Oregon Water Resources Department
Electronic Public Comments
Permit: R 12928
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Name
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Comment
kimberley Priestley
WaterWatch of Oregon
WaterWatch opposes the requested extension of time to develop R-12928 for a number of reasons including but not limited to the following: (1) The denial of a previous extension without challenge precludes a new application for an extension. The OWRD has already issued a Final Order (FO) denying an extension of time request for this permit. The applicant did not file a timely petition for judicial review of that decision under ORS 183.482 or file a timely petition for reconsideration with the OWRD. (2) Any decision on this extension application should deny the application on the grounds outlined in #1 and cancel the permit. (3) The applicant did not develop the permit within the time allowed and did not apply for an extension before the time period for development had elapsed. Permit holders should not be able to apply for an extension of time after the time to develop has elapsed. (4) The market and present demand of water in the Coquille system requires denial of this extension request. The Coquille system is home to ESA listed Coho, as well as Chinook and lamprey. The Coquille system, including Bear Creek and Bill Creek, are not meeting water quality parameters, including temperature, dissolved oxygen and flow modification. Cranberry bogs will only add to the water quality problems in this system and further imperil already stressed fish populations. Given these issues, there is not good cause to allow the extension request.