Oregon Water Resources Department
Electronic Public Comments
Transfer: T 13777
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Brian Posewitz
WaterWatch of Oregon
Any transfer approved pursuant to this application should make clear that the water can only be appropriated during the irrigation season (even if used for industrial purposes). The water rights proposed to be transferred are so limilted and the transfer statutes do not permit the Department to change the season of use, which is more likely to cause injury and/or enlargement in any event. Moreover, the transfer must incorporate all limitations in the water rights proposed for transfer, including the cumulative limitations among related water rights. Thank you for considering our comments.