The Deschutes Basin Board of Control (DBBC) has prepared a document addressing recent statements and questions related to the Habitat Conservation Plan and other conservation initiatives.
STATEMENT
Some have alleged that irrigators want the public to be distracted by what they term a false dichotomy of "frogs versus farmers," when instead, in their view, the "real" choice is a healthy river system and efficient irrigators versus waste. This point of view relies on the asserted premise that there is currently enough water in the system to take care of the needs of both the species and “efficient irrigators” if Central Oregon Irrigation District (COID) would just stop wasting water and allow water sharing.
RESPONSE
The premise for this viewpoint is seriously flawed. First, it assumes that COID patrons are wasting water. This is false. While the technology around water use will always improve over time, just because a landowner has not purchased and implemented the latest state-of-the-art technology, it doesn't mean that they are wasting water. They're still putting water to beneficial use, just as they've done for the last 100 years.
Second, the viewpoint is flawed because it assumes COID is responsible for its patrons' water use efficiency, and that COID can somehow force its patrons to become more efficient. State law doesn't give irrigation districts the authority to do this. At the same time, however, state law does enable COID to make its overall delivery system more efficient.
Third, the viewpoint is flawed because it assumes there is currently enough water in the system for COID, North Unit Irrigation District (NUID), and fish and wildlife. There's simply not, without large scale piping projects by the districts, which can be combined with voluntary efforts by landowners who undertake on-farm improvements.
And finally, the viewpoint incorrectly assumes COID is not allowing sharing. That's also false. COID currently delivers an average of 20 cubic feet per second (cfs) of water (conserved by COID through previous piping projects) through the Pilot Butte Canal and to the North Unit Main Canal.
COID is currently working with the Deschutes River Conservancy, Summit Conservation, and AMP Insights on a water marketing program. The pilot project would allow water right sharing between water users. The goal of the pilot project is an additional 5 cfs during the 2020 irrigation season, with a total goal of delivering 50 cfs through water sharing and on-farm programs. The program, which is expected to launch in 2020, is being funded through a U.S. Bureau of Reclamation WaterSmart grant.
STATEMENT
Critics allege the irrigation district conservation plans are flawed in relying on “expensive big piping” to reduce water use when “far cheaper approaches” are available such as piping private ditches, eliminating flood irrigation, and offering incentives to use less water.
RESPONSE
The districts are employing a variety of conservation tools including:
Transfers: Permanent transfers of water rights off the land generate improved water supply for farmers, cities, and the Deschutes River.
Leases: Temporary transfers (usually one year) of water rights off the land generate improved water supply for farmers, cities, and the Deschutes River.
Sharing: Water agreements between districts facilitate water conservation measures and improve reliability.
Piping: Piping outdated canals, which can leak up to 50% of their water during transmission, allows landowners and the Deschutes River to capture an abundance of water.
Reservoir Management: Better allocation of stored water addresses district water supply and streamflow needs.
On-farm Improvements: Districts are working with landowners to implement voluntary conservation measures.
The districts are focused on updating the antiquated irrigation infrastructure in a way that does the most good for farmers, the community, and the environment. Many of the districts are stuck with wildly inefficient systems that were built over 100 years ago. Due to their design, it’s estimated that up to 50% of all irrigation water in unimproved systems is lost before it ever makes it to the farm. By replacing leaky, open canals with closed pipes, districts can help farmers do much more with less. Water saved from seepage below and evaporation above can now go to the farm or stay in the river to help support wildlife conservation, while the gravity-pressured water eliminates the need for farmers to maintain costly pumps in many situations.
In 2017, COID completed a thorough analysis of on-farm as well as private lateral water loss inefficiencies. The study showed that with a substantial investment, there is certainly the potential for significant water savings from on-farm improvements.
At the same time, the cost to convert COID-owned canals to fully pressurized systems costs about the same as converting less-efficient farming practices, but would save almost twice the water lost to seepage.
In order to achieve the on-farm efficiencies with the current canal system, farmers currently using flood irrigation would need to buy irrigation systems, install electricity, and pay energy costs. It is important to note on-farm improvements are voluntarily conservation measures by landowners and not something the districts can control or mandate.
As an example, once COID is piped and pressurized, the cost to farmers converting from flood irrigation to more efficient irrigation practices will decrease by 50%. When pressurized service is available, farmers will have a strong incentive to convert less-efficient systems and pipe private lateral lines to maximize the benefits of efficient water deliveries.
STATEMENT
It has been suggested by some that the irrigation districts aren’t working together to encourage conservation.
RESPONSE
The districts are partnering together using a collaborative, scalable, and thoughtful approach to conservation. The districts are working together and have been successful in securing large-scale investments needed to make a difference. The districts are committed to ensuring the improvements benefit everyone, including rivers, fish, and frogs.
On December 7, 2017, COID and NUID entered into a water sharing agreement. The agreement outlines the districts’ commitment to incorporate all the tools at their disposal to share water, allowing NUID to leave more water in the river during the winter.
COID’s conservation measures will generate a more reliable water supply for NUID. NUID will then be able to make water available from its storage in Wickiup Reservoir to increase winter flows in the Upper Deschutes River.
It’s important to note that district improvements and conservation measures would not be progressing as efficiently nor as quickly without the committed cooperation of multiple public and private entities.
STATEMENT
It has been suggested that family farmers of NUID should be prioritized to receive irrigation over COID landowners due to the assumption that COID landowners don’t utilize the water in a productive fashion.
RESPONSE
When it comes to water use, Oregon state law does not favor certain crops over others or favor a particular kind of farming operation over another. State law also does not dictate that a water user must generate a certain amount of income from his or her water use.
Whether a landowner is growing industrial hemp, carrot seed, or a hay crop, so long as irrigation water is used to grow a crop, the districts do not have the legal authority to make value judgments around whether the use of water by particular landowners are sufficiently productive.
This is not an issue for the districts or critics to decide. This is also why incentive-based programs are important, as these programs can help to encourage users to make choices in favor of conservation.
STATEMENT
There is confusion regarding COID’s instream lease program, with some commenting that COID doesn’t allow its patrons to lease water to instream use for the benefit of the Deschutes River.
RESPONSE
COID’s robust instream leasing program allows patrons to lease all or a portion of the water right appurtenant to their land, in lieu of irrigating, for a one or three-year period. Instream leases are a critical component of the district's water marketing program. On occasion, a request to lease may be denied for operational reasons or if a water right does not meet the Oregon Water Resource Department’s leasing criteria. Learn more about instream leasing: https://www.oregon.gov/OWRD/programs/WaterRights/IS/IL/Pages/default.aspx
STATEMENT
Some have alleged the DBBC’s approach set forth in the proposed Deschutes Basin Habitat Conservation Plan (HCP) is misplaced, by failing to create stronger incentives for the conservation of on-farm water.
RESPONSE
The HCP is a voluntary, applicant-driven process to allow the irrigation districts in the Deschutes Basin to continue their otherwise legal operations in light of Endangered Species Act (ESA) listed species located in the vicinity of the districts’ delivery systems. It’s the districts’ responsibility, in coordination with the U.S. Fish and Wildlife Service and the National Marine Fisheries Service, to determine how to meet the needs of the ESA listed species in light of the districts’ legal obligations to deliver water to their patrons. The HCP is not intended to be a tool to fix the entire Deschutes River system. Rather, it is a mitigation plan to allow the districts to continue their operations and is simply one tool in a multi-tool toolbox. The districts’ HCP in no way prevents others from addressing their own ESA liabilities, or from developing other means for making improvements to the river system.
STATEMENT
It has been alleged that COID’s primary objective for piping canals is to generate revenue with hydroelectric projects. There is a belief that such hydroelectric projects create a disincentive for on-farm water conservation because more water saved means diminished hydropower revenues.
RESPONSE
COID is not planning to construct new hydroelectric project facilities at this time. In 2019, COID’s board of directors voted that providing pressurized water to COID’s patrons is a key priority. This decision lessens COID’s hydropower opportunities.
In the current 30% design for COID’s delivery system improvements, there are four areas that will need to have pressure reducing valves. These areas could be replaced with hydroelectric project facilities; however, COID is not pursuing hydropower at this time due to a lack of viable contracts for the sale of the power that could be generated.
STATEMENT
Critics are alleging the proposed HCP stream flows in the Deschutes River and its tributaries are not adequate for the protected species.
RESPONSE
While the HCP targets are set at specific flow levels to be achieved at specific intervals, the districts will be putting water into the Deschutes River as soon as their piping projects are completed. For example, the Smith Rock King Way project on the Pilot Butte Canal will conserve 30 cfs. Upon completion of the project, COID and NUID will increase instream flows accordingly.
STATEMENT
Some have asserted that the HCP is flawed because it doesn’t show “how” river flows will be provided. Underlying this assertion is a concern that COID is not adequately participating in efforts to increase instream flows for fish and frogs to those specific levels that will be required if the proposed HCP is approved.
RESPONSE
COID has agreed to share in the obligations imposed by the HCP on all of the districts, by agreeing to implement conservation projects and pursue various water marketing opportunities. This is clearly stated in the District to District agreement signed in 2017 by COID and NUID. Meanwhile, the HCP itself is not intended to be a prescriptive agreement. To meet the goals and objectives set forth in the HCP, the districts will work together to conserve and manage flows for the benefit of the entire community.
STATEMENT
Some have claimed the proposed HCP would excuse the districts from having to make adjustments to the use of river water, beyond those in their plan, for the benefit of ESA listed species for 30 years, even if climate change impacts during that time period further imperil the survival of the species.
RESPONSE
The HCP does not “excuse” the districts from future adjustments, as the HCP contains elements to address both climate change and “changed circumstances.”