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 Lisa BrownWaterWatch of OregonComments of WaterWatch of Oregon RE: IR for G-17663 (2.495 cfs) (Malheur Lake Basin, Harney 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 WRD may be creating an untenable groundwater situation in this part of the state. (3) The Ground Water Availability evaluation in the GW Review reports on declining groundwater levels in areas that are likely down gradient of the proposed wells. It also reports that there are a number of undeveloped wells in the area and that groundwater level declines are likely to increase in the future. The GW Reviewer states he is not prepared to find that the groundwater is over-appropriated but that does not seem to be the applicable standard. WaterWatch requests an explanation as to why WRD believes that issuing additional groundwater permit in this circumstance meets its statutory (ORS 537.621 and ORS 537.525) and rule (OAR Division 9) standards.