brachycentrus
Just finished a River Runs Through it!
Can anyone or is anyone willing to shed some light on this ?
February 19, 2007 Ms. Carol Collier Executive Director Delaware River Basin Commission.
Dear Ms. Collier:
Following up on my letter of February 16, I am writing to explain in more detail why we are requesting copies of any DRBC studies (and supporting data) showing that constant minimum releases from Cannonsville of approximately 600 cfs cannot be implemented. Water temperature is critical to the survival to the upper Delaware’s wild trout population - most especially from Spring through early Fall. Underscoring this point is a 1980 study of the Delaware by Dr. Walter Sheppard, PhD., (commonly referred to as the Sheppard Study) that clearly states a release of 325 cfs from Cannonsville would not be adequate to maintain the temperature needs of trout in the upper Delaware River. This conclusion is fully supported by long time, “hands on” experts that live on and analyze the river on a daily basis. It’s well known that several of those long time River experts are members of FUDR; they have spent the majority of their adult lives living on or near and/or working on the upper Delaware, and they have maintained careful observations and detailed personal records. These records clearly show that 600 cfs constant minimum releases, from mid May through September, can and have been provided safely (without jeopardizing the needs of the City or any other consumer) in almost every year. Supporting these personal observations, are the records of the USGS flow/temperature gage at Stilesville (located immediately down river from the Cannonsville Reservoir) showing that average Cannonsville releases, during this time frame, were well over 600 cfs. (We have a link to this gage on our website). I realize, of course, that these are averages. Still, this combination of personal records and observations with historical data from the Stilesville gage does suggest that the issue may not be one of sufficient water availability, but rather one of water management. A study commissioned a number of years go by Trout Unlimited by Dr. Piotr Parasiewicz, then at Cornell University, titled “Strategy for Sustainable Management of the Upper Delaware River Basin,” concluded that 600 cfs were available. In fact, Dr. Parasiewicz recommended adoption of a constant minimum release regime of 600 cfs from early Spring to early Fall, and a 300 cfs release regime for the remainder of the year. When the study was completed, it was widely distributed. Moreover, TU summarized the study – advocating that a 600 cfs release regime be adopted – in articles they published in leading fly fishing magazines. FUDR has a complete, un-redacted, copy of the study on our website (www.fudr.org). In addition to personal observations and records, historical flow and temperature data and the Parasiewicz study, all supporting the need for and feasibility of minimum summertime releases from Cannonsville of 600 cfs, FUDR asked Dr. Peter Kolesar, PhD., Columbia University, to launch a major study to see if the 600 cfs plan was feasible. The results of his work (to the extent we have seen it) shows that a constant minimum release of 577 cfs can be provided for the fishery from June 1 through the end of September - in nine out of ten years. In the “tenth” year, releases would have to be reduced. (However, we would argue that any needed reductions should be implemented proportionately so that the burden falls equally on all River users.) Interestingly, Dr. Kolesar also determined that there was no statistical relationship of significance between reservoir levels at the end of September and the following June first. The complete, un-redacted study (as of last winter) is on our website. More recently, it’s our understanding that Dr. Kolesar has been working closely with the City of New York and the DRBC in developing a new release regime – an Adaptive Minimum Release. We realize, and history shows, that many different methodologies, advocated by many different people, have been suggested as solutions to an effective release regime for the upper Delaware’s fishery: constant minimum, probability of refill, arbitrarily determined banks, adaptive minimum, flexible flow, arbitrary targets, etc. Some of these have been implemented - and failed. Some have yet to be proven. It does appear to us, however, that an adequate (600 cfs or near) constant minimum release can be safely implemented, that it would be in the best interests of the fishery, aquatic insects, and local tourism economies and would provide easily verifiable compliance by the average angler through the USGS gaging stations. Having said that, however, we are committed to what is in the best interests of the fishery and its related ecology. We have also had the opportunity to be briefed on the new DSS computer model, which is, as you know, a habitat model. That is, it is a model that will allow for educated guesses as to how many fish there will be with a given amount of water at given locations along the River, and there is a temperature overlay to this model. While this is a very useful tool in studying the fishery, the model was never designed to, nor does it, recommend reservoir release rates or, to our knowledge, “real time” water temperatures that are critical to the fish, the bugs, and the local economies. At best, release projections would have to be extrapolated from a combination of the DSS model and the OASIS model. This brings us to the OASIS model. OASIS is the model consistently relied on and referenced by the DRBC, NYC, NYSDEC, etc., for determining fishery related releases, among its other applications. It also is the model required by the Parties to the Decree for their consideration of any new proposal. As you know, FUDR learned a year and a half ago that, in spite of its importance as a decision making tool, the past nineteen years of data had never been entered into the model. Moreover, as you also know, OASIS has been found to have data entry errors, data that could not be sourced, and questions re people ‘tinkering’ with the program’s original logic. This model has been used for years including through much, if not all, of Revision VII (the current Fishery Management Plan). Unless these problems have been corrected and those corrections validated, studies based on the model would, we think, be suspect to any reasonable person - certainly to FUDR. All of the above, as I hope you can appreciate, has lead to our dilemma regarding the new proposed Revision VIII (or at least the proposed methodology for the Revision, since we have not seen any actual final numbers) and my request of a couple of days ago. There is, in our opinion, a substantial foundation for our continuing to advocate for an easily monitored, constant minimum release at or near 600 cfs from Cannonsville during the warm weather months of the year, something the DRBC, the City, et al., has consistently rejected. Yet we have not seen any studies, based on reliable modeling that disproves the feasibility of this scheme. Hence my request; can you forward to us studies that prove what we suggest cannot be done? Certainly, we all want what is in the best interest of the fishery, and the opportunity for us to review your studies would be helpful in our understanding. Thank you Carol. Craig Findley President Friends of the Upper Delaware River
February 19, 2007 Ms. Carol Collier Executive Director Delaware River Basin Commission.
Dear Ms. Collier:
Following up on my letter of February 16, I am writing to explain in more detail why we are requesting copies of any DRBC studies (and supporting data) showing that constant minimum releases from Cannonsville of approximately 600 cfs cannot be implemented. Water temperature is critical to the survival to the upper Delaware’s wild trout population - most especially from Spring through early Fall. Underscoring this point is a 1980 study of the Delaware by Dr. Walter Sheppard, PhD., (commonly referred to as the Sheppard Study) that clearly states a release of 325 cfs from Cannonsville would not be adequate to maintain the temperature needs of trout in the upper Delaware River. This conclusion is fully supported by long time, “hands on” experts that live on and analyze the river on a daily basis. It’s well known that several of those long time River experts are members of FUDR; they have spent the majority of their adult lives living on or near and/or working on the upper Delaware, and they have maintained careful observations and detailed personal records. These records clearly show that 600 cfs constant minimum releases, from mid May through September, can and have been provided safely (without jeopardizing the needs of the City or any other consumer) in almost every year. Supporting these personal observations, are the records of the USGS flow/temperature gage at Stilesville (located immediately down river from the Cannonsville Reservoir) showing that average Cannonsville releases, during this time frame, were well over 600 cfs. (We have a link to this gage on our website). I realize, of course, that these are averages. Still, this combination of personal records and observations with historical data from the Stilesville gage does suggest that the issue may not be one of sufficient water availability, but rather one of water management. A study commissioned a number of years go by Trout Unlimited by Dr. Piotr Parasiewicz, then at Cornell University, titled “Strategy for Sustainable Management of the Upper Delaware River Basin,” concluded that 600 cfs were available. In fact, Dr. Parasiewicz recommended adoption of a constant minimum release regime of 600 cfs from early Spring to early Fall, and a 300 cfs release regime for the remainder of the year. When the study was completed, it was widely distributed. Moreover, TU summarized the study – advocating that a 600 cfs release regime be adopted – in articles they published in leading fly fishing magazines. FUDR has a complete, un-redacted, copy of the study on our website (www.fudr.org). In addition to personal observations and records, historical flow and temperature data and the Parasiewicz study, all supporting the need for and feasibility of minimum summertime releases from Cannonsville of 600 cfs, FUDR asked Dr. Peter Kolesar, PhD., Columbia University, to launch a major study to see if the 600 cfs plan was feasible. The results of his work (to the extent we have seen it) shows that a constant minimum release of 577 cfs can be provided for the fishery from June 1 through the end of September - in nine out of ten years. In the “tenth” year, releases would have to be reduced. (However, we would argue that any needed reductions should be implemented proportionately so that the burden falls equally on all River users.) Interestingly, Dr. Kolesar also determined that there was no statistical relationship of significance between reservoir levels at the end of September and the following June first. The complete, un-redacted study (as of last winter) is on our website. More recently, it’s our understanding that Dr. Kolesar has been working closely with the City of New York and the DRBC in developing a new release regime – an Adaptive Minimum Release. We realize, and history shows, that many different methodologies, advocated by many different people, have been suggested as solutions to an effective release regime for the upper Delaware’s fishery: constant minimum, probability of refill, arbitrarily determined banks, adaptive minimum, flexible flow, arbitrary targets, etc. Some of these have been implemented - and failed. Some have yet to be proven. It does appear to us, however, that an adequate (600 cfs or near) constant minimum release can be safely implemented, that it would be in the best interests of the fishery, aquatic insects, and local tourism economies and would provide easily verifiable compliance by the average angler through the USGS gaging stations. Having said that, however, we are committed to what is in the best interests of the fishery and its related ecology. We have also had the opportunity to be briefed on the new DSS computer model, which is, as you know, a habitat model. That is, it is a model that will allow for educated guesses as to how many fish there will be with a given amount of water at given locations along the River, and there is a temperature overlay to this model. While this is a very useful tool in studying the fishery, the model was never designed to, nor does it, recommend reservoir release rates or, to our knowledge, “real time” water temperatures that are critical to the fish, the bugs, and the local economies. At best, release projections would have to be extrapolated from a combination of the DSS model and the OASIS model. This brings us to the OASIS model. OASIS is the model consistently relied on and referenced by the DRBC, NYC, NYSDEC, etc., for determining fishery related releases, among its other applications. It also is the model required by the Parties to the Decree for their consideration of any new proposal. As you know, FUDR learned a year and a half ago that, in spite of its importance as a decision making tool, the past nineteen years of data had never been entered into the model. Moreover, as you also know, OASIS has been found to have data entry errors, data that could not be sourced, and questions re people ‘tinkering’ with the program’s original logic. This model has been used for years including through much, if not all, of Revision VII (the current Fishery Management Plan). Unless these problems have been corrected and those corrections validated, studies based on the model would, we think, be suspect to any reasonable person - certainly to FUDR. All of the above, as I hope you can appreciate, has lead to our dilemma regarding the new proposed Revision VIII (or at least the proposed methodology for the Revision, since we have not seen any actual final numbers) and my request of a couple of days ago. There is, in our opinion, a substantial foundation for our continuing to advocate for an easily monitored, constant minimum release at or near 600 cfs from Cannonsville during the warm weather months of the year, something the DRBC, the City, et al., has consistently rejected. Yet we have not seen any studies, based on reliable modeling that disproves the feasibility of this scheme. Hence my request; can you forward to us studies that prove what we suggest cannot be done? Certainly, we all want what is in the best interest of the fishery, and the opportunity for us to review your studies would be helpful in our understanding. Thank you Carol. Craig Findley President Friends of the Upper Delaware River
