Oregon Water Resources Department
Electronic Public Comments
Application: G 19249
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Name
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Comment
Eric THompson
The Groundwater Review states: “No nearby wells fully penetrate alluvial aquifer in this area, and thus potential injury to nearby groundwater users was not assessed for this review.” But it does not make clear what depth would be assumed to fully penetrate alluvial aquifer. Several nearby wells are at similar depth and should all be assessed for the review. Wells within 0.5 miles: COLU 2244 (130’) COLU 2245 (156’) COLU 2246 (100’) Wells within 1 mile: COLU 437 (105’) COLU 1896 (100’) COLU 1902 (119’) COLU 1905 (106’) COLU 53321 (100’) [Many more from 1-2 miles] My residential well is one mile away already has periods of complete water depletion from June through October. This application proposes to increase groundwater usage near me by more than 10x the current usage! I have concerns that my current water supply problems would become even worse with this massive increase in groundwater usage. I would like to see the full analysis and data that lead to the conclusions in the report that “groundwater is not over-appropriated and the proposed use is within the capacity of the resource”. I question the validity of this because I already have water depletion problems. I specifically question what is the capacity of the resource and how does this appropriation of more than 10x current usage affect the many wells within 1 mile of the irrigation source? Proposed: Complete a more thorough groundwater analysis including the effect on wells within 1 mile with applicable data and a full water budget over the area that shows that appropriation at each well site is well within the estimated capacity throughout the year. This should show both current state and projected state if this additional 749 acre-ft of water is pumped from this single point during the driest time of year.
Eric Thompson
The Original Application Section 9 should include the Rainier Drainage District which encompasses all of the lands referenced in the application. The Rainier Drainage Improvement Company includes all of the properties in this district and is established under ORS 554 to provide flood control, drainage, and irrigation for the lands inside the district. Proposed: The original application should be amended with these considerations and re-released for review.
Eric Thompson
West Rainier Water Association
The well for the Public Water System of the West Rainier Water Association was not mapped or considered in the Groundwater Application Review. This well (COLU 2244) is nearly the same depth and approximately 20 feet away from the proposed irrigation well (COLU 2248) on the same parcel. It can be assumed that these two wells are drawing from essentially the same hydraulic point, and there is potential for substantial interference with water availability for the members of this public water system. Any depletion simulations should consider usage by both of these wells, and depletion assumptions should be assumed to impact both of these wells. It is not clear how the irrigation well (COLU 2248) can be used on this property and still comply with the Cross Connection Control Requirements of OAR 333-061-0070 which identify it as a High Risk Health Hazard that requires backflow prevention for the premises. I propose that the Groundwater Application Review be amended with these considerations before proceeding to later reviews. .