The Musconetcong Watershed Association Opposes the DRAFT Lake Hopatcong Water Level Management Plan
Information about the Revision of the Lake Hopatcong Water Level Management Plan
The Musconetcong Watershed Association (MWA) participated in the Citizens Advisory Committee (CAC) which was formed by the NJ Department of Environmental Protection, in part, to ensure that the Musconetcong River and all of its uses and users were fully considered in the revision of the Lake Hopatcong Water Level Management Plan. Subsequent to the final scheduled meeting of the CAC, the NJDEP unilaterally amended the draft LHWLMP without input from the CAC.
It is a section of this altered Plan to which the MWA and many other downstream users of the Musconetcong River object. Specifically it is the paragraph found on page 32 of the DRAFT Plan titled â€œLow Waterâ€ in the CHANGES FROM NORMAL OPERATION section that concerns us. This added paragraph will allow manipulation of the dam without notice to the members of the CAC or downstream users. It will allow NJDEP to reduce the outflow of the Lake Hopatcong Dam to the Musconetcong River not based upon any declared emergency, but to optimize recreational uses on the lake. Insertion of this paragraph into the Plan creates a loophole unacceptable to downstream stakeholders as it allows continued violation of the minimum passing flow.
As of January 18th 17 municipalities, the Musconetcong River Management Council, Hunterdon County the Musconetcong Sewerage Authority, Hackettstown Municipal Utilities Authority and Heritage Conservancy have passed resolutions calling for the removal of â€œLow Waterâ€ paragraph.
It is important to note that while the issue of arbitrary lowering of the outflow was discussed at several meetings, the CAC was told that â€œthe Department (NJDEP) cannot damage downstream uses including the ecology of the Musconetcong River for the benefit of Lake Hopatcong. It is likely that low water levels in the Lake during the boating season will coincide with hot / dry weather patterns. Under these conditions maintaining passing flow out of the Lake will be critical, since it is likely that other tributaries to the Musconetcong will also be flowing at very low levels.â€ (Larry Baier, NJDEP, Chair Citizens Advisory Committee, Meeting Notes April 19, 2010).
The Musconetcong Watershed Association, along with many downstream users, requests that the NJDEP withdraw the "Low Water" from the draft Plan until such time as a full Environmental Impact Analysis can be conducted on the effect of the reduced flow on:
MWA opposes a lowering of the outflow below the 12 cfs required by law because all existing information about stream ecology supports the understanding that low flow destroys habitat and harms aquatic life. This is not a new idea or a hypothesis; there is an abundance of studies that demonstrate the effects of low flows on stream health. Low flows exacerbate temperature impairments, affect habitat availability, food production and the dispersal of food insects in a stream. The fact that so many studies exist demonstrates that consistent and adequate flows are accepted as a major contributor to stream health.
What needs to be done in order to be sure that decisions regarding outflow reduction are being made based upon science and not in response to political or commercial pressure? In several instances in the LHWLMP DRAFT, including the added "Low Water" paragraph, the decision to reduce outflow is to be based upon "discussions" or consultations. We request the following steps be undertaken to collect and understand data before such decisions are made:
5. The relationship between outflow at the Lake Hopatcong Dam and the flow in the Musconetcong River at the point of discharge at the Musconetcong Sewerage Authority must be documented. The drainage area to the MSA discharge is 30.9 square miles of which 25.3 square miles is contributed by Lake Hopatcong. Consequently, the operation of the Lake Hopatcong Dam has a significant effect on the dilution available at the MSA's discharge point, particularly during extended dry periods or droughts.
6. The impact upon Lake Musconetcong of the reduced flow in the river, particularly as it relates to growth of aquatic plants in the lake and the rare and endangered plant species found in the lake must be studied.
7. All decisions must be based on published, specific pass/fail criteria.