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DateNameCompanyComment
 Gabe Chladek Dear Oregon Water Resources Department, I am writing in regards to your Initial Review DENIAL of Pinnacle Utilities/Kameron Delashmut Groundwater Application : G-19139. I support your Initial Review Denial. The proposed use is not within the capacity of the resource available. Such proposed use will very likely harm both the Deschutes River Scenic waterway flows and the groundwater levels in the area. I have already suffered from lowering groundwater levels by having to replace my well pump from increased sediment load and lowering the well pump deeper in the well. We were lucky we were able to lower it and not have to dig it deeper, like many of my neighbors have had to do. Therefore, the proposed use of water by Pinnacle Utilities/Kameron Delashmut for the proposed Thornburgh Resort is NOT in the best public interest. I recommend that the Initial Review be turned into a Proposed Final Order and that you deny the application. Sincerely, Gabe Chladek
 Rima Givot I strongly urge you to deny application for water rights to Thornburgh Resort. As a long time resident of Central Oregon, I am watching neighbors left and right have to deepen their wells, deal with sediment in wells, and even have to redrill wells that have gone dry. This costs tens of thousands of dollars for each family. We do not actually know how much water is currently in the aquifer, nor how quickly it is replenished, and by anecdotal observation, the water is diminishing, especially in the area of the proposed resort. In addition, the mitigation Thornburgh is proposing is short term and is using water in a different area than the proposed resort itself. So the water that would potentially be drawn will be affecting a different area than the water rights they are hoping will mitigate the use. The impact of drawing six million gallons of water a day from an aquifer that feeds the Middle Deschutes River will have severely negative effects on the native ecosystem of the Deschutes River and would also have detrimental impacts on the already lowering Alder Springs and Lower Whychus Creek drainage. I urge you to have the courage to do what is right for the greater Central Oregon population and ecosystem and deny these water rights applications. There is a precedent in other communities of aquifers going dry in a desert area. Wells drying up is a current worldwide problem: https://www.scientificamerican.com/article/millions-of-groundwater-wells-could-run-dry/. Please acknowledge history and the current world status and recognize that your decision will impact our current and future generations. It's time to STOP drawing millions of gallons of water to irrigate golf courses, and really look at sustainable solutions that will support the dramatically increasing population in Central Oregon. Please represent the people of our community and deny water rights to Thornburgh to irrigate golf courses and lawns in an area that is currently covered with native plants that can sustain in the desert and also give habitat to native animals. I appreciate the work you are doing, and I urge you to keep the best interest of the Central Oregon residents and the health of the local ecosystems at the forefront of your decision. Sincerely, Rima Givot
 Kimberley PriestleyWaterWatch of OregonWaterWatch supports the OWRD proposed denial of application G-19139. The proposed use is not in the public interest for a number of reasons, including but not limited to the following: (1) As determined by OWRD’s groundwater review of application G-19139, the proposed appropriation is not within the capacity of the resource as defined by OAR 690-400-0010. (2) Contrary to the OWRD finding in the IR, the groundwater resource is over-appropriated. OAR 690-400-0010(11)(a)(B) defines over appropriated as is relates to groundwater as a condition of water allocation in which the appropriation of groundwater by all water rights exceeds the average annual recharge to a groundwater source or results in the further depletion of already over-appropriated surface water. Surface waters in the Middle Deschutes (zone of impact determined by OWRD) are over-appropriated 12 months of the year. The OWRD has found the potential for substantial interference (PSI). Thus, thus proposed use will deplete already over-appropriated surface waters, which by rule, means that groundwater is over-appropriated. (3) The Deschutes Groundwater Mitigation Program does not overcome the fact that water is over-appropriated. The Deschutes Groundwater Mitigation Program does require mitigation for all new groundwater applications to mitigate against the effects of groundwater pumping on surface water, however, existence of this program does not negate the initial determination required by rule. Per OAR 690-400-0010(11)(a)(B) groundwater in the Deschutes Basin is over-appropriated. Moreover, it should be noted that the Deschutes Groundwater Mitigation program does not include a timing element to require mitigation year-round. Thus, unless the applicant is proposing year-round mitigation, pumping under this program would still result in further depletion of already over appropriated surface water source, meaning the groundwater resource is over-appropriated any way you look at it. (4) The proposed use will result in injury to surface water right holders, including both instream and out of stream rights. Injury means that an allocation or reallocation decision will result in another, existing water right not receiving previously available water to which it is legally entitled. See e.g. OAR 690-385-0100 (6). This groundwater right will have year-round impacts on surface flows. Surface water is over-appropriated 12 months of the year. Unless the applicant is proposing year-round mitigation, instream water right will not receive previously available water to which they are legally entitled. Moreover, we did not see any proposed conditions that would protect other groundwater right holders from injury. The Deschutes Groundwater Mitigation program does not mitigate the impacts to groundwater, only surface water. Groundwater declines have been documented by the OWRD in the Deschutes Basin. (5) The applicant notes that this groundwater application serves as “back up” in case permit G-17036 is cancelled. Oregon water law does not allow for speculation in water use. G-19139 (like the two limited license applications this applicant has also submitted) is being used to hedge bets against other water right processes. OWRD cannot issue multiple rights for the same beneficial use, to do so is not only not allowed by statute but is bad public policy. (6) The applicant is proposing to store groundwater in lakes and ponds without obtaining either a storage permit or a secondary surface water right to beneficially use that stored groundwater. Under Oregon law, all ponds and reservoirs must have a reservoir permit in place before they are constructed. ORS 537.400, ORS 537.130(1) & (2). Oregon law allows for only one exception from this law for off channel ponds that were in existence on or before January 1, 1995 that store less than 9.2 af or have a dam of less than 10 feet, and had registered with OWRD before 1997. ORS 537.405(1) &(2), OAR 690-340-0010(1)(e). The OWRD’s groundwater application form on page 9 clearly states that if any groundwater under the permit will be used for storage both a reservoir right and a secondary surface water right must be obtained. Despite the law and the OWRD’s clear statement of requirements to obtain these additional permits on page 9 of the application, on page 6 of the application the applicant asserts that “storage is implicit in this use category and applicant understands no separate reservoir permit is required to accompany the application.” Contrary to what the applicant asserts, storage is not implicit in the definition of “quasi-municipal” use (See OAR 690-300-0010(4)). For these and other reasons this application is not in the public interest and the application should be denied.
 David Arnold Thank you for responding to this application with "Propose to Deny". Given the Review - Groundwater/Application (GW-Review) and the number of wells in the Cline Falls and Northern Tumalo Area are going dry. I feel this was a correct response. The Deschutes Basin Aquifer has been declining for the past 30 years. This has been blamed on drought. population growth and piping of the irrigation canals. In my 50 years living in Central Oregon a domestic well was drilled to a average depth in the 60's and 70's was 450 feet, then in the 80's the average well was 600 to 650 feet. Today, well's are being drilled to 700 feet and lower. Again I ask that OWRD do and extensive study of the Deschutes Aquifer so those of us living here a guarentied a sustanable domestic water supply.