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DateNameCompanyComment
 Jody Perry Hello, I understand that Mr Blech intends to go for the gold on the property. He tried to get several of his neighbors to go in with him. His intent is to open a gravel pit & then if gold is found he can circumvent expensive permits etc to continue with what's necessary to rape & poison the land for hoped profit. He has no regard for the health of Grave creek nor any consideration of the other residents in the area. Have you ever heard a rock crusher? Why can't he do something wonderful with the land instead of going for gold & buying off our county commissioners like Simon Hare. I hope you absolutely stop this already rich monster!
 Lisa BrownWaterWatch of OregonDue to formatting and word limit issues in WRIS, WaterWatch has submitted a letter to WRD regarding Application S-89848. To summarize, Application S-89848 is an “expedited secondary” water right application that seeks water for use at a controversial proposed large-scale mine that would be located in Sunny Valley near numerous residences and domestic wells and next to Grave Creek, with its cherished fish runs, which flows into the prized Rogue River. The application implicates several significant public interest issues and should not be processed an expedited secondary permit. The proposed source reservoirs (permits R-15319 and R-15320) were improperly permitted based on faulty SWARS data that completely omitted the instream water right (Certificate 72697), resulting in allowed diversions into storage during months when water was not and is not available. That problem has not been corrected by OWRD. Further, there is no mechanism to ensure that water would not be diverted into the reservoirs when the instream water right is not met (which again, was not considered at time of issuance of the reservoir permits which were issued during months when water was/is not available). This implicates many public interest issues detailed in our comment letter. The proposed mine and the many attempts to get approvals and water rights have been the topic of numerous proceedings and reviews due to the significant expected impacts. Applicant lacks any approval from DOGAMI to conduct mining and lacks approval from DEQ to conduct mining that involves any water use. The proposed water use raises significant water quality concerns that have not been addressed. The Rogue Basin Program Rules require any mining water use approval to be conditioned to protect water quality. Ensuring that can be done needs to be addressed in a non-expedited permitting process. In sum, this application proposes a use that is inappropriate for an expedited permit due to the myriad of public interest issues involved. It also does not qualify for an expedited application because no storage has been authorized in the source reservoirs. At a minimum, WRD should refer this application to the standard process for a full review. We also flag that this application is nearly identical to Application S-88508 which has been pending since 2018, and regarding which many public comments were submitted. Thank you for considering these comments. Please do not hesitate to contact me with any questions or for more information. S/ Lisa A. Brown Lisa A. Brown Staff Attorney lisa@waterwatch.org
 Gregg Getchell Public Comment regarding Application S-89848 by Sunny Valley Sand and Gravel I live in Sunny Valley and have been involved in the attempt to open a mine in the floor of this small valley. Since the inception of this project the need for study and review has been forefront to the public interest as the necessary applications and permits were submitted for approval. I understand, from following this project for years, that this business currently lacks approval for water storage in 2 specific reservoirs along with no approval (DEQ) to mine with water or an approval to do any mining. (DOGAMI) All adding to how important a full review process is with every application related to this project. As a resident living in the designated impact area of this project I feel water use approval is the instrumental most important aspect above everything else in the overall application to open this business and supports the case for deep public interest and review in its behalf. This has held true here for approximately the last 14+ years with this case. The scope of the project has demanded and led to full and complete reviews, studies, hearings and reports and experts at every step the way. This applicant has essentially the same application still on file, filed in 2018, waiting on a decision. Why would the examination of this new application, now with a request for an expedited review be looked at in a less complete way? Why grant a process that is trimmed down, streamlined and handled differently to such a pivotal decision? A review weighed out against the scope of this project and its risk to our water in this small area supports the denial of an expedited review process for this particular application. I request a full review process be used to review this application. Thank you, Gregg Getchell 3370 Sunny Valley, OR 97497
 Diane Getchell I am responding through Public Comment regarding Application S-89848 by Sunny Valley Sand and Gravel. I have followed this project closely since its inception close to 14 years ago and live in the designated impact area of 1500 feet. Since the beginning of this endeavor there have been significant related public interest issues and I believe when a project of this scope is proposed there should be careful steps taken to thoroughly examine every related aspect, taking necessary time for study, input and assessment. The public interest should not be fall out or the casualty in this situation. This process should not be limited in any way through and by expedited approval. I am aware of a closely similar application S-88508, submitted in 2018, as I submitted comments on that application at the time. Due to the review duration of this application it would support cause to not expedite a new, similar one, as it has not been approved and is still under review. I can only surmise that if a similar duplicate application, now requesting expedition, has been submitted that this applicant is hoping through limited that review that certain studies, assessments and reports will not be done or disregarded as there will not be time under this sped-up, streamlined and limited process. This would lead to future approvals, where water is concerned, that were done circumventing a full review process. Every water use aspect of this disproportionate sized project in this small valley threatens the existence of residents here and those living downstream to where Grave Creek enters the Rogue River. This is a projected 40-year project. Our domestic wells and the aquifers here and along the creeks are already at risk posed by illegal drug grows. Water is a huge Public Interest issue. It is protected by OWR by way of careful review. (ORS 537.170(8)) Weighing the public interest regarding the threats that this project brings to the water use in this valley strongly support the fact that a full review is appropriate with this application. That will be accomplished by denying an expedited review. Diane Getchell 3370 Placer Rd Sunny Valley, OR 97497
 Frances OyungRogue RiverkeeperThank you for the opportunity to comment on Application # S-89848, which seeks an expedited secondary permit for stored water use under permits R-15319 and R-15320 by Sunny Valley Sand and Gravel, Inc. Rogue Riverkeeper, a program of the Klamath-Siskiyou Wildlands Center, represents over 4,000 members and supporters who are dedicated to protecting the water quality and fish habitat of the Rogue River. We urge the Oregon Water Resources Department (OWRD) to deny this expedited permit and instead review the application through the standard process as outlined in ORS 537.153. The proposed activity, part of a larger aggregate mining development along Grave Creek’s floodplain, lacks land-use approval and could adversely affect public interests, including water conservation, protection of existing water rights, economic considerations, and alignment with state water policies. Additionally, related permits for this mining project are still under review, and a comprehensive assessment is necessary to prevent any detrimental impacts to public interests. Thank you.
 Steven Lawwill  Please consider the many issues involved with Application #S-89848 before approving an expedited secondary procedure. This application deserves a thorough review in light of the threats this mine presents to surrounding homesteads and Coho salmon. My family depends on a domestic water well within the impact area of Sunny Valley Sand & Gravel (SVS&G). We are depending on Oregon Water Resources Department to protect our water from contamination, diversion (intentional or accidental), and over use. This area in known for ultramafic and serpentine soils. The materials to be mined by SVS&G were actually deposited by a debris flow from an ultramafic zone well documented by the USGS. The recycling of processing wash water will fill SVS&G ponds with concentrations of chromium (Cr), cobalt (Co), iron (Fe), manganese (Mn), nickel (Ni), scandium (Sc) and chrysotile asbestos. Liners are subject to failure and do not adequately address the risk. Issuing a water right for mining poses a significant risk considering the area involved. I urge OWRD to deny an expedited secondary procedure and to not approve this stored water to be used for mining.
 Raymond Baxter I am opposed to the approval of this application. If approved, SVS&G will continue with their plans to excavate multiple 80' deep pits along Grave Creek. It doesn't take a college degree in hydrology to understand the basic laws of water flow. The path of least resistance is always constant, volume and pressure are directly related and alterations in any segment of a delivery system will affect the entire system. Should the excavation of the before mentioned pits intersect with, and open the fissure that my well is in, the water within that fissure will freely flow into the open pit, thereby dropping the pressure in the entire system. When the pressure drops the volume will also drop. This will reduce the amount of water in the system and the gallons per minute available in my well. I, like many of my neighbors, have spent years building homes, out buildings and shops, and landscaping our properties. I have some serious concerns about a deep pockets commercial GOLD mining operation coming into our beautiful valley and threatening to take away the water supply that is vital to maintain the life styles to which we have become accustomed. Laws, statutes, ordinances, regulations, procedures, etc. should not be utilized verbatim, but more as guidelines. A fair, just and righteous decision can be made when these guidelines are mixed with a healthy dose of COMMON SENSE. Do not expedite or approve this application or the identical previous application #S-80508. For the sake of the waters entrusted to you for the people of Oregon, move this to a full review process and DENY.
 William Lorch The application must be denied due to illegal use of the water well near the east border of the property. An OWRD representative went to investigate another water issue and noticed the east well being used illegally and told the landowner to shut down the well. The landowner has also illegally diverted water from Grave Creek and Shanks Creek. He fabricated a large trackhoe up on the shoulder of Placer Road and then drove it down the steep embankment causing major soil damage and across Grave Creek during spawning season on to the property. These actions as well as others constitute a lack of trust in the landowner which constitute the denial of this permit application.
 Andrew Martin These permits were issued in error. They do not have rights to use this water, and their evidence of use after 2009 is invalid and must be re-evaluated. The water was never used here to irrigate this land during their proposed period which means they forfeit the rights. If they are given rights, they will divert a major amount of water which will limit the amount of water everyone receives in the valley for the following near 20 miles. This will impact salmon spawning and also our wells in the surrounding area. There is concern of contamination due to the high levels of serpentine rock that will be crushed and enter the creek via possible seepage, as the Reservoirs are not properly lined. Please look at the aeriel evidence that shows irrigation was never performed and our testimony that no diversion or irrigation ever took place.
 Debra Lawwill Oregon Water Resources Department must consider the many complex issues involved with Application #S-89848 & #S-89508 before approving an expedited secondary procedure. This application deserves a thorough review in light of the threat these issues will have on the quality and quantity of water for domestic water wells and endangered and threatened fish and wildlife in the Rogue River Basin. This second request (originally S-88508/2018) now brings additional reason of concern for domestic water wells. Allegedly, a sand and gravel operation in Prineville, OR Crook County has contributed to harmful levels of manganese in water wells. The proximity of the Sunny Valley Sand & Gravel mining plan to Grave Creek has the potential to be even more harmful. The Oregon Water Resources Department should NOT approve Application #S-89848 and/or #S-88508 as an expedited secondary right.
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