Oregon Water Resources Department
Electronic Public Comments
Transfer: T 13572
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Date
Name
Company
Comment
Steven Patten
City of Milton-Freewater
The proposed transfer is for UMAT 50516 which has additional water rights attached to it (Cert 89449, Cert 94671, Cert 95156 and Cert 95157). Certificate 89449 does not have water level decline conditions. The other three water rights have water level decline restrictions built into the permits/certificates. These requirements state that if water level declines meet the conditions laid out in the permit/certificate, then the water user shall discontinue use of, or reduce the rate or volume from the well(s). The proposed transfer of additional points of appropriation (APOA) is noted in the application as a way to improve groundwater management. However, the APOA’s seem more likely to allow continued pumping from wells/water rights that may have triggered the water level decline conditions. The groundwater declines in the Walla Walla subbasin’s basalt aquifers are of grave concern and groundwater management changes are critical to protect the resource for the future of all users. Permitted changes should benefit the entire system and if possible also provide benefits for the users and safeguard the resource for the future. The City of Milton-Freewater has a concern that it appears this change will allow the transfer of water rights from old wells to new wells thereby by-passing permit/certificate conditions on water level declines. Due to the critical nature of the status of this aquifer, permitted changes and transfers must not be approved if they would result in a negative impact on the basalt aquifer system.