Hello friends, this is a piece I've been meaning to write for a month and I'm glad to have finally taken the time to sit and write this down. This is written as a letter to submit to the US Fish and Wildlife Service as they review a proposed draft of the Deschutes Basin Habitat Conservation Plan submitted by the water board of our region.
Even if you don't live in Oregon, if you live in the West this sort of issue is no doubt at play in your region as water in the west is complicated and founded on 100 year old laws and doctrines that in my opinion, need some serious innovations as climate change and population pressures threaten our resources, our rivers, entire ecosystems, and our rural communities.
There are a lot of deeply important sides to this issue, a lot of people have focused on the threats to fish and wildlife which is of primary concern, so I wanted to use my first hand experience in irrigation and farming in the two irrigation districts that most need to work together, COID (Central Oregon Irrigation District; Bend, Redmond, some Tumalo) and NUID (North Unit Irrigation; Jefferson County) of which COID is a Senior Water rights holder with a lot of power, and NUID being the most Junior Rights holder and who is first to have water allotments cut back/ off. Our district NUID has already been cut back 1/3 of our normal water allotment. On normal years we operate with 2.5 acre feet of water, this year we farmed with 1.6 acre feet allotment. We watered at night, our water is metered and we order it in each week as needed, we were very conservative, we catch any runoff water we can, and we are pursuing pump-back systems to maximize our water efficiency. We used to farm east of Bend, so have years of experience using irrigation water systems in COID and our experience now in Madras has only highlighted the insane waste of their systems.
One thing I wanted to focus on, that I have not seen really talked about much, is the concern over how the Doctrine of Prior Appropriation definition of "Beneficial Use" of this precious resource, irrigation water, is in need of assessment and conversation in Central Oregon. Please read this and consider this point of view. Please Share this with anyone you think might read it and find it important. Perhaps its a point of view you've never considered?
US Fish and Wildlife Service is reviewing the DRAFT Habitat Conservation Plan right now and they are taking public comments through December 3. PLEASE SUBMIT A COMMENT! You can submit a simple form response via deschutes3030.org or you are welcome to pull anything you like from what I wrote if it resonates. At the end I pasted info as to where to submit comments, or where to read the Draft HCP.
Again this is hugely important for the future of our region, our river, our family farms. Because some districts hold power via seniority and money doesn't mean their wasteful ways can continue. We need communities to hold our municipalities responsible.
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Docket no. FWS-R1-ES-2019-0091
To whom it may concern;
After reviewing the draft HCP and attending several meetings in Central Oregon regarding the drafted proposal, there are several key issues not adequately addressed and I would like the Service to consider demanding further investigation of how senior water rights districts will actually reduce the massive waste of our irrigation resources within their districts now.
My husband and I farm professionally in Madras, Oregon. Previously we farmed east of Bend for almost 10 years. We have direct experience as patrons of COID and NUID and it is very clear to anyone with this perspective the blatant WASTE of water within COID. I understand COID very recently has begun initiatives toward piping projects, but these measures come decades late and will take decades to implement, continuing to threaten not only the animal species but also the human populations down the irrigation line. The proposed HCP does not adequate address conservation measures and market incentives that could be enacted NOW, which could allow wasted water in COID to be traded or leased back to the river or to NUID, which is already operating with ⅓ less of our normal water allotment (1.6 acre feet.)
I understand the Service can not change Oregon water policy established a century ago, but I want to highlight these points as the Service considers the massive oversights and shortcomings of the drafted HCP. There is more that must be discussed and economic incentives must be created to STOP THE WASTE in COID and incentivize the reallocation of water to actual AGRICULTURAL PATRONS for ACTUAL beneficial use, as the Doctrine of Prior Appropriation originally intended..
The Doctrine of Prior Appropriation states that water rights are determined by priority of beneficial use. This means that the first person to use water or divert water for a beneficial use or purpose can acquire individual rights to the water.
When the Central Oregon Irrigation District was formed in 1900, this region was an agricultural region. This is no longer the case by and large. There are some farms that still qualify as Agricultural Producers, but a majority of the patrons in this district are NOT AGRICULTURAL PATRONS.
By definition: Agriculture: practice of farming, including cultivation of the soil for the growing of crops and the rearing of animals to provide food, wool, and other products.
Some facts regarding COID parcels and patrons from Central Oregon Landwatch:
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50% of COID patrons irrigate 3 acres or less. These are hobby farms.
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80% of COID acreage is in parcels of 10 acres or less.
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Average farm loses $13,000 a year In Deschutes County
I understand there are some larger farms and ranches in this district who qualify as agricultural producers, whose livelihoods are directly connected to the cultivation of the land in growing crops and raising animals to produce food, wool and other agricultural products. These patrons should be allotted their full water rights.
The future of water in our arid region requires we take a hard look at how and where our precious resources are being used. It is clear when looking at water usage in COID, much of the irrigation district does not qualify as AGRICULTURAL PRODUCERS.
Now let’s look at the facts regarding the QUANTITY OF WATER being used by a district largely made up of non-agricultural producing patrons, versus the largest agricultural producing district, NUID.
From Central Oregon Landwatch:
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COID uses 116,000 Acre Feet more of water to irrigate 14,000 fewer acres than NUID.
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COID is 80% parcels of 10 acres or less, 50% are 3 acres or less. Average “farm” in Deschutes county loses $13,000 a year.
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These are broadly speaking, NOT AGRICULTURAL PRODUCERS using water appropriated by the Doctrine of Prior Appropriation, which upon creation was intended to appropriate water by priority of BENEFICIAL USE.
COID uses 116,000 acre feet MORE WATER to irrigate 14,000 FEWER ACRES than NUID
We understand much of this WASTE is created because of the “Use it or Lose it” laws which require patrons to use their allotted water, or risk losing their water rights, which then decreases the value of the patron’s property. We understand this because we once leased and farmed land on a parcel in which we watched the property owners reluctantly water sections on their property which had basically become an equipment yard/ parking lot. At the end of the season, they were told they would fly over the parcel and if that area was not greened up from irrigation, they would lose that section of irrigation rights. So all season, they uselessly irrigated precious water, to make a useless parcel green, to satisfy a bureaucratic demand. Waste.
Again, I understand the Service can not change our outdated and waste-inducing water laws, I hope the future of Oregon Water Law addresses these issues, but the drafted HCP does not adequately address the mechanisms of Market Incentives which could reduce this waste, and really INCENTIVIZE real estate owners who care about their property value to trade/ lease their irrigation rights to ACTUAL AGRICULTURAL PRODUCERS WHOSE LIVELIHOODS DEPEND ON IRRIGATION WATER. I understand there exists an Instream Lease Program, but this program has no real economic incentives for patrons to partake in it. Thus, needless watering continues at a massive scale.
On page 3-12 of the draft DBHCP incentives are mentioned, but they are not actually any different than the current Instream Lease Program “incentives” that currently exist and don’t actually incentivize patrons much at all.
“ Creating incentives for landowners to voluntarily reduce demand for water. These incentives can include
- facilitating temporary instream water right transfers under State water law that allow individual landowners to forgo irrigation up to 5 years, with the option of renewal, without risk of forfeiture of the right;
-providing funding and/or technical expertise for landowner system improvements such as piping of ditches and conversion to high-efficiency delivery systems.”
According to the Technical Memorandum prepared by Summit Conservation Strategies in 2017
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Market-based approaches have the potential to provide water supply to meet Basin needs.
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The quantity of water available through these approaches is substantial relative to total Basin needs; depending on the assumptions made, market-based reallocation could meet on the order of 50% or more of supply requirements. By the same token, market-based approaches alone are unlikely to completely meet Basin needs.
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Policy barriers would need to be addressed prior to implementation of some of the market-based approaches identified; other approaches could be implemented immediately.
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Much of the potential water supply identified could be available at relatively low cost; despite the intrinsic uncertainty in this analysis, the conclusion that market-based approaches provide large volumes of cost-competitive water is evident. Market-based approaches and voluntary economic tools offer a source of significant, low cost water supply that merits inclusion in Basin Study water resource scenarios.
Lastly and most importantly, what the draft HCP does not address adequately, is the impact this proposal will have on already vulnerable, rural communities in Central Oregon.
Agriculture is the predominant source of income for Jefferson County, with farmers growing food, vegetable seed, garlic, potatoes and feed on over 60,000 acres of irrigated land. According to Oregon State University, approximately 55% of the US domestic market carrot seed production is grown in Jefferson County, and 45% of the Global market carrot seed coming from Jefferson County.
As the most junior water rights holders according to the Doctrine of Prior Appropriation, NUID and Jefferson County is the first district to experience irrigation water allotment cuts as drought and climatic changes require less water to be used in all of Central Oregon. For rural communities in Jefferson County in which agriculture is the predominant source of income, the loss of irrigation water leave already vulnerable demographics of people even more vulnerable.
Population and Poverty Statistics via the United States Census Bureau 2017:
Deschutes County
Person’s in Poverty Rate: 9.7%
10% Latino/ Native American/ African American population
Jefferson County:
Persons in Povery Rate: 17.2%
43% Latino/ Native American/ African American population
COID’s conservation focus is on piping projects, which will take decades to get done. In those decades, a massive amount of waste will continue to deplete the river, endanger the species of concern, and threaten the livelihoods of rural communities who actually depend on irrigation water. The next draft of the HCP must address in detail how COID will address the massive waste of irrigation water in it’s district to non-beneficial uses, and how COID will incentivize non-agricultural patrons to actually take advantage of the Instream Lease Program. Though this program touts no added fees for patrons to take advantage of this program, unfortunately that is not enough. We must economically incentivize people to lease all or portions of their water allotment back to the river, or downstream to agricultural producers in other districts struggling to get by on reduced allotments.
It is clear to see that when districts and patrons face allotment cutbacks and pressure, conservation measures are taken swiftly and seriously. NUID’s pumpback systems, investments in more efficient irrigation systems, and metered water ordering systems allows our farms to irrigate a much larger amount of land with much less water than other irrigation districts. Some irrigation districts operate on up to 6 acre feet allotments, while our farm as NUID patrons operates on a normal year with 2.5 acre feet allotments. This year due to cutbacks, our farm is irrigating with 1.67 acre feet. With actual pressure to enact conservation measures and improved irrigation systems, there is no reason districts should need upwards of 6 acre feet allotments.
Unfortunately with our Senior/ Junior water rights systems this means there is very little pressure on Senior rights holders to take conservation measures seriously. Because they have first right and there are no MARKET INCENTIVES to redirect water to actual BENEFICIAL USES down the line, gluttony ensues, and this waste endangers vulnerable animal and human populations/communities.
I believe that if ALL irrigation districts were pressured to enact conservation measures seriously the way NUID has, there would be enough CFS flows in the river to allow for proper habitat for species, and there would be adequate water for agricultural patrons using water for beneficial uses. While piping projects are underway over the next decade, we must stop the waste and reallocate water with common sense NOW.
The HCP requires a more in depth proposal of conservation/ market incentive measures that can be enacted NOW, allowing adequate water allotment to patrons qualified under the Doctrine of Prior Appropriation as beneficial users of our irrigation resources. Furthermore, it must address these needs in regards to the vulnerable human communities along with the vulnerable animal species which are threatened by the status quo waste mentality that has predominated water in the Deschutes Basin for decades.
Please submit your written comments by 11:59 p.m. EST on December 3, 2019.
ADDRESSES:
Document availability: To view the DEIS and HCP, go to http://www.regulations.gov and search for Docket No. FWS-R1-ES-2019-0091.
Submitting comments: You may submit comments by one of the following methods. If you have already submitted a comment, you need not resubmit it.
Online: You may submit comments online at http://www.regulations.gov/ in Docket No. FWS-Rl-ES-2019-0091.
Hard copy: Submit comments by U.S. mail or hand delivery to Public Comments Processing, Attn: Docket No. FWS-Rl-ES-2019-0091;
U.S. Fish and Wildlife Service; 5275 Leesburg Pike, MS: JAO/lN; Falls
Church, VA 22041-3803.
FOR FURTHER INFORMATION CONTACT: Bridget Moran, by telephone at 541-
383-7146, or by email at bridget_moran@fws.gov. Hearing or speech
impaired individuals may call the Federal Relay Service at 800-877-8339
for TTY assistance.
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