|
April 13, 2008
Governor Dave Heineman
Office of the Governor
P.O. Box 94848
Lincoln, NE 68509-4848
Dear Governor,
Last year, WaterClaim sent you a letter identifying some of the
problems we see with the computer simulation that is used to measure
compliance with the Republican River Basin Compact with Kansas.
You promptly replied that you had forwarded our concerns to the
DNR for Director Bleed’s consideration.
As there has been a change in personnel at the DNR, we felt that
there might be a new willingness to consider some of the issues that
we feel make it difficult for Nebraska to comply.
Enclosed is a copy of the letter we sent in August of 2007.
Steve Smith, director
WaterClaim
August 8, 2007
Governor Dave Heineman
Office of the Governor
P.O. Box 94848
Lincoln, NE 68509-4848
Dear Governor,
The following is a summary of the concerns that WaterClaim has
with the computer simulation used to measure compliance with the
Republican River Basin Compact with Kansas. Detailed explanations
of each point can be found online at
www.waterclaim.org and at
http://tinyurl.com/2x9hbv After the summary, I have included
more information about each problem identified.
In my opinion, if we want our money and our actions to put more
water in the stream, then the Model needs to, as accurately as
possible, simulate reality. If we feed the Model bad data or
knowingly force the formulas to produce desired results, then the
system has failed and we have wasted a lot of money as well as hurt
a lot of people. You are in the unique position to influence the
DNR and cause it to do its job accurately and with due process.
Modeling the interaction of ground and surface water requires the
estimate of many variables. The more people who look at those
inputs and processes, the more likely the simulation is to give us
accurate information and predictions.
|
Problem |
Brief Description |
|
Missing Water |
The Model
artificially caps the benefit of shutting off irrigation
wells. Approximately 250,000 acre feet are missing from
the Model. The DNR says this water is used by farmers
and that, if it isn’t used by farmers, then it is used
by trees and grass. So, even if the farmer doesn’t use
the water, it will not be in the stream. If this were
true, then most of the reductions we make in pumping
will be of no benefit to the compliance effort.
|
|
Input Data
(Pumping) |
Is accurate data
going into the Model? The data released on the RRCA
(Republican River Compact Administration) web site in
2005 showed pumping in the Basin at a rate three times
greater than what was actual.
|
|
Input Data
(Base Flows) |
Is accurate data
going into the Model? The data released on the RRCA web
site in 2005 showed base flows at several gages to be
greater than stream flows. That is not possible.
|
|
Inaccurate Aquifer Level Predictions |
When the Model
aquifer level predictions are compared to actual levels,
the Model is wrong on about 56% of locations measured.
It is in error mostly in the eastern end of the Basin.
The Model says the aquifer went down much more than it
actually did. This causes the Model to overestimate
base flow depletions caused by groundwater pumping.
|
|
Conservation |
The effects of
conservation are not separated in the system. This
exclusion is intentional. The effects of conservation
are assigned to groundwater pumping. The DNR agrees
that conservation is not labeled as such in the Model
but denies that groundwater pumping has been assigned
the effects from conservation instead. However, a
review of the numbers shows that conservation effects
really are assigned to groundwater irrigation.
Conservation was intentionally omitted from the formulas
because the States did not want any reduction in
conservation, even though it is the primary cause of the
problem. To make the formulas balance, something else
had to take the blame. Groundwater irrigation took most
of it. As a result, though, when irrigation wells are
turned off, the stream will not increase as the Model
predicts.
|
|
Base Flow Calculation Methodology |
According to the
Model, over 50% of the base flows are caused by
precipitation events in the alluvium within a few days
of the precipitation event. This means about half of
the base flow values used by the Model are not
aquifer-related. As a result of the way base flows are
calculated, groundwater pumping is assigned a much
greater responsibility than it causes.
|
|
Base Flows and Dams |
The Model says that
the dams caused a permanent 50% reduction in the amount
of water oozing from the aquifer when they were
constructed. The dams were put in place before
groundwater irrigation became common. Is this drop in
base flows attributed to groundwater irrigation? Is it
accurate? It does not appear to be correct.
|
|
One Layer |
The Model works with only one layer.
This prohibits the software from differentiating between
the alluvial and deep aquifer. It also means the Model
does not recognize the fact that much of the Ogallala
formation is disconnected from the Republican River.
|
|
Allocations, No Rebound |
Even though
precipitation has been nearly normal for several years,
the allocation has not rebounded. We have seen a return
to normal precipitation in 2004, 2005, and 2006; yet,
the Model shows the allocations going down. The DNR
says this is because we have a hydrological drought, not
a precipitation drought. This means the Model bases
allocations on how much water is in the stream, not on
how much precipitation falls in the Basin. |
Thank you for reviewing this information and the other pages of data
I have included. If you have questions or comments, please feel
free to contact me.
Regards,
Steve Smith, director
WaterClaim
|