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 Tom SharpOregon Cattlemens AssociationSeptember 1, 2021 Mr. Craig Kohanek, Water Rights Analyst Oregon Water Resources Department 725 Summer St. NE, Suite A Salem, OR 97301 Re: Comments on ODFW’s In-Stream Water Rights applications: • Application IS-89082 – Sixes River #3 • Application IS-89074 – East Fork Coquille River The Oregon Cattlemen’s Association (“OCA”) was founded in 1913 and advocates on behalf of ranchers and their families to ensure continued success of their operations and contributions to Oregon communities. OCA is committed to sustaining the economic and cultural tradition of caring for Oregon’s working lands while producing one of the State’s top agricultural commodities. Water resources are of the utmost importance to OCA’s members. We appreciate the opportunity to comment on Oregon Department of Fish and Wildlife’s (ODFW) In-Stream Water Rights (ISWRs) applications for IS-89082 – Sixes River #3 and IS-89074 – East Fork Coquille River. We oppose the granting of ISWRs to ODFW for the above referenced applications in OWRD’s Southwest Region. We are concerned about the potential injury to existing water right holders, the possible limitation grant of those ISWRs would have on future development in these areas, and the questionable availability of water these ISWRs are seeking. We are concerned regarding the damage granting of ISRWs could cause by limiting transferability of existing water rights. There is also a concern about the limitation on the movement of the point of diversion where ISRWs are granted. We can foresee the possible claim of injury ODFW could make that could prevent transfer of existing water rights or require unreasonable mitigation. Such mitigation often results in a portion of the transferred water rights being dedicated to additional ISWRs. We also want to raise the concern that the water ODFW is requesting in these ISWRs does not actually exist. Some streams have low volumes in the summer and others now go dry in the summer. It would be irresponsible to grant ISRWs for water that will never be in the system. We believe that granting of these ISWRs will have an adverse impact on the economy of the area. Based on the information we have provided, the ISWRs should not be granted.