Oregon Water Resources Department
Electronic Public Comments
Application: R 90016
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Date
Name
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Comment
06/24/2026
Brian Posewitz
WaterWatch of Oregon
The application should be denied because the applicant cannot reasonably meet all conditions recommended by ODFW to prevent significant detrimental impact to existing fishery resources. ODFW recommends that no water be stored from May 1 through November 30. However, because this is an in-channel reservoir, it will necessarily be storing any water flowing in the channel from May 1 through November 30. Because at least some flow and/or precipitation in that period is inevitable, the only way to ensure no water is stored is to ensure outflows match inflows. However, that will certainly not occur because: (1) OWRD will not require measurement of inflow and outflow; (2) OWRD will not monitor compliance or enforce the condition; (3) the application says there is not even an outlet at the lower end of the reservoir (only that a pump can be used to evacuate water); (4) releases from the reservoir will be from stored, polluted water, which will be too warm to meet temperature criteria and likely contain other pollutants from associated land uses, such that releasing it would violate ODFW's recommended water quality conditions. In the alternative, if a permit is issued, which it shouldn't be, it should at least include all conditions recommended by ODFW, including the "On-channel Reservoir" condition requiring a reservoir operations plan to be reviewed and approved by OWRD showing how the reservoir will not store water from May through November and still comply with the water quality conditions. Thank you for considering these comments.