RKLD Surreply - No DNR Analysis

It is disturbing that the agency concluded that it could establish orders for Indianford Dam gate operations without a quantitative analysis of the hydraulic consequences of the competing gate operation proposals, especially in view of the extent of staff resources it has devoted to this proceeding.

In effect, DNR has based its entire "public rights" case on presumed impacts of water levels by reducing a highly complex subject to mere sloganeering ("Any increase in water levels is bad, no matter when or how long it occurs or how it affects public safety, navigation or property.")