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DateNameCompanyComment
08/20/2021Brian PosewitzWaterWatch of OregonThis reservoir application appears related to applications R89111-15, 17-21. WaterWatch's comments on those reservoirs apply equally here: The application says the reservoir will be outside of any “defined channel or stream.” This is probably in the eye of the beholder as the reservoir may in fact be in some type of gulch, draw or low area that concentrates flow – what others might call a defined channel or stream, even if flow is only intermittent or ephemeral. This is confirmed by verbiage in the applications that says there will be no diversion away from the normal path of the runoff but that the reservoir will be filled by stopping the flow of water with a dam. Comments from ODFW say the reservoir could have significant detrimental impacts on fishery resources by diminishing downstream flows below biologically necessary levels; and by harming water quality if water is released from the reservoirs after storage because water passing through small reservoirs tends to get warmed by exposure to increased solar radiation and to pick up other pollutants from associated land uses (fertilizers, pesticides, animal waste, etc.). ODFW and the water master both recommend limited storage seasons (with some variation that should result in adoption of the shortest recommend storage season). ODFW also recommends a condition that no water be released from the reservoir except for dam safety. All conditions recommended by ODFW should be included in any permit. However, if the reservoir is in fact located in topography that tends to concentrate runoff, and if precipitation occurs outside the recommended storage season, which is almost certain to be the case, the two conditions described above cannot both be met. If precipitation occurs outside the storage season, the limited storage season requires that it not be stored. However, if the reservoir is in the path of concentrated runoff, the only way to not “store” the water is to make sure an equal amount is released from the reservoir, which would violate the no-release condition for water quality. Thus, the Department should verify that the reservoir would not be in any kind of feature that would tend to concentrate any runoff from precipitation outside the storage seasons or, to the extent it would, deny the application on grounds it would harm fishery resources either by reducing flow or harming water quality (it would necessarily do one or the other, as explained above). Finally, materials submitted with the application indicate several of the related reservoirs have already been constructed, apparently without the required water storage permits. OWRD should not simply permit illegally built reservoirs without consequence for having broken the law. Thank you for considering our comments.