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 Jim Backstrand Re: G-18843 WAG Holdings , llc. Request for an irrigation well For 22.7 acres marijuana/hemp chemical refinery and grow site at 18505 NE Jaquith Road. Please Deny This Application and add my letter to the record for OWRD G-18843. This applicant chose to purchase an illegally built/Illegally remodeled turn-key marijuana & hemp chemical processing and grow site. There wasn’t any water available at the time of purchase and they knew that, but chose to spend almost $2,000,000 on it anyway, gambling that they would be able to persuade OWRD and Yamhill County with their deep pockets. This has been a gamble for WAG Holdings, llc from the start but we believe that they thought with enough money, they felt that they would get their way and persuade OWRD to grant them the water by pressuring them with all the money they spent on this property at the top of Chehalem Mountain, at 1400 feet, hidden in the forest, up where no one can see what they are doing. Before we could build our house, we had to show the bank that we had available water, we had to drill a well and prove we had adequate water to run a household BEFORE we were able to get a home loan to build. WAG Holdings, llc has done just the opposite. They purchased this illegally built turn-key marijuana chemical refinery ASSUMING they’d be able to buy their way into robbing the water from the other 2200+ residents living on Chehalem Mountain, who were here first. Don’t reward them for their poor business practices. They gambled that OWRD would feel pressured to approve their request for irrigating a water thirsty crop, on top of a windy mountain, at 1,400 feet, with extremely limited water resources. Just because Yamhill County government doesn’t care about the other 2200+ residents on Chehalem Mountain, please DO NOT make the same mistake they did for this ONE entity. Do not reward them for their poor business practices and them gambling that OWRD will cave to the pressure. They paid cash for this property, money doesn’t seem to be an issue for this group of 9 LLC’s associated with this one address. Thank you and please DO THE RIGHT THING for the other 2200+ residents who were here first and depend on our clean, fresh water for daily living. Jim Backstrand Chehalem Mountain Resident of 31 years.
 Michael Frank To whom it may concern, We appeal to the Water Resources Department to deny this permit request. Based on the data provided and the potential loss of water to the neighbors on chehalem mountain. The applicants proposed well will jeopardize the water supply to the entire surrounding area. PLEASE DO NOT APPROVE THIS REQUEST. The reports clearly show this well will deplete our water. Once this resource is gone, we will have no option for water to our home. Our water rights must be protected. It is the responsibility of the OWRD to protect and serve all water rights. This permit request is an extreme overuse of a natural resource that OWRD has the responsibility to protect (for all ) and not be persuaded by the previous and current poor judgement of other departments or agencies. Our homes, which we built in good faith of our water source, will be jeopardized. Regards, Mike and Susan Frank
 Sheila Pruitt1956This is is reference to Application G-18843. We are residents of The Chehalem Mountains, which is known as Chehalem Mountain Ground Water Limited Area. The applicant's proposed well at 18505 NE Jaquith Road will potentially draw around 7 million gallons of water per year. This is a geologically sensitive area based upon surrounding well-log reports. These reports show fractured characteristics on surrounding wells making drilling and containing water from one aquifer to another difficult. We have read forecasts that indicate we are experiencing drought. Neighbors of Jaquith and Chehalem Mountains are all on wells and this amount of water to be drawn is way beyond what a family of four consume approximately in one year (146,000 gallons). Please help us protect our pristine Chehalem Mountains residences. Sheila and Steve Pruitt 22135 SW Jaquith Rd Newberg, Or 97132
 Ed Christie Comments from Ed Christie concerning application G-18843: Since my family has lived on Chehalem Mountain since the early 1900's, we have witnessed the steady decline in the available well water. I am strongly opposed to the proposal to drill a well on Jaquith Road for use in irrigating hemp or any other commercial crop. Please limit drilling wells on Chehalem Mountain for domestic use only. Thank You Ed Christie, 17900 NE Hillsboro Hwy (503-887-3714)
 Debbie Ward Concerning application G-18843. I am writing in opposition to this application. Washington and Yamhill counties have approved hundreds of homesites on small acreages on Chehalem Mt over many years. Hundreds of wells, primarily for residential use, have subsequently been approved. To now approve a SECOND well on the subject property, especially in an area of limited water resources, for commercial irrigation and/or industrial purposes at this stage of development of the area would appear to be irresponsible and does not seem consistent with the stated charge of the OWRD. If the application is approved we fear that our available water for residential use, allowable livestock use and fire suppression will be put in jeopardy. We respectfully request that you deny approval of application G-18843.
 Ed Christie  
 DALENE BARTLOW LETTER OF OPPOSITION to drilling a new well. Regarding Application G-18843 We live at 1,000 feet elevation on Chehalem Mountain. The Applicant’s proposed well at 18505 NE Jaquith Rd will possibly draw somewhere around 7,000,000 gallons (7 MILLION) of water per year. As a comparison, an average family of four people will draw approximately 146,000 gallons of water per year. It would take an average family of four 47.95 YEARS to draw the same amount of water the Applicant will draw in 1 year. They propose to drill in the Chehalem Mountain Ground Water LIMITED area, among and very close to, in several cases, neighboring wells, in a geologically sensitive area based upon surrounding well log reports. These well reports typically show broken, fractured, visic characteristics on surrounding wells making drilling and containing water from one aquifer to another difficult. Forecasts for water availability into the future indicate we are experiencing drought and do not include little or no detailed information on agricultural activity with regard to wine grapes and cannabis as noted in OREGON’S 2017 INTEGRATED WATER RESOURCES STRATEGY (I.W.R.S.). The APPROVAL conditions set forth in the INITIAL REVIEW are weak with regards to well interference and well monitoring requirements as have been outlined in OWRD Publication, Groundwater Report No. 27, N. Willamette Basin, Newberg Area, dated 1978 and Oregon’s 2017 I.W.R.S. Oversight to ensure WAG HOLDINGS will comply with any rules/regulations set forth by OWRD will be difficult to non-existent until wells start to go dry. Asking homeowners to “re-drill another well” if your well goes dry is unacceptable as per the hydrology/geology reports show that once the aquifer is dry, there is no more water for any of us. There is obvious disregard by the applicant’s agent, Pacific Hydro-Geological for concerns of water availability predictions as cited in both hydrology reports companies: Rehm Geological and CwM-H2O Water Management (the 2 Geologic/Hydrologic companies were hired as a group).Since our well on 23235 SW Mountain Home Rd. is at 365 feet we oppose the drilling of a new well that will affect our Aquifer level. Sincerely, Murray and Dalene Bartlow 23235 SW Mountain Home Rd. Sherwood, Oregon 97140
 Luisa PonziChehalem Mountain Winegrowers AssociationAugust 27, 2020 Concerning Application G-18843. We are writing in opposition to this application. There appears to be evidence that the approval of this irrigation allowance could be detrimental to many homes and other, less demanding, agricultural products in the surrounding area. As an organization that represents hundreds of wineries and vineyards in the Chehalem Mountains, an industry that brings millions of tourism dollars and employees thousands of people. Additionally, it is a product that is sustainable and requires very little water use. By acquiescing to an organization that did not plan or implement well and putting other’s businesses at risk would be truly neglectful of the stated charge of the Oregon Water Resources Department: “To encourage, promote and secure maximum beneficial use of such water resources.”. We urge you to deny this application. With respect, The Board of The Chehalem Mountain Winegrowers Association
 Yvonne Len August 27,2020 Oregon Water Resources Department Re: G-18843 I oppose and support the Chehalem Mountain residents regarding any drilling of a new well on Chehalem Mountain for any purpose other than residential use. With the possibility of withdrawing approximately 7 Million Gallons of water per year, and no forethought as to the impact on human lives and wildlife, THIS IS UNACCEPTABLE! The possible compromise of existing wells, loss of water to residents within one year, and telling homeowners to drill new wells, at a cost of $15-$20,000 per well, THIS IS OUT OF THE QUESTION! WHY SHOULD THE HOMEOWNER HAVE TO PAY FOR A NEW WELL, WHEN THE CAUSE IS CREATED BY ONE ENTITY DRAWING OFF TOO MUCH WATER? I live on Highway 240 at Red Hills Road. This will effect all of us downhill from the Chehalem Mountain. Bryan Creek from Walker Reservoir and Harvey Creek are tributaries to the Chehalem Creek. Right now, the Chehalem Creek, at the back of my property, is “DRY”. You can walk the whole creek bed, approximately 2-3,000 ft. plus. I have lived here for seventeen years and it has never be this dry, to be able to walk in the creek bed. Also, there are a couple of small ponds, holding hundreds, if not thousands of baby trout. Per Oregon Wildlife, there is nothing to be done to save them. “It will be the strongest of the trout to survive”. Yes, I have contacted OWRD with “no call back” and Oregon Wildlife, who did call me back. Oregon Wildlife and OWRD are aware of this situation. Either some entity has pumped all of the water out or it has been dammed to the west of my property. As for this, BUTANE HASH OIL REFINERY? OUT OF THE QUESTION to be near any residential area or on top of a mountain. If it explodes, it will injure and kill people, demolish homes by fire, the fire will have fuel to burn the whole mountain and wildlife. Is it really necessary or important to have a BUTANE HASH OIL REFINERY in a residential community and so close to the city of Newberg, Oregon? Please see the following videos: 1. ATF demonstration of blast and 3600 degree F. 2. 5/17/20 LA Times, Los Angeles, 12 firefighters injured. 3. 6/27/17 Channel 6 News KOIN, explosion, homeowner killed. 4. 3/4/2020 KEZI 9 News Eugene, Oregon. Man burned, sent to Portland. YOU HAVE TO BE LICENSED IN STATE OF OREGON TO PRODUCE HASH OIL. Sincerely, Yvonne Len (503) 828-8849
 Hamacher Eric We are writing in OPPOSITION to application G-18843 for 18505 NE Jaquith Rd, Newberg, OR 97132. This application is for a property located within the Chehalem Mountain Groundwater Limited Area (CMGLA). There has been substantial and consistent opposition to this project since the first hearings were held by the Yamhill County Board of Commissioners (YCBC) considering the project last fall. Over 200 letters of opposition were submitted to the Board. Most of those letters came from neighbors, who are senior water right holders and are concerned about the injury that such a huge groundwater draw would have upon the already declining aquifer and thus existing wells and springs further downhill. Our family lives and we make our living in agriculture in the CMGLA and would be affected by granting this proposed irrigation right. Our opposition is two fold: • The allocation of this water is detrimental to the public interest • This application relies on undue pressure being placed on the Water Bureau due to irresponsible planning Public Interest: The purpose of review of new water right applications is to ensure that the public interest is served in allocating the use of this public resource. State statutes charge the Oregon Water Resources Department with taking actions that “encourage, promote and secure the maximum beneficial use and control of such water resources.” The application being considered overwhelmingly goes against the maximum beneficial use and endangers this precious resource for both existing and future generations in the area. The amount of water required for the project and where it would come from have been vague from the beginning. An estimate of 7,000,000 gallons of water was calculated to be needed over the growing season from May-October. Early on the applicant proposed trucking water from McMinnville (9-12 trucks per day) to meet water needs of the operation. Trucking that much water would take over three thousand trucks. Obviously, trucking water was never a real consideration. A well supplying 7 million gallons a year within the CMGLA certainly goes against the public interest by posing a clear threat to the integrity of wells serving over 2200 people farther down the mountain in both Yamhill and Washington Counties. The groundwater supplies in this area are declining. The submitted hydrology reports from both Rehm and CwM-H20 state that there would be serious interference with neighboring wells. The report from CwM-H20 states: “The proposed rate of 0.019 CFS (8.5 gpm) is within the range of yields observed in this WBZ. However, CwM believes that pumping at the proposed location, depth, and rate could have significant impacts on neighboring wells. show that serious interference with other wells is highly likely.” According to the 2019 Oregon Budget, Note on Contested Wells in Oregon ( ): “Unsustainable groundwater appropriation depletes the long-term water supply for all users” “...junior groundwater pumping that reduces surface water flows does so to the detriment of senior surface water rights. For example, in some areas of the state, pumping of groundwater has reduced discharges from springs, impacting those that rely on those springs. While there is continued demand to allow for new water uses; it is better for existing water users if the Department does not over-appropriate the resource in a manner that then requires curtailment or threatens that existing uses will not be able to be sustained into the future.” Undue Pressure on the OWRD: The application of this water right is part of a calculated risk made by the applicant that there would be sufficient undue pressure put upon the OWRD to grant a water right due to the amount of money spent on the project by the time the permit came up for consideration. It is a reckless attempt to take and privatize a huge amount of water, every year, now and into the future from people living and doing business in the area. Planning a grow operation for high water use crops such as hemp and marijuana on top of a windy mountain, at 1400’ elevation in shallow clay soils, in a restricted water use area, at best shows extremely poor planning and judgement. This calculation was made regardless of the impacts upon other stakeholders or how seriously short the application fell of meeting the required criteria for approval. Granting such an application will only encourage other deep pocketed applicants to force their will upon the OWRD and the people of Oregon. According to the 2019 Oregon Budget, Note on Contested Wells in Oregon ( ): “Establishing infrastructure before a water right is approved puts undue pressure on approval and may result in the applicant and Department incurring additional unneeded expenses.” “The Department always recommends that individuals interested in developing a project that requires the use of water check with the Department early – even before purchasing the property.” “If permanent curtailment of junior users is required in aquifers to protect the remaining supply for senior users, the junior users lose their investment.” Choosing and buying a poor site, with very limited water resources, spending a lot of money on improving the site, on consultants and on attorney’s fees was a choice. It was a choice the applicant made, gambling on getting a water right that offered a high financial reward even though it would appear such an application did not meet the criteria required for getting approval of such a right. It was a calculated manipulation of the process for achieving a water right. It was a choice that unfairly pressures an approval of a groundwater right by OWRD and will likely injure neighboring property owners. The proposed use for this application: •Does not support the maximum benefit of the resource. •Is not sustainable. •Is not in the public interest. •Is likely to harm senior water right holders (and ultimately the applicant) The preponderance of evidence supplied shows that not one but multiple criteria for the granting of a water right have not been met. The legal backing for denial is clear. The legal obligation for the denial is clear. I urge that this application, G-18843 be denied. Thank you for your consideration of our concerns. Sincerely, Eric Hamacher and Luisa Ponzi For more information on the farming of these crops and their water needs: Purdue University ( the major University studying the growing and processing of hemp and marijuana in the US says “(It’s a) myth that hemp can be grown anywhere. Hemp grows best on a loose, well-aerated loam soil with high fertility...poorly-drained clay or poorly structured soils often results in establishment failures.” The Purdue Hemp Project is a wealth of information about siting and growing operations such as the one being considered. It shows how much water is required for such operations and the many variables needed for their success. I submit it as a resource to explore in order to more clearly understand the immense water needs, now and into the future, every year that this application proposes.