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DateNameCompanyComment
 Brian PosewitzWaterWatch of Oregon1. In general, WaterWatch opposes in-channel reservoirs due to their impacts on fish passage, water quality and stream hydrology. To the extent water storage is required and justified, it should be off-channel. 2. The application indicates that a new dam will be built 500 feet downstream from the existing dam. That would change the point of appropriation for the existing storage rights, which is not allowed (because storage rights are not water uses subject to transfer). Thus, the application should be for a new storage right for the entire anticipated volume. 3. The application suggests that upstream "passage" for adult fish will be provided with a trap and haul system. We questions whether that constitutes fish "passage" within the meaning of Oregon's fish passage statutes. Passage should be volitional or, if not, the applicant should be required to get a waiver of fish passage requirements, showing a "net benefit" to native migratory fish, before the application is approved. 4. Reservoir storage in the stream channel will injure and conflict with instream water rights for aquatic life in Rickreal Creek. 5. The application is not clear on whether storage will include water from Rockhouse Creek. Page 2 was amended to remove that reference but page 5 still includes it. 6. Any permit issued should include all conditions recommended by the watermaster, ODFW and ODEQ. 7. The applicant should be required to have all land-use approvals before a proposed final order is issued. 8. The application should include further specific commitments to streamflow augmentation, by secondary water rights, to offset ecological harm of in-channel storage. 9. The application lacks sufficient detail for full public interest evaluation (e.g. regarding outlet works, buffering for water quality, flow augmentation, temperature control, etc.). 10. Any approved dam should include temperature control to avoid harm to water quality.