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DateNameCompanyComment
04/07/2026Rory IsbellCentral Oregon LandWatchApril 7, 2026 Filed via email: Mary.f.bjork@water.oregon.gov Oregon Water Resources Department ? Mary Bjork, Senior Water Right Technician 725 Summer St NE, Suite A Salem, OR 97301 Re: Application # LL-2023 (Knife River Corporation – Northwest) To Whom It Concerns: Thank you for the opportunity to provide comment on the above-referenced limited license application. Central Oregon LandWatch (LandWatch) opposes the issuance of the requested limited license and respectfully requests the Department deny the application. LandWatch is a land use and conservation advocacy organization with over 900 members that has proudly protected Central Oregon’s forests, farmland, high deserts, rivers, wildlife, and vibrant communities for 40 years. LandWatch works on water resource issues throughout the Upper Deschutes River Basin, including the Crooked River Basin. We continue to be interested in both restoring instream flows and supporting an efficient irrigation-based farming community throughout Central Oregon. LandWatch's members and the public have an interest in the scenic, recreational, and fish and wildlife habitat values of the Crooked River Basin and the Deschutes Basin, and in maintaining the health and safety of public groundwater resources by preventing groundwater depletion and contamination. Additional groundwater withdrawals threaten the public’s interest in the Deschutes and Crooked Rivers and are likely to exacerbate existing groundwater quality problems. The proposed limited license directly conflicts with the interests of LandWatch and its members, as outlined below. 1. LandWatch’s opposition to this limited license application arises in the context of existing groundwater quality concerns in the area surrounding the well sites proposed for additional pumping. The subject property appears to be at the epicenter of a slowmoving public health and environmental quality crisis. For several years now dozens of residential and agricultural wells in the area have been contaminated by dangerously 2 high levels of manganese, arsenic, and other heavy metals. Residents have experienced serious health problems, children have broken out in hives, livestock have been stillborn, property values have been destroyed, and tens of thousands of dollars have been spent on retrofitting existing wells. To be clear, at this time, the exact cause of the contamination is undetermined, and LandWatch expresses no opinion on whether the industrial activities on the subject property are related to the contaminated well water.1 Nevertheless, it is imperative that OWRD take the well-documented environmental conditions surrounding the subject property into account. The fact that the cause of contamination is undetermined is not a reason to proceed with business-as-usual in the area. Any additional appropriation of groundwater, temporary or otherwise, is wholly inappropriate and reckless until the nature and cause of the contamination has been determined by the State of Oregon. We offer several Oregon Department of Environment Quality documents as exhibits in support. See Exhibit A (2022 DEQ fine showing the applicant pumped wastewater into a creek/irrigation canal), Exhibit B (2026 DEQ letter informing DOGAMI/Knife River that Knife River violated testing protocols), Exhibit C (2026 DEQ Groundwater special studies showing contamination), Exhibit D (DEQ website landing page with sampling results showing increases in levels of arsenic and manganese), Exhibit E (DEQ/Oregon Health Authority Summary Memo). News outlets have also reported extensively on this situation. Exhibit I (OPB article (August 26, 2025), Exhibit J (Central Oregon Daily article (March 18, 2025)). 2. In addition to concerns about water quality, issues of water quantity exist as well. The source of this well-documented groundwater contamination does not affect the impact that increased groundwater withdrawals will have on the groundwater resource. OWRD data from area wells show that groundwater levels are steadily declining. Exhibit F (OWRD Hydrographs for well tag 461554). This hydrograph shows groundwater decline especially during the past five years, beginning around 2021 when OWRD issued the existing limited license request for the same applicant on the same property under LL 1876. In 2021 the well level was 11.19 feet, and in 2026 the level is 43.19 feet, indicating that groundwater levels have dropped by 32 feet over the last five years. The local groundwater resource is not stable and increased groundwater withdrawals are likely 1 At least one report by a certified geologist and engineer, Jim Newton, has found that “elevated levels of manganese are probably occurring as a result of the Site mine.” See Exhibit H, page 1 (Memorandum from Cascade Geoengineering (March 20, 2023)). 3 not within the capacity of the resource. Further, decreasing groundwater levels are likely to exacerbate groundwater quality concerns, as a lowering water table is likely to lead to increased leaching or release of contaminants into the groundwater resource.2 In other words, whether the applicant, Knife River, is responsible for the welldocumented groundwater contamination is immaterial to whether the proposed limited license will exacerbate both the existing groundwater quantity and groundwater quality conditions. 3. It appears that this limited license application is not permitted under the Deschutes Basin Plan. That plan mandates that water used for industrial or mining purposes in the Lower Crooked River basin must not interfere with other beneficial uses of water. OAR 690-505-0040(4). Unless and until it is determined that the applicant’s mining activities have no causal relationship with the well-documented groundwater contamination in the area surrounding the subject property, the Department should not issue a new limited license for increased water use. The Department cannot ensure that issuing the requested limited license will not result in interference with other beneficial uses of water. 4. The application appears to seek water to serve uses disallowed under Crook County land use regulations. According to the local watermaster’s statement included in the application packet, “aggregate washing” appears to be a use for which the limited license is sought. This use, however, is disallowed under the 2015 Crook County conditional use permit (file no. 217-15-000115-PLNG) under which the applicant conducts its mining activities. That permit, also included in the application packet, states at condition of approval number 28, that “[t]he existing water well on the mill site must not be used for aggregate washing operations[.]” The Land Use Information Form completed by Crook County planning staff references this condition as well. Any use of groundwater for aggregate washing activities is not authorized by local land use regulations and would require a new conditional use permit approval. 2 Melissa A. Lombard, Johnni Daniel, Zuha Jeddy, Lauren E. Hay, and Joseph D. Ayotte. 2021. Assessing the Impact of Drought on Arsenic Exposure from Private Domestic Wells in the Conterminous United States. Environmental Science & Technology 2021 55 (3), 1822-1831. DOI: 10.1021/acs.est.9b05835 4 DOGAMI has confirmed that the applicant has already violated the conditions of its 2015 conditional use permit issued by Crook County, writing that the applicant’s “current use of the ‘settling ponds’ on tax lot 703 for the settling of process water is inconsistent with both the state and county approvals." Exhibit G (DOGAMI Memo to Crook County (October 2025)). While the cause of the significant groundwater contamination in the area of the subject property has not been definitively determined, it has been determined by DOGAMI that the applicant is in violation of state and county approvals by way of its use of settling ponds to discharge used mining proc
04/06/2026Kimberley PriestleyWaterWatch of OregonWaterWatch strongly opposes LL-2023. We have submitted extensive comments in letter form.
04/02/2026Ashley McCormickN/ATo Whom It May Concern, It has recently come to my attention that a Limited License (LL) application may have been submitted by Knife River for the Woodward site in Prineville (4755 NW Stahancyk Lane). If such an application has been filed or is currently under consideration, I am writing to formally request that it be rejected. This area is already experiencing serious water quality concerns. Numerous homes within roughly a half mile of the site rely on private wells that draw from the same aquifer. Currently, between 60+ households depend on this groundwater source for their domestic water supply. Residents in this area are already facing unsafe and contaminated water, and the source of that contamination has not yet been conclusively identified. State-led investigations are still ongoing to determine the cause of the contamination. In the past, representatives from DOGAMI indicated that drought conditions may be concentrating contaminants in the aquifer due to reduced water availability. If that assessment is accurate, it raises significant concerns about allowing additional withdrawals from an aquifer that may already be under stress. Increasing water extraction while the system is potentially experiencing depletion and contamination seems both premature and risky. Given the uncertainty surrounding the source of contamination and the existing strain on the aquifer, approving additional water allocation could further impact water availability and quality for the surrounding community. It is also important to note that Knife River has a documented history of compliance issues at this location. The company has previously been fined by the Department of Environmental Quality (DEQ) for violations. Additionally, there have been numerous Conditional Use Permit (CUP) and county code violations associated with operations at this site. These past actions raise serious concerns about the company’s commitment to responsible resource management and regulatory compliance. With the current level of oversight already appearing insufficient to prevent violations, it is difficult to believe that granting additional water rights would result in improved stewardship of the land and water resources. Most importantly, the community surrounding this site is already dealing with toxic and unsafe water conditions. Allowing additional withdrawals from the aquifer that these homes depend on could further threaten both the availability and safety of their water supply. For these reasons, I respectfully urge the reviewing agency to deny the Limited License application for the Knife River Woodward site until the source of the contamination is fully understood, the aquifer’s sustainability is clearly evaluated, and stronger assurances of compliance and oversight are in place. Thank you for your time and consideration of this matter, and for prioritizing the protection of local water resources and the health of the residents who depend on them. Respectfully, Ashley McCormick
04/02/2026Julie Thompson I am writing to formally object to the proposed Limited License that would allow increased water pumping at the Knife River/Woodward mine site. My concerns center on the potential environmental and community impacts associated with expanded groundwater extraction. Increased pumping may significantly affect local water tables, potentially reducing water availability for nearby residents, agricultural users, and surrounding ecosystems. With the current Sampling Plan taking place on site for contaminated water this seems like a bad idea. There is a risk that increased pumping could alter water quality. Changes in groundwater flow patterns may mobilize contaminants or sediments, potentially affecting both surface water and drinking water sources. Without comprehensive and transparent monitoring, these risks remain insufficiently addressed. I am also concerned that the long-term cumulative impacts of this activity have not been fully evaluated. Temporary or “limited” approvals can set precedents that lead to sustained or expanded extraction over time, compounding environmental stress in the region. Given these concerns, I respectfully request that the agency deny the application for increased water pumping Protecting local water resources is critical for environmental sustainability, public health, and the long-term resilience of the community. I urge you to carefully consider these factors before making a decision.