Dear Water Resources Commission:
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Please approve the rulemaking petition to close critical groundwater areas near Boardman to new unpermitted stockwatering uses of more than 5,000 gallons of water per day.
The permitting exemption for stockwatering might have made sense when the law was adopted in 1955, and when livestock operations were mostly small and dispersed, but the water demands of stockwatering on today’s factory farms are far more than incidental. This is particularly true in the Umatilla Basin near Boardman, which already has 80,000 cows on industrial-scale dairies, and where a new dairy of about 30,000 cows is planned. Large livestock operations should not be allowed to take unlimited amounts of water from already overstressed aquifers without the reviews associated with new permits or transfers of existing water rights. The proposed limit of 5,000 gallons per day is reasonable because it is the same as the limit on commercial and industrial use without a permit.
Thank you for considering my comments.