Records per page:
DateNameCompanyComment
 Patricia CarrollOregon Lakes AssociationOregon Lakes Association (OLA) supports the issuance of the instream water right in the amount applied for by ODFW. Fulfillment of these applications will provide assurance into the future that instream flows for stream biota and channel function will be available without jeopardizing the existing valid water rights issued for other beneficial uses.
 Ellen PorterUmpqua Valley AudubonUmpqua Valley Audubon Society provides this comment in support of the issuance of the instream water right in the amount applied for by ODFW.
 Mark RogersOregon Council Trout UnlimitedThe Oregon Council of Trout Unlimited supports Application # IS 89308 in the amount applied for by ODFW. Thank you.
 Shaun PigottTrout Unlimited - Deschutes Redbands ChapterThe Deschutes Redbands Chapter of Trout Unlimited, representing 758 local members in the Deschutes Basin, supports the in-stream water right application # IS 89308 in the amount applied for by ODFW.
 James FraserTrout UnlimitedTrout Unlimited (TU) supports this Application (IS 89308) in the amount applied for by ODFW. TU is a non-profit dedicated to conserving coldwater fish (such as trout, salmon, and steelhead) and their habitats, and we have more than 350,000 members and supporters nationwide. Thank you for considering our input.
 Jennifer FairbrotherNative Fish SocietyNative Fish Society supports the issuance of the instream water right in the amount applied for by ODFW. Thank you.
 Ryan HoustonOregon Natural Desert AssociationThe Oregon Natural Desert Association supports this instream water right.
 Caylin BarterWild Salmon CenterWild Salmon Center supports approval of instream water right application IS-89308. We do not support OWRD’s proposed reduction of streamflow protection to estimated average natural flow regardless of the biological needs of fish.
 Kimberley PriestleyWaterWatch of OregonWaterWatch strongly supports the issuance of this instream water right in the amount requested by ODFW. We are also submitting a longer letter of support, but wanted to include this statement of support on the electronic record.
 Barry ShullanbergerLake CountyApril 20, 2023 To: Oregon Water Resources Department Re: Public Comment for Applications IS-89308, IS89312, IS-89315 The Lake County Commissioners would like to provide the following comments for the proposed ISWR applications listed under these streams within Lake County. Lake County lies in the rain shadow of the Cascade Range within a series of closed-basin watersheds. This region of Oregon is solely dependent on winter snow pack to feed stream flow and lake fill. Water availability and reliability is unpredictable as cycles of drought are not uncommon. The county is currently experiencing its third year of exceptional drought conditions, placing great challenges and hardship on the communities and species that rely so heavily on water. Unique to the closed basins of Lake County are endemic fish species. These fish species have evolved to become morphologically and genetically distinct, adapting to alkaline waters and fluctuating flows. Key to the survival of these species is connectivity to upstream refuge habitat during periods of drought. Limiting factors impacting population distribution and abundance include road infrastructure with perched culverts, irrigation diversions, and channel modifications that have degraded stream function and valued habitat. Our local land and water agencies, in particular the Lake County Umbrella Watershed Council (LCUWC) and the Lakeview and Fort Rock Soil and Water Conservation Districts (SWCDs) have done an amazing job treating our landscapes and improving water resources. From 2005 to present, the two partners have secured and spent over $12.4 million towards 54 stream projects that address fish passage, aquatic habitat, and riparian improvements, as well as irrigation efficiencies. Landowners have been willing to work with our local agencies, including local ODFW specialists, to achieve these important improvements. Between the LCUWC and the SWCDs, there is currently $916,264 in grant money earmarked for six Warner Valley stream projects and $737,903 focused on three Goose Lake Valley projects. Both funding numbers focus 80% of the funding towards materials and construction, much of which is spent with local contractors and construction companies. This demonstrates our economic reliance on these projects, as well as the ecological benefits they provide. Landowners are now reluctant to commit to these projects since ODFW gave notice of intent to file for ISWRs this past summer. This intent to file and the resulting stalemate in project work not only delayed or canceled important stream improvements, but has also resulted in less jobs created to complete the projects, and strained relationships with landowners that have been a vital part of LCUWC and SWCD success. Lake County hosted one of the state leaders from ODFW this in the fall of 2022 where 36 local landowners came to discuss potential ISWR requests at that time. It was very much appreciated that ODFW made this effort to come visit in person. We also had Representative Mark Owens there to help with discussions and potentially lead to options that ODFW and local landowners could work with which we have called “Option B.” Option B would allow for collaboration with ODFW and landowners to come up with a solution other than filing for ISWR to meet the needs of both. ODFW initially agreed to this collaboration to come up with a solution but soon changed direction and filed ISWR’s instead. ODFW has agreed to request to OWRD to put the ISWR’s on administrative hold to continue those discussions. The County intends to have future discussions with ODFW to see where we could agree. One of the issues we continue to hear is that the landowners are looking at the estimated average natural flow described in each of the applications. We understand that this is a model and the model was run from 1958 through 1987 using streamflow estimates from that time period to come up with an average. The estimated average is nowhere near reality in today’s streams being discussed. An example is IS-89313 Drake Creek where the model shows an estimated streamflow in July of 7.63 cfs to a low in January of 6.69 cfs. Drake Creek was extremely low due to drought and lack of snow pack. Instream water rights are not being met particularly in the summer months. The commissioners hear of examples like this across the county. The reason for this example is that when we go to discuss with landowners about options that we could discuss with ODFW concerning instream flows, we need a baseline that is true to real conditions to start with for average natural flow so that everyone is on the same page. Instead, we have a highly inflated estimated average natural flow that does not correlate with what is in today’s streams in Lake County. The ISWR applications we have received for Lake County show that OWRD is using these estimated average natural flows to determine what an allowable instream use would be. Decisions are only as good as the information that you have available. According to OAR 635-400-0015 (10)(b) Instream flow requirements greater than 70 percent or less than 30 percent of the naturally occurring stream flows or water surface elevations for any given time period shall be evaluated for appropriateness of the requirement in relation to naturally occurring stream flows or water surface elevations. Because a recent and accurate assessment has not been done, it calls into question the validity of the data collected and how it applies to OAR 635-400-0015, and therefore also its appropriateness to the current situation. Lake County would like to see OWRD help with this situation to provide new numbers to come up with current cfs flow numbers that would give the County a new baseline to then discuss protecting instream flows. This information would be extremely valuable in collaborating with ODFW to further discuss an Option B in lieu of an ISWR. Lake County would like to continue with the administrative hold on these ISWR so that we can work to together towards other solutions other than an ISWR. The county commissioners do not support the ISWR applications submitted by ODFW currently up for review within Lake County. We feel that the economic impacts would be significant and the proposed use will impair or be detrimental to the public interest. Without water, agriculture cannot survive especially in our high elevation, closed basin watershed so dependent on winter snowpack. We appreciate this opportunity to provide comment and are available for further conversations if needed.