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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 allocable for the purpose(s) identified in the application. That rate allowed is shown in the table above titled “Allowable Instream Use” and, if less than the rate shown in “Requested for Fish Life and Fish Habitat” 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 3.65 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 may be needing ODFW 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”. By the middle of summer Powell Creek flow near it’s mouth is subsurface, however, I speculate that flows capable of supporting juvenile fish occur at the upper end of the stream reach identified. It is important that these flows no matter how small be protected from further out of stream uses. A particular issue is one time withdrawals that reduce a portion of the stream to isolated pools which would likely cause any listed coho salmon to perish (i.e. direct take). The regulatory process needs to be flexible to accommodate the perennial flow requirement for fish, even at very low flows for sub-reaches of the stream segment identified.