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DateNameCompanyComment
 David HerbstUniversity of California Sierra Nevada Aquatic Research LaboratoryDavid B. Herbst, PhD Sierra Nevada Aquatic Research Laboratory, University of California 1016 Mt Morrison Road, Mammoth Lakes CA 93546 herbst@lifesci.ucsb.edu (760) 258-6066 August 9, 2016 To: Oregon Water Resources Department Re: Further diversions of the Chewaucan River to Lake Abert It has come to my attention, and to others concerned about diversions of inflows of the Chewaucan River from their destination to Lake Abert, that Application R 88250, continues neglect of the ecological values of this rare and threatened lake. The incremental strangling of flows has, over many years, resulted in chronic deficits of inflow to this saline lake, with the consequence that life in the lake has been decimated by low water levels and toxic high salinity. Abert has been shown to be critical migratory habitat for millions of shorebirds, waterfowl, and waterbirds, supplying them tremendous food resources from productive invertebrate populations (brine shrimp and flies). Without inflows sufficient to balance evaporation, the lake has been declining and seldom has sufficient water to support the kind of habitat it has been in the past. This is NOT a result of the recent drought. While the drought exacerbates the problem, it has been upstream agricultural diversions and impoundments that undermine the long-term stability of the lake. While this 100 AF proposed by this application is not much water in the big picture, granting another diversion amounts to continued neglect by water management authorities of the State of Oregon. I obtained my PhD at Oregon State University, and have done research at this lake for many years. My published research and Lake Abert technical papers for ODFW highlight the problems of higher salinities, which includes decreasing the productivity of the lake and eventually passing a threshold of ecosystem function. It is a wonder to see when this lake is thriving, and should be treated as a critical wildlife habitat unique in all of Oregon. At a technical review level, this is not an alternate reservoir, subject only to review of existing water rights. Since OWRD data shows the Chewaucan is over-allocated, cumulative impacts on the river and Lake Abert must be addressed. The standard review process should be followed here as that includes a public interest review. It is in the public interest to evaluate any and all diversion permits from the Chewaucan, to consider how Chewaucan diversions have already disrupted the Lake Abert ecosystem. It is time not to consider more diversion, but for the State to review existing management, and find solutions that balance the needs for water in this valuable ecosystem alongside other water uses in the larger Chewaucan basin. Sincerely David B. Herbst, PhD Research Scientist, University of California
 Ronald Larson The system Chewaucan River is already over appropriated and increases in water diversions are negatively affecting the Lake Abert ecosystem, according to recent peer-reviewed studies by Moore (2016) and Larson et al. (in press.). Therefore, I recommend that OWRD issue no further surface- or ground-water diversion permits for the Chewaucan Basin that would decrease inflows to Lake Abert. If a water use-permit is issued, I recommend that OWRD requires the applicant be buy water from an existing permit holder, so there is no net loss of water to the system. References: Larson, R., J. Eilers, K. Kreuz, W.T. Becher, S. DasSarma, and S. Dougill. In Press. Recent Desiccation-related Ecosystem Changes at Lake Abert, Oregon. Western North American Naturalist. Moore J. 2016. Recent desiccation of Western Great Basin Saline Lakes: Lessons from Lake Abert, Oregon. U.S.A. Science of the Total Environment 554-555:142-154.