Oregon Water Resources Department
Electronic Public Comments
Application: R 89435
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Comment
Brian Posewitz
WaterWatch of Oregon
The application should be denied because the use cannot reasonably be restricted to the period ODFW indicates is necessary to prevent significant detrimental impact to existing fishery resources. ODFW recommends that no storage take place between May 1 and November 30 because any water stored then would be needed for downstream flow to support fish. However, the application indicates the reservoir would be in an intermittent stream that generally flows in both May and November. The reservoir would also unavoidably capture rainwater June-October. Without precise monitoring of inflow and outflow, the reservoir will store water when ODFW says it cannot do so without harming fish downstream. However, OWRD will not require measurement of inflow and outflow and there will be no enforcement oversight. The reservoir will therefore inevitably store water when ODFW says it should not. If a permit is nevertheless issued, it should require measurement of inflow and outflow. It should also include, verbatim, ODFW's recommended water quality condition for an on-channel reservoir, which requires a plan to detail how water quality standards will be met even though the reservoir is likely to aggravate water-temperature problems in downstream waters by reducing flows and releasing, at times, warmed and polluted water.