Oregon Water Resources Department
Electronic Public Comments
Application: R 88420
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Date
Name
Company
Comment
08/18/2017
Brian Posewitz
WaterWatch of Oregon
This application should be denied because the proposed use will have a significant detrimental impact on existing fishery resources. As noted in the comments by ODFW, the significant native fish populations in the Yamhill basin are being detrimentally impacted by reservoirs that deprive the basin of cool, clean water by: (1) storing water that would otherwise flow downstream; and (2) releasing water that has been significantly impaired in quality through warming and additions of nutrients and other pollutants. The Department's standard conditions for reservoir permits are not adequate to prevent this from happening because, among other things: (1) the department will not require measuring inflow and outflow to ensure live flow is passed outside the storage season; (2) the Department's standard "water quality condition" is triggered only be a decrease in water quality conditions due to reduced flow and, even then, only allows but does not require restriction of the use. If a permit is nevertheless granted, it should be conditioned to require the reservoir be located outside the stream channel so flows outside the storage season are not stored. The permit also should prohibit releases of stored water to prevent water quality impacts. These conditions are required to implement the ODFW advice that, outside the storage season, flows be passed in a manner that does not impact water quality.