert with the DRBC) were relied on in developing this plan. (3) After decades of one Revision after another, each of which seems to have had an increasingly debilitative effect on this unique fishery, there is a stark common denominator - not a single revision has ever been subject to independent validation.

For forty years, the DRBC and the City of New York Department of Environmental Protection (NYCDEP) have had their way with this unique wild resource without any objective, entirely independent scientific validation. It is time for a change! A highly qualified team of scientists should be assembled, provided the DRBC conclusions, all supporting data, all supporting documentation, complete computer models, the USGS and other fishery related studies and any other materials they may require to fully and objectively evaluate this proposed FFMP. Further, this independent team must be given full access to the same information for any previous reservoir release regimes they might request. The team should be made fully aware of solutions suggested by outside groups or individuals regarding the issue of releases. Finally, this team must be completely independent; that is, it must be free of any financial, academic, fraternal, personal or business relationships with the DRBC, its employees, members of the Agency’s subcommittee’s, subcontractors, etc. If this new proposed FFMP is to be regarded as credible, these validations must be concluded before the proposal is adopted.

We urge you to join FUDR and to call for these critically needed independent validations.

Craig Findley, President
Friends of the Upper Delaware River
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