Oregon Water Resources Department
Electronic Public Comments
Application: R 88765
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Comment
Brian Posewitz
WaterWatch of Oregon
1. The application proposes an additional source of water for storage at the same location as storage authorized under existing certificates. The application and any permit should therefore be classified as supplemental, denied if supplemental water rights are not allowed for storage, or conditioned on cancellation of the existing water rights, which appear from the application to be subject to forfeiture in any event. 2. Any permit should be conditioned to protect peak and ecological flows in the Pudding River and downstream waters. 3. No permit should be granted because the Pudding River is used by threatened salmon and steelhead and further water withdraws will exacerbate the threats to these species. 4. The storage season suggested in the initial review appears to be inconsistent with OAR 690-502-0120(4). 5. The application if redundant of application R87871 in that they would serve the same alleged need.