4.1 City’s Impact on Tumalo Creek
Mr. Hickmann goes on to discuss the impact of the City’s diversion on Tumalo Creek, as follows:
The hydroelectric facility, if built, would not take additional water from Tumalo Creek. The facility would generate renewable energy from water that the City uses to meet municipal water demand {A-17, B-7}
Comment: The statement by Mr. Hickmann is misleading. As confirmed in part 1, the SWIP (including the hydropower facility) will take additional water from Tumalo Creek, particularly in the winter months. Median stream flow in the creek during winter months is in the mid-60s (cfs). According to its projections, the City will be diverting 21 cfs or fully one-third of the water in the creek by 2030. Measured at the location where the City currently returns unwanted flow from its pipes to Tumalo Creek (near Outback), the SWIP will increase the City’s current take of water during the winter months from 8.5 cfs (5.5 mgd) to 21 cfs or a 150% increase over current diversions. The City has carefully avoided drawing public attention to this awkward consequence of their plans, nor accounted for the environmental impacts of these additional diversions in any of their documentation about the project.
Mr. Hickman goes on to try and make the case that the SWIP should be evaluated only on the basis of the increase in diversion:
With the new system, the City will only divert more than 18.2 cfs (current allowed diversion) when there is a municipal demand for it, and the water is available. Availability is based on water rights and available flow. So, the net increase of withdrawal of water from Tumalo Creek (when the water is available and City demand would require it) is 21.0-18.2 = 2.8 cfs. This is a maximum increase of 15 percent. {A-17, B-7}
Comment. This is inconsistent with Mr. Hickmann’s statement that no “additional” water is to be diverted.
The main point here however is that Mr. Hickmann seems concerned only with the increase in water use and thereby misses the obvious point that under a well only water supply system the City would divert 0 (zero) water from Tumalo Creek. Because the SWIP involves fully rebuilding the City’s pipes that bring the water into town the SWIP should be (and was) compared to other alternatives that do not involve rebuilding the City’s surface water diversion and conveyance system. The “with and without” SWIP comparison then would be between 21 cfs in diversions and 0 cfs of water diverted. Mr. Hickmann seems unaware of common practice and methods in project analysis, in particular how to structure an alternatives analysis and evaluation their impacts on water resources.
4.2 Restoration of Tumalo Creek flows
With respect to Tumalo Creek flows Mr. Hickmann recognizes the stream flow issue with the following statement:
Tumalo Irrigation District, who owns large senior water rights on Tumalo Creek, have identified over 30,000 acre feet of losses and are actively conserving the 50 percent leakage within their canal system. Additional options exist to prioritize flows that meet all the needs of fish, farms, and people and the City of
Bend is actively working with all basin groups to achieve these goals. {A-15}
Comment. Once again, the City has put forward an argument that lacks credible objective support.
An informative response to recent inquiries on this issue was received from the Deschutes River Conservancy. This was summarized in detail for Trout Unlimited and StoptheDrain (click here to download). The City argues that in stream flows are best met through programs based on Tumalo Irrigation District conservation programs. However to complete proposed TID conservation plans major public financing will be required, and unfortunately the resultant flow restoration will still fall far short of the Oregon Fish and Wildlife flow goal of in-stream rights of 32 cfs. “All the needs of fish…” will not be met under the City’s proposal.
