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 Lisa BrownWaterWatch of OregonWaterWatch of Oregon's Comments on the IR for Application S-89469 Thank you for opportunity to comment on the IR for application S-89469 for year-round industrial use of 7.5 acre-feet from two sources: the South Umpqua River and the Galesville Reservoir (which impounds Cow Creek, a tributary to the South Umpqua River). The application map depicts the POD as being on the South Umpqua River in Dillard (T28S R6W S29), approximately 36 miles away and of Galesville Reservoir (T31S R4W). We request that the IR be re-issued because it does not reflect the classifications for the South Umpqua River and its tributaries established in WRD’s Umpqua Basin Program Rules. OAR 690-516-0005(1)(e). WRD’s Umpqua Basin Program Rules state: “The unappropriated waters of the South Umpqua River and tributaries, excluding Lookingglass and Roberts Creeks, are withdrawn from further appropriation except for human consumption, livestock consumption, irrigation of up to 1/2-acre non-commercial garden and water legally released from storage from July 15 through September 30 of each year, by the Water Policy Review Board's Order of Withdrawal dated April 29, 1985. This limitation shall not affect the withdrawals previously enacted by the Board for the waters of Roberts and Lookingglass Creeks.” OAR 690-516-0005(1)(e). The IR (p. 2) states that year-round use from Galesville Reservoir may be allowed, if applicant secures and files with WRD an agreement with the reservoir for stored water. This does not recognize that the Umpqua Basin Program Rules for the South Umpqua and its tributaries only allow use of water “legally released from storage from July 15 through September 30 of each year.” OAR 690-516-0005(1)(e). This limit applies to application S-89469, which apparently requests (at least in part) to divert water released from storage at Galesville Reservoir downstream at a POD on the South Umpqua River below its confluence with Cow Creek. We request that the IR be reissued to reflect this limitation and state that water may be available for only from July 15 through September 30 of each year. We also request that any re-issued IR specifically state that, pursuant to the Umpqua Basin Program rules, the South Umpqua and its tributaries are withdrawn from appropriation except for certain uses that do not include industrial use. Id. Therefore, we request that any re-issued IR explicitly state that the South Umpqua River, which the application identifies as a source for the use, is not classified for appropriation for industrial use. Thank you again for the opportunity to comment. We may have additional comments upon further analysis. Please do not hesitate to reach out with any questions. Best, Lisa Brown Staff Attorney lisa@waterwatch.org 503.295.4039 x102