FFMP and the Delaware

[Big_Spinner]

Hi guys,

Here is a Morgan Lyle article:

Fly fishing: FFMP water release regulations will likely go unchanged

Fly fishing: FFMP water release regulations will likely go unchanged
Thursday, September 18, 2008
MORGAN LYLE

We now have a full year’s experience with the new rules governing water levels on the world-class trout streams of the Catskills.

Despite some grumbling about their

effect on the fishing and calls for more generous releases of water from reservoirs on the rivers, the rules could be locked in for the next three years at a vote scheduled for next week.

The Delaware River Basin Commission, which governs releases of water from New York City reservoirs to the East and West branches of the Delaware River and the Neversink River, is scheduled to meet Wednesday in Trenton, N.J. On its agenda is a vote on extending the Flexible Flow Management Program, which was established on an interim basis last September.

Advocates have been trying to get the plan modified to provide bigger releases of trout-friendly cold water, but there’s no evidence so far that they’ve been successful.

“My guess is they might push it through as is, but that’s only a guess,” said fishing guide, real estate agent and river advocate Jim Serio of Hancock, N.Y.

Serio was one of the people who talked New York, New Jersey, Pennsylvania, Delaware and New York City into adopting the FFMP — an improvement over the complex and ineffective rules that used to regulate how much water was released from New York City’s dams for the benefit of the rivers below.

But Serio freely acknowledges that the new rules still don’t provide enough water for ideal conditions. Conservation and angling groups — including Trout Unlimited, The Nature Conservancy and Serio’s group, the Delaware River Foundation, among others — agree more water should be returned to the rivers.

It’s not as though there’s not enough water to go around. New York City uses an average over the past 10 years of 508 million gallons a day, but demands that 765 million be reserved for its use. A small fraction of that amount would do wonders for the rivers.

A big complaint about the old rules was their inflexibility. Well, the new rules can be pretty inflexible too.

“In April 2008, a surge of water flowed from the Cannonsville reservoir into the West Branch of the Delaware River,” said Elizabeth Maclin, Trout Unlimited’s vice president for eastern conservation, and the state TU chairmen from New York, New Jersey and Pennsylvania in a letter to the DRBC.

“In late April, the water flow was cut down to just a trickle, 5 percent of what it was just days before. Even though the reservoirs were almost completely full, the rules dictated this dramatic reduction in the amount of water released into the river. When this type of reduction in flow occurs, the river and its tributaries get smaller and the fish and wildlife habitat is greatly compromised.”

But while the flows allowed under the FFMP are too small, and the river levels sometimes jump around willy-nilly to meet that flow target in New Jersey, the concept of the FFMP is sound, Serio said.

“Let’s keep FFMP in place for at least another year with two modifications: increase the summer flows to 350 cfs, and eliminate the yo-yo flows,” he said. “There’s plenty of water. We are totally blessed to have around 45 inches of precipitation a year, and if it’s managed properly, there’s enough for everybody.”

 

[Big_Spinner]

Hi,

What bothers me with all the negative talk about FFMP is that there is no alternative suggestion given.

FFMP can be significantly improved without much modification.

It just needs more water to be made available to it. Tihs has been the ongoing constraint to any system that has been in place.

Rev 7 was not bad, just needed more water.

The interim FFMP provides the framework for getting more water for the system and it should be tweaked now and evaluated every few motnhs while the rest of the important studies are completed. This will allow for more improvements moving forward.

A combination of FFMP and Rev 7 that would provide for greater releases and establish minimum flow targets may be the best short term solution. But that is another story.

Jim

 

[quality time]

“Let’s keep FFMP in place for at least another year with two modifications: increase the summer flows to 350 cfs, and eliminate the yo-yo flows,” he said. “There’s plenty of water. We are totally blessed to have around 45 inches of precipitation a year, and if it’s managed properly, there’s enough for everybody.”

AMEN to that Jim!

QT

 

[NJFred]

Clarify the fishery objectives... Keep entire WBD cool (72 degress and below) and the river bottom wet to protect habitat and fish. Create thermal refuge in upper part of mainstem... Junction and 2 to 3 miles downstream. Release more water to upper East and Neversink as a secondary objective if possible. (far more important to creat thermal refuge in the main then to use water alternatively for more releases into the east and neversink)

Here's my thought on how to improve FFPM to meet above objectives. Kick up minimum releases from Cannonsville across the late spring to early fall by 150CFS. (e.g. Instead of 100 or so CFS we'd have at least 250 CFS at the moment).

Reinstitutre a thermal relief safety valve based on the Hancock and Lordville gauges. Should temperature's exceed 70 degrees at Hancock, release more water. Should temperatures at Lordville exceed 75 degrees release more Cannonsville water. (if you think about it, a thermal release trigger is good for both fish and NYC as it can only save water as it's only used when needed. Doing away with it was a huge mistake!)

I think there is enough water to accomplish this in a normal year. Look at all the water in Cannonsville today (particularly due to all the water saved by the use of downstream water from PPL and very notably Alliance in meeting the Montague mins).

Comments? (one concern I have given this year's history would be does this keep enough water in the Upper Main which has been as low as I can remember due to PPL AND alliance power gen)

 

[Big_Spinner]

Hi Fred,

All good stuff.

Jim

 

[brachycentrus]

Hi,

What bothers me with all the negative talk about FFMP is that there is no alternative suggestion given.

FFMP can be significantly improved without much modification.

It just needs more water to be made available to it. Tihs has been the ongoing constraint to any system that has been in place.

Rev 7 was not bad, just needed more water.

The interim FFMP provides the framework for getting more water for the system and it should be tweaked now and evaluated every few motnhs while the rest of the important studies are completed. This will allow for more improvements moving forward.
A combination of FFMP and Rev 7 that would provide for greater releases and establish minimum flow targets may be the best short term solution. But that is another story.

Jim

Jim,
What are the important studies that havent been completed yet?

Here are a few suggestions :

Take 1 vote away from NY so that the Decree parties would have a level playing field to incorporate change.

Mitigating releases to compensate for Wallenpaupak and Mongaup.The DRBC recognized the danger of less upstream releases due to power generation and boating releases, yet still failed to adequately address or mandate them.
Any FERC involvement or order should have to be voted on by the Decree parties. Seems like FERC has played more of a role in this than should be allowed as far as power and boating releases on PPL and Alliance energy hydro.


In lieu of this, temperature and flow targets downstream that protect the river at least to Lordville. Even Revision 1 had protection all of the way to Callicoon. Then they whittled it down to Hankins, then Hancock, then nothing..........

Define the objective:
I know I,ll hear crap on this one, but what the hell. It is nice to say more water should be apportioned equally, but if the objective is to protect and enhance the existing wild trout fishery on the Upper Delaware, I question why more water should be given to the East Branch and Neversink. The extra water that was given to those rivers reduced the WB releases which helped put the Upper MS at risk.

 

[Agust]

I spent yesterday late morning and early afternoon in Albany, with folks from Governor Paterson's office, NY DEC, various flood groups, Jeff Zimmerman(attorney for FUDR and one of the flood groups), Lee Hartman (PA TU) and some folks from various NY legislators offices.

The talking heads at NY DEC and the engineer for NY on the DRBC seem convinced that the FFMP is "doing a better job". A claim that pretty much everyone in the room, and in general everyone except NY City, disputes. At this point there does not appear to be any of the decree parties willing to step up and veto accepting FFMP as the plan of record.

It appears that NY state acknowledges that the Main Stem is in no way protected, and that this also is "by design". Everyone admits that there is plenty of water, even NY City, but they also insist that any plan must allot every drop of the 800 million gallons a day to NYC. Even though the actual use is about 500 mgd, and long term forecast for 2035 does not exceed 600 mgd. The "reason" for this is that NYC does not want to have everyone become "dependent" on the excess water, and have a claim to it "in the future". The obvious flaw in this is that New York City has the supreme court decree allowing it to use the 800, for drinking water. It also demands that safe yield be computed every year, based on previous years consumption, but that is not occurring. Meaning that there is plenty of water in the system for everyone for at least another 25 years, but NYC is would prefer to sacrifice the current health of the river in case sometime in the 2100 or 2200's they may need all the water.

At present, with the numbers being used by the FFMP, no one I know or trust in the environmental or angling or flood concern group thinks the FFMP should be accepted. At a minimum the vote must be delayed until the horrific and egregious harm cause by the initial mis-calculations are corrected. Hopefully an overflow crowd at Trenton on the 24th will pressure the DRBC to refrain from accepting the plan, until the errors are corrected and all the excess water is allocated to habitat flows. Including changes to prevent the huge fluctuations of flow ( 900cfs to 45cfs in a single day), adequate procedures to prevent thermal problems and low flow issues in the entire watershed (including Neversink, East Branch and Main Stem.) In addition, flow targets need to be set for Cannonsville and Lordville and Montague that include averages, so that the River Master can gradually increase or decrease the flows to meet targets without the constant Fully Open/Fully Closed current protocols.

As Jim mentioned, a truly flexible flow plan is needed, and the FFMP shows great promise if the correct data is used. but as this past summer indicated, the rigid and stingy number in the existing trail year were a complete and utter failure and demonstrated No flexibly and gross mismanagement.

 

[brachycentrus]

Agust,
Thanks for the report.
If the main stem was allowed to warm by design, what would the implications be for the wedge mussle issue?
Is this still a topic for discussion?
Thanks,

 

[Agust]

Agust,
Thanks for the report.
If the main stem was allowed to warm by design, what would the implications be for the wedge mussle issue?
Is this still a topic for discussion?
Thanks,

The issue is that the dwarf wedgemussels do not appear to have been considered. Which as you might expect is indeed a topic of discussion, and did elicit some concern from the governor's representative. Especially when presented with a picture of 4 dead federally listed endangered species.

 

[Big_Spinner]

Hi Agust,

I for one do not believe that the FFMP should be voted down.

Clearly, FFMP has some advantages over Rev 7 and Rev 7 has some advantages over FFMP. Either will work if they are given more water. That has been the battle all along.

Everyone that has said that does not present or offer what will happen when and if it does get voted down.

I think we revert to Revision 1.

FFMP should be continued on an interim basis. Get the water allocation raised (the hard part) and it is a simple matter of inserting new numbers into the FFMP matrix that would optimize the releases and flows for the rivers.

We do not want to allow FFMP to be voted in for the three year period, without some improvements. The only way to accomplish that is to ask for it to be continued on an interim basis. If it gets voted in for three years, then no one will do anything for 2.5 years and then there will be push to have it approved for the next 5 year period. IF it stays in operation on an interim basis, there is a better chance to make changes in the short term.

Jim

 

[Big_Spinner]

There was discussion with Fish and Wildlife service at the SEF meeting concerning the DWM. They are going to consider a flow target at Callicoon to protect the DWM. I do not think it will be a high enough target to do much good for anything concerned.

A Lordville target would be better to protect the more northern populations and if the northern populations are protected, so will the others.

Jim

 

[Green Highlander]

Serio was one of the people who talked New York, New Jersey, Pennsylvania, Delaware and New York City into adopting the FFMP — an improvement over the complex and ineffective rules that used to regulate how much water was released from New York City’s dams for the benefit of the rivers below.

But Serio freely acknowledges that the new rules still don’t provide enough water for ideal conditions. Conservation and angling groups — including Trout Unlimited, The Nature Conservancy and Serio’s group, the Delaware River Foundation, among others — agree more water should be returned to the rivers


...This is the reason why I suggested that all of the acronym organizations need to back off, look in the mirror and accept the fact that because of your noble efforts (and I don't mean it sarcastically) the system is worse off. The above sounds like a John Kerry speech "I was for it before I was against it". The FFMP is a horrible plan and needs to be scrapped, not tweaked. Ask for a constant 450cfs from the Cannonsville all year round and all of our problems will be solved. As long as there is a steady 450, they can pull all they want from the Lackawaxan to meet the Montague targets.


GH

 

[Big_Spinner]

Hi All,

My position has never changed.

Get as much water for the ecological benefit of the rivers.

FFMP provides a mechanism to do that.

There are two separate issues.

First, How much water can you get?

Second, How to best distribute that water over four rivers and 365 days?

FFMP solves the second question.

Now, solve the first question. Get more water and FFMP will do a good job of distributing that water to the rivers and seasons to protect and enhance the river habitat.

Jim

 

[oasis man]

I have just received a response from Dan Plummer of FUDR, in response to my question as to what will happen if FFMP is voted down.
His reply is that their lawyer's opinion is that either they will go back to Revision 1, or a new revision could be created as an interim that would hopefully satisify the needs of the endangered species,habitat, and the fishery.
I do not recall the details of Revision 1. But if this is indeed a possibility, I think it prudent for this Revision to be presented in this forum so that folks will know what they might be asking for.
An informed decision on this issue is important for all of us who really care about this fishery.
OM

 

[NJFred]

The real issue here, which probably even matters more than which plan we end up is the advent of increasing downstream water to meet the Montague targets.

If you have been following the river closely this year, you would see that PPL has been releasing lots of water out of Wallenpaupack into the Laxawaxan and Alliance Energy out of the Rio resevior releasing into the Mongap. PPL is not necessarily new but the new licensure of Alliance has really hurt releases from Cannonsville this year. They tend to be operated in a planned fashion so when one is releasing the other is not minimizing the need of upstream water releases.

In another year at another time the weather pattern we had this summer would have provided plenty of Cannonsville water to meet Montague mins. Cannonsville is at 70% as I type this. In years back we would have been at 40% or 50% for this type of relatively dry year. All that water released down the WBD and into the Main.

One of the real tragedy's has been the low flows in the Upper Main Stem with flows at Lordville reaching a low of something like 340CFS. I can't recall the last time the Upper Main ran this low. We saw the pictures. All that exposed river bed created huge damage to inscect life not to mention the endangered Zebra Mussle.

Paradoxically, downstream water does make more water available in the upstream NYC reseviors. It's theoretically a key part of a long-term solution for the fishery. But the powers that be simply won't give the fishery a drop of the saved upstream resevior water unless they are forced by law. It's pretty clear that they could give a hoot about the fishery and eco system of the Delaware.

 

[brachycentrus]

NYC Reservoirs Docket and Resolutions

Revision 1
D-77-20 through 90-12

Revision 1 provides thermal protection down to Callicoon. As I read it, they realized that they initially did not budget enough water due to PPL and Mongaup releases, so they passed amendments authorizing more water to be released.
The effects of the two rivers generating power is not new, just the strategy of NYC has changed.
If you follow the history of Revision changes you'll see the abandonment of Callicoon, then Hankins, then Hancock as thermally protected water.

 

[NJFred]

Regarding Allaince and PPL.... aren't the quantities of water different than in the past? More can be released?

 

[Big_Spinner]

Hi,

Rev 1 - which everyone hated by the and one of the reasons we all tried to get something better.

Cannonsville Release: June 15 - August 15 = 325 cfs minimum
Cannonsville Release: The rest of the summer and year = 33 or 45 cfs minimum

Pepacton Release: June 15 - August 15 = 70 cfs minimum
Pepacton Release: The rest of summer and year = 45 cfs minimum

Temperature targets are the same as revision 7:

Release water from the thermal bank (6000 cfs-day) if temps were going to exceed 75 as a max or 72 as a daily average. This never worked. Not enough water and increased yo-yo releases.

Revision 7 thermal and habitat bank was increased to 20,000 cfs-days.

I do not believe that there could be any other untested release protocol that could gain approval by next week.

Going back to Revision 1 is a huge step in the wrong direction.

Releases from Cannonsville during May and the first two weeks of June, would be 45 cfs and many of you complained (and I agree) that 215 cfs in May and 260 cfs in June under FFMP was not enough. Release from Cannonsville would drop to 45 cfs on August 16th if there were no temperature concerns!!! Many of you have forgotten the times when the release all winter on the WB was 45 cfs or when we went into drought emergency a release of 8 cfs in the winter or 23 cfs in the summer. All of this is under revision 1.

Jim

 

[brachycentrus]

Jim,
That may be the case and there were times of concern. But at the time, there also were consistant Montague releases out of Cannonsville.
This fishery developed from those releases.
If FFMP were in place at these current numbers, I doubt that this fishery could ever have developed.
If I had a choice between anchor ice in the winter and lethal summertime temps, give me the anchor ice.
History has proven this by the very existance of this fishery.

 

[Big_Spinner]

Hi Brachy,

You are just wrong about the consistant Montague releases.

They were no different then as now. There is just variation from year to year.

There were so many years that we begged for water in June when the release was only 45 cfs.

Jim

 

[Big_Spinner]

Hi Fred,

PPL does not release more or less water than in previous years.

PPL has lake level targets tht they need to obey. Those targets have changed only in timing and not total quantity.

They still need to be at the same lake elevation on September 1st.

Jim

 

[Big_Spinner]

Just to be clear so that you can form your own opinion:

These are minimum releases

Cannonsville May release

Rev 1 = 45
FFMP = 215

Cannonsville June release

Rev 1 = 45 1st to 15th and then 325
FFMP = 260

Cannonsville July release

Rev 1 = 325
FFMP = 260

Cannonsville August release

Rev 1 = 325 1st to the 15th then 45 cfs
FFMP = 260 cfs

Winter

Rev 1 = 33
FFMP = 80

Jim

 

[Agust]

The only agency that can make the decision is the DRBC, and the parties that make up the DRBC. Regardless of what Jim, Dan, Agust, "Green Highlander" or anyone else wants. That is not throwing my hands up in defeat, just a simple statement of fact. Next Wednesday there are 4 possible outcomes.

1. Accept FFMP as is.
2. Reject FFMP completely.
3. Defer voting until the FFMP can be tuned and the last year analyzed.
4. Pull a rabbit out of their collective ... uh ... hats and surprise everyone with a new plan.


The last is very unlikely, the second is extremely unlikely (to much invested in time and money by DRBC). The most likely choices are the odd ones and the first, accepting as written, is a very real possibility. So far NYS, PA and NYC all seem likely to vote for it. DE usually just follows PA, NJ is the wild card but has a history of acquiescing to NY, especially under the current Governor.

Honestly choices 1,2 and 4 are likely to be bad for the trout fisheries in all of the rivers, and especially the Mainstem. I believe we need to push very hard for a deferral of the vote. If for no other reason than to give the DRBC a chance to see the folly of the current parameters of the FFMP, and correct it before committing to a three year plan. (with 2 automatic 5 year renewals ) If you thought this year was bad, imagine the river after 13 years of this mis-management.

And quite frankly there is no other proposal on the table, so suggestions to the contrary will not be considered unless the vote is deferred.

As Jim stated, the FFMP can solve the issues if the correct numbers are used. Primarily if safe yield is accurately calculated and releases set accordingly. After all the 300 mgd overestimation of usage by NYC, is over 100 Billion gallons a year. There is plenty of water, the DRBC has a responsibility to allocate it fairly for all interests and we need to hold them to that.

 

[Big_Spinner]

Hi Agust,

Deferring the vote I think allows for Revision 1 to take over October 1st.

A possible option would be to extend the interim FFMP for a period of time. It may actually extend on its own, if no vote is taken. I will try to check on it.

Personally, I would prefer to extend the interim FFMP rather than go back to Revision 1.

Jim

 

[oasis man]

AGUST,
With regard to option 3 (defer voting until FFMP can be tuned) , this would be my choice, however, what can be done to get NYC to accept additional releases?? The coalition did detailed work,( hundreds of hours of work) , showing that additional releases could be achieved with extremely small increases in drought days over the study period, and they rejected all proposals that did not fall within their extremely conservative approach.
So unless there is a new approach that the fishing community can rally around, even if option 3 is accepted, I have heard of no plan that will get NYC to change their mind.
In my view, the only positive value that legal proceedings would have is to somehow publicly embarass the NYC folks...but they have pretty thick skins, and they can present their approach as one that is protecting the drinking water of 9 million NYC recidents...
OM

 

[Agust]

If they defer the acceptance vote, they can chose to default to Rev 1 (unlikely) or continue the existing FFMP (probable).

As to whats new, the horrid results of the interim plan are hard to ignore. In addition there is a new Safe yield study, that confirms the availablity of the water we all know is there. It does need review by NJ, Army Corps and DRBC proper. There is also quite a bit of "interest" in how the September 6th artificial drought may have contributed to dead dwarf wedgemussels. It's possible the NPS or EPA may interject and demand a delay.

Time is our only ally at this point. If allowed to continue the interim FFMP until all data is evaluated, we stand a better chance of getting reasonable changes made to the FFMP before ratification.

Those of you harking back to Rev 1, would do well to remember that because of the bad valve NY seldom was able to shut the West Branch down as much as they legally could. Now they can, and Rev 1's mandated flows are abysmal. So Jim, we are on the same page, FFMP as it stands is not "good" (but can be) but Rev 1 was most assuredly horrid (and continues to be so).

 

[quality time]

As Jim stated, the FFMP can solve the issues if the correct numbers are used.

I believe this is the tact that should be taken, as it has the highest chance of success. FFMP, while flawed, does put more overall water in the system than the other options. I have been critical of those that have maintained an idealist attitude throughout the years on this subject, calling for arbitrary mandatory releases. The reality of the situation is mega-complexity.

First of all, everyone seems to forget that if it weren't for NYC's dams, the fishery wouldn't exist at all. Now factor in the environmental issues (mussels, etc.), flood control issues, water supply protection issues, and the fishery issues, and it is clear that a one size fits all mandatory constant release is never going to happen. There are way too many interests involved, all competing with each other in some ways, and in others complementing each other.

As an example, the flood control groups would like to see more water released, which would seem to be consistent with what the fishery people would like. However, the timing for their desired draw-down would be most likely in the spring. The fishery people would prefer to reserve some of that water for the warmer times. A flexible plan that would address both of these issues through fair balance is obtainable through compromise. The bigger problem, however, is that water balancing equation becomes very complex when you factor in the rest of the interests.

FFMP was a good first step in this direction. Now let's keep lobbying for additional incremental changes to fine tune the plan in a manner that keeps putting more water into the river. The board is going to want to move slowly on this, and they will be more likely to approve small changes and watch for any negative impacts......boards tend to be conservative unless there is a clear reason justifying aggressive actions, which doesn't exist in this situation. So long as there are no negative impacts, we will be able to keep lobbying for additional changes to the planover time. Perhaps, we can even make some allies with the other interests?

Just my two cents worth.

One other thing I do want to say.....I really appreciate the passion and dedication of all the fishery people on this issue, regardless of their stance on the 'how', everyone's stance on the 'what' is clear and passionately defended!

QT

 

[NJFred]

I think GH had it right.

The key is more water released from Cannonsville.

Moving from one plan to another sure seems like nothing more than rearranging the deck chairs on the Titantic.

Personally I'd be fine with FFMP with 150CFS to 200CFS more release through out the late spring thru fall. AND... a temperature trigger for a release at Lordville or at least at Hancock and a decent bank to pull from so that it's meaningful.

 

[Green Highlander]

Man, the first time I suggested that everyone should back off, I set a personal record for groans and it's good to see that the groaners have come around. If you look at Rev 1 vs. FFMP in the critical months of July and August, Rev 1 delivers the water that is desperately needed in the hot months and the FFMP releases at the same time are clearly inadequate. FFMP was dumping nearly a 1000 CFS in the middle of winter and posters were taking a victory lap because there was no anchor ice in January...save that water for part of June, July and August. FFMP is a failure, we need to accept it and move on with one organization, one voice, one vision, one objective and one plan. Constant 450cfs all year out of the Cannonsville.

GH

 

[Big_Spinner]

Hi GH,

While 325 is certainly better than 260 from June 15 - August 15th, what about May and the rest of summer when the release from FFMP is still 260 but Rev 1 drops to 45 cfs?

Pepacton summer release of 70 under Rev 1 instead of 140 under FFMP.

I think we all agree that we need more water, how do we get it?

It would be great if we could save that 1000 cfs winter release to release in the summer, but you can't. The release is that high when the reservoir is almost full. The idea is to release that water in a controlled way and not let it spill without control in the Spring. I was one of the people saying that FFMP was a good thing to do this. The alternative under Rev 1 would be to release 45 through the winter and then let 10,000 spill in the spring.

Now, ideally, it would be best to release that water the summer before it falls!! The reservoir is going to spill whether you release 260 or 450 or 800 through the summer.

The other option would be to raise the reservoir and capture that water for release in the summer. This is the only way to make sure tha the water is actually there to release.

Jim