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 Brian PosewitzWaterWatch of Oregon, et. al.WaterWatch, together with Center for Biological Diversity, Center for Food Safety, Food and Water Watch and Humane Voters Oregon, submitted comments on this application by email to Ann Reece. Those comments hereby are incorporated by reference. In short, the proposed temporary transfer should be denied. It would enlarge the use the because it is water that is surplus to the from lands and would not be used otherwise. It also would injure existing rights because it would facilitate significant exempt use of groundwater in a critical groundwater area in exchange for forbearance of use from what is assumed to be the same source but is in fact different. Finally, the application no longer accurately identifies the owner of the from lands. Thank you for considering these comments.