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DateNameCompanyComment
02/14/2019Brian PosewitzWaterWatch of OregonAmended comments (please delete prior comments, which misunderstood a portion of the ODFW comment form): The application should be denied because, based on ODFW's comments, storage of water between May 1 and November 30 would pose a significant detrimental impact to existing fishery resources. Conditioning the permit with a limited storage season cannot avoid the impact because the email exchange included with the application suggests OWRD is unlikely to enforce such a condition, thereby making it illusory. If a permit is nevertheless issued with a limited storage season (which we oppose for the reason just given), the season should be consistent with ODFW's recommendation and the permit should require (not just permit) measurement of inflow and outflow. Otherwise there would be no way to determine if the reservoir is in fact storing water outside the permitted storage season. Thank you for considering these comments.
02/14/2019Brian PosewitzWaterWatch of OregonqPlease consider the following comments: 1. The ODFW comment form has conflicting information in response to Question 4 about the season of use that should be permitted. Part of the response suggests no water should be stored May 1 through Nov. 30. The other part suggests no water should be stored April 15 to Sept. 30. The applicant should be required to submit a new application with non-conflicting recommendations from ODFW regarding the season of use that will not pose a significant detrimental impact to existing fishery resources. Any permit should then be consistent with that recommendation. 2. If a permit is issued with a limited season of use, the permit should require (not just permit) measurement of inflow and outflow. Otherwise there is no way to ensure water is not being stored outside the permitted storage season. The email correspondence submitted with the application shows the applicant quite logically asked how the permit holder could comply with the storage season requirement if water happened to enter the reservoir outside the storage season (a question we have been raising for years with respect to permits with limited storage seasons but without required measuring devices. The applicant appears to have received a response from OWRD that (a) the storage season would be different from either of the storage seasons ODFW could be interpreted to recommend; and (b) not to worry about it if water is stored outside of that season. With respect to (a), OWRD should not issue a permit inconsistent with ODFW's recommended storage season. With respect to (b), if that is in fact OWRD's approach to enforcement of a limited storage season, any condition limiting the storage season will be illusory and cannot be relied on to avoid posing a significant detrimental impact to existing fishery resources. The proposed permit therefore should be denied. Thank you for considering these comments.