Oregon Water Resources Department
Electronic Public Comments
Application: S 89855
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Date
Name
Company
Comment
01/23/2025
Kirk Maag
Stoel Rives LLP, on behalf of Port of Morrow
The Port of Morrow (Applicant) believes the Initial Review for Application S-89855 incorrectly concluded that the source of water for the proposed use is “an unnamed stream.” The Department’s conclusion is not supported by substantial evidence and is inconsistent with the findings of fact and/or conclusions underlying the Department’s approval of other applications, including Application S-29309 (now Certificate 30022), Application S-68481 (now Certificate 91286), and Application S-54163 (now Certificate 91287). That error had cascading impacts throughout the analysis in the Initial Review and led the Department to preliminarily determine that the application is unlikely to be approved. Applicant believes these issues could be most efficiently addressed in a meeting between Applicant, its representatives, and Department staff. In any event, Applicant encourages the Department to re-examine its analysis before issuing a proposed final order.