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DateNameCompanyComment
02/06/2016Brian PosewitzWaterWatch of OregonThe application proposes an eight-acre-foot in-channel reservoir. ODFW has said the reservoir will have a significant detrimental impact on existing fishery resources and has appropriately flagged some of the concerns: important downstream fisheries and a potential for the reservoir to impact downstream water quality. Although ODFW said conditions can mitigate the impact, ODFW did not provide enough information for OWRD to say what those conditions should be. ODFW said the applicant should consult with ODEQ. However, without knowing what ODEQ recommends before issuing a permit, OWRD cannot reasonably condition the permit itself. OWRD cannot just condition the permit to say consult with ODEQ and do what it says. Without specific conditions in the permit itself, time will make it impossible to determine whether the use is consistent with the ODEQ advice (which will be lost to the sands of time). ODFW's recommendation about vegetation around the reservoir also is insufficiently precise. Moreover, ODFW does not appear to address impacts to downstream flows (water quantity). The application therefore should be denied at least until advice form ODEQ is in the record and ODFW makes its advice more specific. Then OWRD can appropriately condition the permit. In the alternative, the only condition that can be sure prevent the impacts flagged by ODFW would be a condition that the reservoir be located outside the stream channel and that it not release water into the watershed below. Thank you for considering these comments.