Comments and Letters

Crown Columbia Water Resources

Columbia River flowing through the photo with blue sky and clouds.
Columbia River near Vantage by Kayla Magers

CELP wrote a letter to the Washington Department of Ecology with concerns over Crown Columbia Water Resources, LLC (“Crown”)’s unprecedented application (No. S4-33625) for a water right that appears to be intended to allow new diversions of water almost anywhere in the Columbia Basin. An area-wide permit of this type has, to CELP’s knowledge, never been approved or implemented in Washington. It would be an entirely new type of water appropriation program and raises serious legal and policy questions. We believe that approving such a permit would be unlawful, and have grave concerns about the process that is being followed.

Read our full letter here.

Nooksack River Adjudication

Nooksack River by Elan Ebeling

CELP wrote a letter to the Washington Department of Ecology urging them to select the Nooksack River for the next basin to be adjudicated.

“CELP strongly urges Ecology to select the Nooksack River basin (WRIA 1) as the next Washington
basin to be adjudicated. The Nooksack is an important river system that supports native runs of wild chum, chinook, coho, and pink salmon, as well as other salmonids including bull trout and steelhead. The Tribes with reserved fishing rights in WRIA 1 (the Lummi Nation and Nooksack Indian Tribe) have requested action by the Federal Government to judicially determine their reserved water rights, including water for instream flows to protect their rights to fish and in turn the habitat on which those rights depend.”

Read our full letter to Ecology here.

We are also lobbying for funding to start the adjudication process in support of the Governor’s proposed operating budget.

Chehalis River Basin Flood Damage Reduction Project May 2020

Chehalis River. Proposed Dam Site. Photo by Shane Anderson

CELP provided comments on the Chehalis River Basin Flood Damage Reduction Project Draft Environmental Impact Statement (DEIS) in opposition to the proposed dam.

“Building any dam would make no practical, environmental, or economic sense, and would violate Washington’s legal obligations under treaties with Indian nations, which have the status of federal law, and the Endangered Species Act. Instead, the state should foster wetland restoration and other resilient designs to make the floodplain safer for people. “

Read our full comments here.

Other Comments and letters over the years

Comments on the Department of Ecology’s June 2018 Draft Final Guidance for Determining Net Ecological Benefit (NEB). The Center for Environmental Law and Policy (CELP) and the Deschutes Estuary Restoration Team
(DERT). June 8, 2019. /wp-content/uploads/Comments-on-Draft-Final-NEB-Guidance.pdf

Comment on Okanogan County Ordinance 2016-5, concerning
determinations of water availability with respect to building permit applications.
December 19, 2016. /wp-content/uploads/CELP-Comments-on-Okanogan-County-Ordinance-No.-2016-5.pdf

Comments on the draft Report entitled “Mitigation Options for the Impacts of New Permit-Exempt Groundwater Withdrawals (“Report”). November 20, 2015. /wp-content/uploads/CELP-comments-Ecology-Draft-Mitigation-Alternatives-Report.pdf

Comments on the draft reclaimed water rule, proposed chapter 173-219 WAC. September 20, 2015. /wp-content/uploads/Reclaimed-water-rule-comments-FINAL.pdf

CELP Rural Water Supply Guidance Document Comments. March 31, 2015. /wp-content/uploads/CELP-Comments-on-Rural-Water-Supply-Report-3-31-15-FINAL-w-attachment.pdf

Comments regarding the City of Spokane’s proposed applications to add a point of withdrawal to two existing water rights. January 22, 2015. /wp-content/uploads/CELP-comments-on-draft-City-of-Spokane-ROEs-1-22-15.pdf

Comments on the City of Walla Walla draft Report of Examination (ROE). October 4, 2014. /wp-content/uploads/CELP-Comments-on-Walla-Walla-ASR-ROE-10-4-14.pdf

Comment on Okanogan County’s update of the 2009 Environmental Impact Statement: Addendum A: Revisions to the Okanogan County Comprehensive Plan. April 8, 2011. /wp-content/uploads/CELP-Comments-on-Okanogan-County-SEPA-4-8-11-FINAL-1.pdf

Comments on draft WAC Ch. 173-517, the Qulicene-Snow WRIA rule. July 10, 2009. /wp-content/uploads/Quilcene-Snow-draft-rule-comments-7-10-09-FINAL.pdf

Comments for the Odessa Subarea Study feasibility study and environmental impact statement. September 19, 2008./wp-content/uploads/CELP-Scoping-Comments-9-19-08.pdf

Comment on the preview of USBR’s appraisal study of providing new surface water supply to the Odessa Subarea. December 15, 2007. /wp-content/uploads/CELP-Comments-on-Odessa-Appraisal-12-15-07.pdf

Wenatchee Watershed Rule Comments. August 23, 2007. /wp-content/uploads/Wenatchee-Comments-8-23-07.pdf

Comments on the draft amendments to the Walla Walla basin rule, WAC Ch. 173-532. These comments are submitted by the Center for Environmental Law & Policy, Public Employees for Environmental Responsibility, and WaterWatch of Oregon. March 23, 2007. /wp-content/uploads/CELP-Comments-on-draft-WW-rule-3-23-07-Final-Corrected.pdf

Comments on the Supplemental Environmental Impact Statement for the latest proposal to mine gold from Buckhorn Mountain in northeastern Okanogan County, Washington. December 14, 2005. /wp-content/uploads/CELP-CommentsDraftSEIS-12-14-2005.pdf