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DateNameCompanyComment
 Ivan MaluskiFriends of Family FarmersFriends of Family Farmers represents small and mid-sized family farms across Oregon. We are concerned about the steady loss of smaller dairy farms in Oregon in recent decades and the harmful impact this has had across rural parts of the state. We believe this to be connected to a growing number of exceedingly large dairy operations in Oregon and the US, which have contributed to an oversupply of milk products and exceedingly low prices - economic conditions that have helped push smaller dairy farms out of business. It is our view that the loss of small and mid-sized farms in Oregon is not in the public interest. If this new use of water is approved, it could further accelerate the loss of smaller and mid-sized dairy farms in Oregon, which numbered 1133 in 2002 and a little over 200 today. To our knowledge, there has been no economic impact study conducted on the proposed Lost Valley/Willow Creek dairy to determine the potential impact on smaller and mid-sized dairy farms in Oregon. However, shortly after a similar sized dairy located in Oregon in the early 2000s, according the Oregon Employment Department, Oregon lost nearly half of its dairy farms (mostly small and mid sized) in just five years, as an average of nine dairy farms closed each month between 2002 and 2007. Because of this history, we urge you to deny this proposed use of water (Application LL 1692) because it is not in the public interest. Additionally, this proposed use of water could contribute to further degradation of groundwater in the Lower Umatilla Basin Groundwater Management Area, impacting neighboring farms and rural communities. At this time, the operation that would use this water has not yet had its animal waste management plan or National Pollutant Discharge Elimination System (NPDES) permit approved by the Oregon Department of Environmental Quality or the Oregon Department of Agriculture. Granting a new water right before the NPDES permit and animal waste management plan have been approved would be contrary to the public interest. Even if these permits are ultimately granted, we are concerned that further groundwater degradation will likely result if this water right is granted. This would not be in the public interest. Thank you for your consideration of these comments.
 Hannah ConnorCenter for Biological DiversityWillow Creek Dairy, an assumed business name of California dairy magnate Greg te Velde, seeks a “limited license” to pump up to 664 gallons of water per minute (almost a million gallons per day) from the Ordnance Basalt Critical Groundwater Area near the Columbia River for his new mega-dairy near Boardman. The application should be denied because the proposed use is not “short-term or fixed” in duration and because it would result in limited licenses of more than five consecutive years for the same use. The application also should be denied because, under Oregon Administrative Rules, a limited license can be granted only if “the proposed water use will not impair or be detrimental to the public interest.” That finding cannot be made here because water is not available, because the proposed use would injure other water rights, and because the limited license would facilitate construction of large, industrial dairy that would pollute the air and water, hurt fish and wildlife, displace family farms, and subject nearly 10,000 cows (30,000 in the long-run) to extreme confinement and other inhumane treatment. Thank you for consideration of this comment. Sincerely, Hannah Connor Staff Attorney Center for Biological Diversity
 Tarah HeinzenFood & Water WatchThis application should be denied for the reasons stated in the comments submitted separately by email from eight groups including Food & Water Watch, which hereby are incorporated by reference. The proposed use does not qualify as short term or fixed in duration, would result in limited licenses of more than five years for the same use and would injure existing water rights. Moreover, the Department does not have substantial evidence to say water is available. In addition, the application will result in water pollution, for all of the reasons explained in those comments and because CAFO animal waste management plans are not designed to be 'zero discharge' plans, either with regard to surface waters or to groundwater. Thank you for considering these comments.
 Brian PosewitzHumane OregonThis application should be denied for the reasons stated in the comments submitted separately by email from nine groups including Humane Oregon, which hereby are incorporated by reference. In particular, the proposed use would impair or be detrimental to the public interest because it would facilitate construction of an inhumane factory farm. Thank you for considering these comments.
 Brian PosewitzWaterWatch of OregonThis application should be denied for the reasons stated in the comments submitted separately by email from nine groups including WaterWatch of Oregon, which hereby are incorporated by reference. In particular, the proposed use does not qualify as short term or fixed in duration, would result in limited licenses of more than five years for the same use and would violate the prohibition on new appropriations from the Ordnance Basalt Critical Groundwater Area. Thank you for considering these comments.
 Lisa Brisley To Whom It May Concern, Please deny any permits or requests from the new mega-dairy farm near Boardman, Oregon. Mega-dairy farms pose unacceptable pollution risks to the air, water, and soil. "They produce high amounts of methane and nitrates from cow slurry, nitrogen pollution from fertilizer used for animal feed and carbon emissions from land use and production." Mega-dairy farms rely on inhumane treatment of dairy cows and their offspring and are used as milking machines by standing for long hours on concrete slabs, inhumanely confined to the indoors with no access to outdoor fields or pastures, and succumb to many illnesses and diseases due to deplorable conditions in which they are forced to endure. Once the cows are of no use for their dairy production, they are slaughtered for their meat and by-products. Mega-dairy farms are inhumane and are economically and environmentally destructive and unsustainable. Please say "no" to any permits or requests from this or any mega-dairy farms. Thank you, Lisa Brisley
 Maggie Salter This proposed use of water is not in the public interest because it would allow large amounts of water to be taken from a limited groundwater resource. It also would enable construction of an industrial scale dairy that would pollute the surrounding air and water with gas and waste from the animals. These operations have a huge effect on the environment due to emissions of greenhouse gases like methane, nitrous oxide, and carbon dioxide. If the effect on climate change isn't enough to show that we don't need other one of these awful industries then consider what the animals who are exploited for this industry go through. The dairy cows are artificially impregnated and have been manipulated so that they lactate 12x more than they normally should which is completely unnatural and unhealthy for the cow. Plus they have their babies ripped away from them hours after they give birth and just like humans they form bonds and connections with their children. The baby cows if female will have to endure the same life long process their mothers did and if they are male they are sent to veal farms where they are slaughtered a few months later. Thank you for considering our comments!
 nora weisbord This proposed use of water is not in the public interest because it would allow large amounts of water to be taken from a limited groundwater resource. It also would enable construction of an industrial scale dairy that would pollute the surrounding air and water with gas and waste from the animals. Finally, dairies of this scale are inhumane because they keep the cows in highly confined conditions, rarely if ever let them outside to graze, deny them contact with their offspring, and give them only very short lives. Thank you for considering these comments.
 Lori Smith This proposed use of water is not in the public interest because it would allow large amounts of water to be taken from a limited groundwater resource. It also would enable construction of an industrial scale dairy that would pollute the surrounding air and water with gas and waste from the animals. Finally, dairies of this scale are inhumane because they keep the cows in highly confined conditions, rarely if ever let them outside to graze, deny them contact with their offspring, and give them only very short lives. This proposed industrial scale dairy is bad for people, animals, and the planet. Thank you for considering these comments.
 Martha Howe I'm asking that you deny these applications for groundwater permits for several reasons. One, these types of farming operations are inherently cruel. The animals are intensively confined, forcibly impregnated, have their babies taken away shortly after birth, and are generally disallowed from engaging in their natural, normal behaviors. Secondly, factory farms have a devastating impact on local wildlife and our natural environment due to farmed animal waste and excessive use of resources. Lastly, these operations require an enormous amount of water on a daily basis. By using public resources, they stand to significantly deplete a prized and crucial natural resource: water. Thank you for you time.
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