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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”. We concur with WRD initial review to approve. The amounts allowed by WRD are less than those requested by ODFW.. October is an important month for salmon migration. Periodic high pulses of flow are needed to move fish to spawning areas. The monthly average flow does not account for natural periodic pulse flows which are needed for migration. KS Wild recommends that ODFW and WRD discuss these discrepancies amicably and proceed to issue a proposed final order.
 Miranda GrayCurry Watersheds PartnershipThank you for the opportunity to comment on this Instream Water Right (ISWR) application. This comment is on behalf of the Curry Watersheds Partnership, which is a group of non-regulatory organizations working together to help local landowners and communities keep Curry County's lands and rivers healthy and sustainable. The Curry Watersheds Partnership includes the Curry Soil and Water Conservation District, the South Coast Watershed Council, the Lower Rogue Watershed Council, and the Curry Watersheds Nonprofit. Our mission is to support our communities to care for our lands and waters, now and into the future. It is our understanding that ODFW’s application for this ISWR is for water that is already over allocated for summer months, and therefore it seems as if this proposal would have little or no bearing on new junior applications at this time. We also understand that the intent of this ISWR is not to harm or otherwise impact existing water rights, while protecting flows for wild fish going forward against new water withdrawals for other uses. We believe that the ISWR is important because it provides a goal for achieving the instream flows needed to support water conservation, fish and wildlife habitat, improved water quality, and recreation for our community. However, there is concern that local farms and ranches could be negatively impacted in the future, when and if water would become available. To address these concerns we suggest that OWRD consider a temporary alternative, such as a time-limited instream water right or lease, instead of issuing ODFW a permanent ISWR certificate to be held in trust by OWRD. We understand that water leases are for an initial period of up to five years, at which point the water right holder can apply for renewal. If and when the water conservation goals of the ISWR are met, we would ask that ODFW and OWRD revisit this application in close consultation with our local governments. Additionally, we want to underscore that there seems to be a lack of communication between state and local agencies and local governments. This lack of communication only perpetuates the sense that the decisions are all being made “top-down” without local input. We work closely with local ODFW staff and are aware that they work in a positive and collaborative way with local ranchers to lease water rights in a way that is mutually favorable. We don’t want to see these issues turning into local government working against ODFW’s recommendations, and suggest working on clearer communication with local agencies in the future. One of the pillars of our work is to support landowners and public agencies to care for their land in ways that sustain clean rivers and streams, foster abundant fish and wildlife, and keep local farms, ranches, and forest lands productive. We believe that this can happen, but only when landowners, their elected representatives, and public agencies work together towards common goals. Thank you for your consideration.