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 Brian PosewitzWaterWatch of OregonThe above proposed temporary transfer should be denied because it would injure existing water rights and result in an enlargement of the use. The proposed transfer would allow surface water irrigation rights held by Gregory te Velde, the owner of the Lost Valley Farm dairy, to be used for irrigation on the property of a nearby dairy, Sage Hollow Ranch. The application says Sage Hollow will use the surface water rights instead of using groundwater rights it holds to irrigate the same property. The apparent reason for the temporary transfer, and for Sage Hollow’s expected forbearance from using its groundwater rights, is to allow te Velde to claim “mitigation” for his use of groundwater from the same general aquifer, but without a permit, under a claim that his use is “stockwatering” that is exempt from permit requirements. Thus, the proposed temporary transfer seeks to accomplish on a short-term basis what te Velde and Sage Hollow seek to accomplish on a long-term basis with proposed transfers T-12247 and T-12248. The proposed temporary transfer would cause injury and enlargement for the reasons stated in the protests filed against T-12248, which hereby are incorporated by reference. The proposed transfer also would cause injury for the additional reason that Sage Hollow will have no legal obligation to refrain from using its groundwater rights, even if te Velde is pumping from the same aquifer under a claim of exemption, thereby further exacerbating groundwater declines in the Ordnance Basalt Critical Groundwater Area. The proposed temporary transfer also would cause an enlargement for the additional reason that the surface water rights to be used by Sage Hollow are surplus water rights to Lost Valley that would not be used if not transferred temporarily to Sage Hollow. For the foregoing reasons, the proposed transfer should be denied.