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DateNameCompanyComment
 Lisa BrownWaterWatch of OregonComments of WaterWatch of Oregon RE: IR for G-17650 (Malheur Basin, Malheur County) September 19, 2013 Submitted via the WRIS WaterWatch is becoming increasingly concerned about the number and sizes of new groundwater permits that OWRD is issuing in Harney and Malheur Counties. For example, today is the deadline to comment on four IRs to issue that are all located in the Malheur Basin or Malheur Lakes Basin. Specific Comments: 1. The proposed condition specifying that “The water user shall discontinue use of, or reduce the rate or volume of withdrawal from, the well(s) if any of the following events occur:” does not seem to meet OWRD statutory and rule based requirements for protecting Oregon’s groundwater. First, it fails to specify to what extent a user would need to “reduce” the withdrawal if one of the triggers were met. Second, those triggers appear to be set at points where once met, the use is out of compliance with the statutory and rule requirements. In other words, they are not protective enough. This proposed condition does not adequately protect the resource particularly when OWRD is issuing new groundwater permits in areas of known declines and problems. 2. OWRD does not seem to be adequately considering the cumulative effects of new permit issuance. For example, applications G-17650 and G-17651 should have been considered together given their proximity. We are concerned that another Klamath or Umatilla groundwater situation is being created in this part of the state. 3. The proposed wells are within a mile of the Malheur River (2200 feet). (GW Report, Adobe p. 5). The GW Review states: Apparently based on this, the Review concludes there is not hydraulic connection and no PSI. However, we are not aware of any standard requiring “direct” or “efficient” hydraulic connection. It appears that PSI should have been found here. 4. WRD should consider the cumulative effects of this application with the pending application G-17651, which is for irrigation of adjacent acreage, (40.2 acres new primary irrigation and 199.3 new supplement irrigation) with two proposed well locations (and any others that may also be pending). 5. WRD’s Water Rights Mapper does not show any primary right that corresponds to the requested 140.4 acres of supplement irrigation. This may be because the Warm Spring Irrigation District rights are not mapped in that system. WaterWatch requests clarification regarding the applicable primary right. Thank you for considering these comments.
 Lisa BrownWaterWatch of OregonComments of WaterWatch of Oregon RE: IR for G-17650 (Malheur Basin, Malheur County) September 19, 2013 Submitted via the WRIS WaterWatch is becoming increasingly concerned about the number and sizes of new groundwater permits that OWRD is issuing in Harney and Malheur Counties. For example, today is the deadline to comment on four IRs to issue that are all located in the Malheur Basin or Malheur Lakes Basin. Specific Comments: 1. The proposed condition specifying that “The water user shall discontinue use of, or reduce the rate or volume of withdrawal from, the well(s) if any of the following events occur:” does not seem to meet OWRD statutory and rule based requirements for protecting Oregon’s groundwater. First, it fails to specify to what extent a user would need to “reduce” the withdrawal if one of the triggers were met. Second, those triggers appear to be set at points where once met, the use is out of compliance with the statutory and rule requirements. In other words, they are not protective enough. This proposed condition does not adequately protect the resource particularly when OWRD is issuing new groundwater permits in areas of known declines and problems. 2. OWRD does not seem to be adequately considering the cumulative effects of new permit issuance. For example, applications G-17650 and G-17651 should have been considered together given their proximity. We are concerned that another Klamath or Umatilla groundwater situation is being created in this part of the state. 3. The proposed wells are within a mile of the Malheur River (2200 feet). (GW Report, Adobe p. 5). The GW Review states: Apparently based on this, the Review concludes there is not hydraulic connection and no PSI. However, we are not aware of any standard requiring “direct” or “efficient” hydraulic connection. It appears that PSI should have been found here. 4. WRD should consider the cumulative effects of this application with the pending application G-17651, which is for irrigation of adjacent acreage, (40.2 acres new primary irrigation and 199.3 new supplement irrigation) with two proposed well locations (and any others that may also be pending). 5. WRD’s Water Rights Mapper does not show any primary right that corresponds to the requested 140.4 acres of supplement irrigation. This may be because the Warm Spring Irrigation District rights are not mapped in that system. WaterWatch requests clarification regarding the applicable primary right. Thank you for considering these comments.