Central Oregon Irrigation District is currently planning to pipe significant portions of their Pilot Butte Main Canal.  The cost for piping 18.5 miles of this canal is estimated to be $356M, mostly funded by taxpayers via federal and state sources.  Approximately 43,544 acre feet per year (136 cfs) of water will be conserved by this project.  I have long been a critic of these astronomically expensive taxpayer funded projects when far less costly methods of saving water have been identified, especially when the benefits mostly go to hobby farmers who are not providing commensurate economic benefit for the use of publicly owned water.  Nevertheless, I see the rationale for piping canals and reluctantly support them if the water savings are returned to the Deschutes River.  Today, however, that is not guaranteed.

Canal piping projects go through many approval steps, including an Environmental Impact Statement.  Unfortunately, the EIS for the Pilot Butte Canal does not explicitly guarantee returning conversed water to the Deschutes.  You can find the EIS and supporting documents here.

The Deschutes Basin Board of Control, which covers all irrigation districts in Central Oregon (Deschutes, Crook, and Jefferson counties), along with the City of Prineville, has an approved Deschutes Basin Habitat Conservation Plan which includes a requirement to increase winter flows in the Upper Deschutes. The plan is to send water saved from canal piping to North Unit Irrigation District during irrigation season in exchange for NUID releasing water from Wickiup Reservoir in the winter to meet DBHCP flow targets.  The EIS does state that savings from piping the Pilot Butte Main Canal will be used to meet DBHCP flow requirements.

Here’s the problem: the federal government is undergoing radical transformation. Departments are being dismantled, protections for roadless areas are being rescinded, public lands are slated to be sold, environmental regulations are being gutted, etc. It’s not irrational to consider the possibility that the DBHCP is not enforced or even that the Endangered Species Act, the reason the DBHCP was written, is eliminated.  Crazy things are happening these days. Add on to that, the DBHCP expires at the end of 2050. At that time NUID could stop releasing water from Wickiup in the winter, use that water for irrigation in the summer and have the water from the canal piping project.

I believe that in exchange for hundreds of millions of taxpayer dollars the EIS should explicitly state that 100% of all conserved water will be permanently restored to the Deschutes River.  That would guarantee public benefit for public money. This could easily be done with a few sentences in the EIS. Remember that in 2023 NUID received funding for a canal piping project where they planned to return no water at all to the Deschutes but were forced to agree to return only 25% of saved water after significant public opposition.

You can submit your comments on the EIS by sending an email to coid.eis.comment@gmail.com before March 31. Below are my submitted comments.

While the draft Pilot Butte Main Canal Environmental Impact Statement details plans to use water conserved by the piping project to return water to the Upper Deschutes River to meet Deschutes Basin Habitat Conservation Plan requirements to increase winter flows, there is no explicit guarantee to do so. In exchange for the considerable amount of taxpayer funding for this project, Central Oregon Irrigation District and North Unit Irrigation District must make a legally binding commitment to permanently return 100% of all conserved water to the Deschutes River. This binding commitment should apply regardless of future enforcement of the requirements of the DBHCP and continue past the expiration of the DBHCP at the end of 2050.