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 Elissa KarimWaterWatch of OregonThank you for the opportunity to comment on the T-14020 application by Silver Sage Farms. We urge that the transfer be denied for several reasons. First, the proposed transferred lands fail to meet OWRD’s certificate reporting requirements. Second, the applicant has demonstrated a pattern of illegal irrigation on the lands proposed to be transferred to since 2014. Finally, this proposed transfer project cannot be enforced by OWRD. Should a PD be issued, we may raise additional issues as we compile additional information on this matter. For more details, we have emailed our full public comments and enclosures to the OWRD employees Joan Smith, Patrick Starnes, Arla Davis, and Corey Courchane. Please don’t hesitate to be in touch if you have questions. Thank you again for the opportunity. Sincerely, /s/Elissa R. Karim Elissa R. Karim Legal Intern WaterWatch of Oregon ekarim@uoregon.edu Enclosures: T-14020 Certificate Allowance Calculation Data WaterWatch letter to OWRD re: illegal use in Weaver Springs 3-1-2021