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 Chelsea StoneWaterWatch of OregonRe: Comments of WaterWatch of Oregon IR for G-17651 (1.8271 cfs, Malheur Basin, Malheur County) To Whom It May Concern: 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, in the past month of public notices, ten applications have been published with tentatively favorable results in these counties alone. Specific Comments (1) The proposed condition specifying, “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. Kerry Kavanagh to Applicant, September 13, 2013, “File G-17651,” page 4. 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) Although WaterWatch appreciates the existence of the aforementioned condition in Comment 1, we would like to suggest that the Department also begin including a clear reopener clause on groundwater applications in Malheur Basin and Malheur Lake Basin. These are sensitive areas for groundwater, and there have been a large number of permit applications within them. In the event the Department discovers that the over-issuance of groundwater permits is drying up surface water, a clear reopener clause would allow the Department to come back and condition rights at a more stringent level. (3) OWRD is not adequately considering the cumulative effects of new permit issuance. We are concerned that the Department is creating an untenable groundwater situation in this part of the state. Consider, as of September 18, thirty-three of the seventy-four groundwater applications through the initial review stage were in this part of the state, specifically Malheur and Harney counties. There are five permits in these counties in initial review, including this one, with comment deadlines today. We suggest that the Department should be considering all of these applications together, given their close physical proximity and the sensitive nature of the basins in Malheur and Harney County (specifically the Malheur Basin and the Malheur Lake Basin). Together, these five applications ask for a total of 7.1117 cfs from six wells. Thank you for your time. Sincerely, Chelsea Stone Legal Intern