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DateNameCompanyComment
 Lisa BrownWaterWatch of OregonAdditional Comment on extension for G-15000 Please consider this comment on the extension request for permit G-15000 in addition to the comments we filed yesterday. 1. We request that the PFO specifically address how the permit holder has complied with the following permit condition and how that compliance was demonstrated: “The use of water is for the non-consumptive use of groundwater in a closed loop system. Pumping and use of groundwater shall occur so as to prevent off-site groundwater and surface water effects.” (Permit at p. 2). For example, when was the “closed loop system” constructed? What is the design of the closed loop system? Also, how are “off-site groundwater and surface water effects” prevented in the pumping and use of the groundwater? (This condition appears to us to bar classifying the use as non-consumptive simply because the water flows to a stream.) We look forward to seeing this information in the PFO. Please let me know if you have any questions. Best, Lisa Brown
 Lisa BrownWaterWatch of OregonComments on the extension request for permit G-15000 1. This permit was issued for non-consumptive use only for use in a closed loop system. (Permit, p. 2). The (incomplete set) of water use reports show significant water use occurring in every month. In 2004, for example, reported water use was nearly 300 acre-feet in each month. It is unclear whether or how this use is non-consumptive. If it considered non-consumptive because the water is flowing directing to the Molalla River, for example, the permit holder should demonstrate the amount of water being returned to the system. If the permit has been used for consumptive water use, this would be a fundamental violation of the terms of permit issuance urging denial of the extension and cancellation of the permit. 2. The permit holder has failed to submit required water use reports after 2008. WRD’s on-line water use reporting page shows that only seven water use reports have been submitted since the permit was issued 15 years ago. The failure to submit the required reports is particularly concerning here where the permit was issued for non-consumptive uses only. WRD should deny the extension, or condition the permit to require WRD to cancel the permit if future reports are not timely received. 3. The permit holder did not commence construction under the permit within one year of permit issuance. Construction of a well that is not authorized under the permit cannot count as construction commenced under the permit. Such a standard would thoroughly undermine WRD’s permitting authority and evade the legislative intent in ORS 537.230. 4. We note that as we were preparing these public comments on 9/29/2015 (two days prior to the end of the public comment period), a signed PFO dated 10/6/2015 was available in WRIS. That PFO states that no public comments were received (p. 3, #3). If the public comment period is to be meaningful, WRD needs to at least read and consider any public comments received by the end of the comment period before writing the PFO. Thank you for considering these comments. Best, Lisa Brown