Oregon Water Resources Department
Electronic Public Comments
Application: R 88417
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Comment
Brian Posewitz
WaterWatch of Oregon
The application proposes to store a significant amount of water in a reservoir in the stream channel. Although ODFW has said the stream does not, and did not historically, have native migratory fish, water released from the reservoir could affect water quality in downstream waters that do have fish. The ODFW review form does not indicate if ODFW considered that. In any event, any permit should be conditioned to ensure that releases from the reservoir do not detrimentally impact downstream water quality. (OWRD's standard water quality condition is inadequate because it is triggered only by violations of water quality standards due to reduced flow.) In particular, the permit should prohibit release of water during summer and early fall because such water is likely to be water quality impaired for temperature (at least). If that condition would impair downstream flows (i.e., if the stream has flow that time of year), the permit should be denied or require that the reservoir be moved off of the stream channel.