NonBasicSpecificComments04

• Title: Comments 4
• Date: 10/23/2003
• SWSI - Doc Type: Comments

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BRIAN D. RICHTER ET AL.

Ecological Applications
Vol. 13, No.1

these flow guidelines have not received n1ucp attention ervoir operations) and other water management issues.
from the states and their proposals have not addressed In turn, the output of these n10del runs by the states
theJ1'l in any explicit way. This neglect can be largely has _ been analyzed by the federal enVirOn1l1el1tal agen..
explained by' the reluctance ~of the _negotiators to use cies to assess incompatibilities with their instrean1 flow.
flow targets that they felt had not been adequately guideHnes~
linked to desired floodplain of chanllel conditi011S and' There has been disagreenlent over some of the key
ecological responses~ While the federa.l flow guidelines inputs to these models", including the relationship be-
were supported with a narrative that described the "gen- twee.il grow'ldwater pumping and rlver flpws, irrigation
eral importance of the specified flow conditions for .delIla.nds, and other water use projections. Tremendous
sustaining species and ecosystem health, the numerical effort was expended in assembling a COll)!nOn set of
.targets were based primarily on statistical character... input data for the hydrologic models, but so~e key
izatioll of the histo~ical flow regime because the federal inputs such as irrigation water consunlPtion during
agencies hoped to preserve as much of the historicaI" . droughts was ~ery difficult to estilnate due to . lack of
flow conditions as possible. The" negotiators wanted to l'llonitoring data~ The lack o~agreement on model input
better understand ho\v'a flow ofa particular level would has been an obstacle in the negotiatiqns, because it has
fill the, channel, inundate the fioodpLaint or otherwise made comparisons of the states' proposals difficult.
affect biota in particular reaches.
Fortunately. work conducted dw~ing the Conlprehen..
sive Study did provloe infornHltioll about instrealTI hab-
itat ava"ilability in the Apalachicola River at various
low-flow levels, an~r identified high-flow levels at
which fish gain access to secondary channels and back-
water areas ill the floodpiain (Freeman et a1. 1997. Light
et al. 1998). The Florida negotiators relied heavily upon
these limited sttldles in framing their watei. allocation
proposal, while .also trying to protect as much of the.
natural flow regill~e as possible (S. Leitnlan, Orn::oOOD
em 0 ftJO[[JDrffi).
We believe the lack of adoption of any form of con-
sensus-derived e;cosyste1l1 flow requirements greatly
hindered the ACF basin negotiations. Before any set
of flow guideIin"es can he fully employ~d in the fashion
suggeste-d by Steps 1-3 of our fraluework, the stat~s
and federal agencies lllUst reach consensus on ecosys-
tenl flow requirenlents. One way to facilitate such con-
sensus might be to convene a more forn1al and rigorous
. scientific assessment of 'ecosystenl flow requiremeiits,
engaging multidisciplinary aCadeJ11ic and agency sci-
entists fronl each of the three states and beyond. An
excellent model for such structured assessment is the
B llilding Block Methodology being employed in South
Africa (King and .Louw 1998).

DCOOJOQIJDO 00000 DO 1JITlOJJ

The C0111prehensive Study produced estimates of ex.-
isting and pl.ojected water den1ands for M and I, ag-
ricultural, and other uses. Subsequently, hydrologic
sinlulation models were developed to enable as~ess-
ment of daily flC?w regimes at 14 different locations in
the basin. Alternate water management s:cenarios can
be explored by n'lodifying projected water denlands and
reservoiI' operations in the models.
Each of the tItree states has u.sed these hydrologic
ITIodeJs in developing their water allocation proposals
for consideration by the other states and federal tep...
reselltatives~ Each state has modified the 11lodel(s) to
reflect key elements of their respective proposals, e.g.,
projected growth in \vater cons1.l111ptionj proposed res-

o CDJD DO OiJITJO OOOf[J[][[il]]

While the ACF basin lies within the cOInparatively
water-rich Southeast, periodic episodes of droughts of-
ten lasting for multiple y~ars) ,do occur. During a
" drough t from 1999 to 200] the annual flows in the river
were only 40% of average. Such periods of drought
have become the nexus of conflict between human and
ecosystem needs for water. For example, l11aintaining
high reservoir levels for recreation and preserving wa-
tel' storage during droughts conflicts with needed re-
leases.- for water quality,. hyd1.~opowerJ navigation, and .
ecosystenl flo\vs. These conflicts are most acute during
. the summer) when naturally low river flows are depleted
by various human uses. In the negotiations3 suggestions
were made to cw.tail or constrain certain uses to enable
other llses to be met adequately.
The federal instream flow guidelines include t\.vo
low-flow parameters (Table 1): a linlit on the one...day
Ininiml.lm flow in each nloi1tb and a !inlEt on the max-
iInUll'l numb~r of days in each year that fio\vs can be
below a certain threshold. The water allocation agree"
l11ent fails to nleet these low-flow guidelines in SOlne
years (Fig~ 5). Therefore, the ecological sustainability
of this water allocation remains in question.

ODD [[[j!TIl rm mrnumo

The original deadline for arriving at "an acceptable
allocation formula was set by-the Compact far 31 De-
cember 1998, but the deadline was extended more than
10 times. The states are highly motivated to achieve a
negotiated agreement; the alternative is to resolve the
issue in the U.S. Supreme Court. The wa.ter allocation
pToposals submitted by each of the states have provided
the basis for the negotiati.ons. The hydrologic models
and analyses of their outputs have proved to be valuable
tools for developing, communicating, and assessing a
variety of ~vater management alternatives. Stakeholder
lneetings, technical meetingsl and workshops and other
private meetings have been conducted both inside and
outside of the formal negotiations. Each of these venues
offered an opportu,nity to .share infor.mation~ present