TGF sample letter Delaware flows

[T1]

[sample letter TGF is using for their members to use as is or modify as they see fit -- must be sent before Friday, 1/18]



Pamela M. Bush, Esq.
Commission Secretary
Delaware River Basin Commission
P.O. Box 7360
West Trenton, NJ 08628-0360

Re: Public Comment to DRBC on the Interim Flexible Flow Management
Plan for Operation of the New York City Delaware Basin Reservoirs

Dear Ms. Bush:

I write to urge the Commission make improvements to the interim Flexible Flow Management Plan (FFMP) now under consideration by the DRBC. As a fisherman, conservationist and member of the Theodore Gordon Flyfishers (TGF), I believe that the FFMP as it is now proposed is only a modest improvement in the management of the valuable Delaware River resource but it does represent a step in the right direction. I believe that the FFMP can and must be improved in ways that will benefit the environment of the Upper Delaware Basin without additional risk to the water supply.

I ask that the DRBC adopt the following improvements to the FFMP proposed by the Conservation Coalition, of which TGF is a member, before implementing the FFMP:

• Adopting the Augmented FFMP proposed by Dr. Peter Kolesar of Columbia University and the Delaware River Foundation that would add additional release matrices to FFMP to set higher release levels when New York City Diversions are less than 700 MGD and less than 600 MGD. These changes reduce spills and provide larger voids in late summer modestly reducing the risk of flooding;

• Modify the flow at Montague, New Jersey mandated under the Decree on a seasonal basis rather than a fixed target; adjust it to reflect actual environmental needs; and manage the flow on a weekly average (as opposed to daily) basis so that river flow does not fluctuate rapidly that is harmful to the river environment and detrimental to recreational use of the river;

• Adopt a more rational approach to decision making including evaluating drought risk based on a range of factors and not on a single “total drought days” factor;

• Improve the FFMP by including additional seasons to better reflect ecological and hydrological factors through the year; and

• Update the OASIS model so that the data set is up-to-date and add new data to the model on an annual basis.

I urge you to adopt these sensible modifications to the interim FFMP. These changes will provide a significant improvement to the environment, especially the world-class Delaware River trout fishery, with no additional risk to the water supply. Thank you for the opportunity to participate in this important process. I hope you will consider my views and those of others like TGF and the Coalition who want to preserve this unique natural resource by working together in a reasonable and cooperative manner.

Very truly yours,
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Please send your letter before the deadline in any of the following three ways:

1. E-mail - to paula.schmitt@drbc.state.nj.us

2. Mail - to Pamela M. Bush, Esq., Commission Secretary, Delaware River Basin Commission, P.O. Box 7360, West Trenton, NJ 08628-0360

3. Fax - to (609) 883-9522