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DateNameCompanyComment
 Richard NawaKlamath Siskiyou Wildlands CenterThis application specific comment is intended to be reviewed in conjunction with KS Wild comment letter dated February 17, 2021 which emphasizes the public benefit of the application and recent research finding concerning “natural flows’. The initial review states: “A percentage of the water applied for has been determined to be allocable for the purpose(s) identified in the application. The rate allowed is shown in the table above titled “Allowable Instream Use” and, if less than the rate shown in “Amount of Water Requested for Instream Use” table, is limited to the rate shown in the “Estimated Average Natural Flow” table.” KS Wild recommends that ODFW and WRD discuss these discrepancies amicably and proceed to issue a proposed final order. It must be recognized that while the natural flows are determined based on averages over a one month period, the average daily and weekly flows are highly variable within the month. For example, the natural flows in the last week of November is likely to be much greater than the listed 13.2 cfs average flow for November. Migrating chinook and coho rely on pulsed flows to provide for migration, not average flows which is more conducive to allocating out of stream industrial needs. Migration timing is highly heritable trait, so we know few coho will be around to migrate the first week of November but many coho will be needing requested flows during the later half of November. We urge that the biological needs of fishes be taken into consideration when assessing instream allocations and “natural flows”. Average summer rearing flows may also create challenges for juvenile fish that need the required allocation 24/7 each day. If the average flow includes substantial drops in flow during any 24 hr period substantial reductions in juvenile abundance are likely to occur that cannot be recovered with subsequent increased flows. Thus there must be some regulatory mechanism that assures a constant minimum flow during the critical summer rearing months. One time water withdrawals that reduce a stream segment to a series of isolated pools can be deadly for juvenile salmonids.