OFC Submits Public Comment Opposing Removal of Murphy Dam

TO: Oregon Department of Environmental Quality
FROM: Nick Stark, CEO, Oregon Freedom Coalition
SUBJECT: Opposition to the Removal of Murphy Dam

Oregon Freedom Coalition, a 501(c)(4) nonprofit dedicated to promoting accountability and affordability in Oregon, opposes the issuance of a permit for the removal of Murphy Dam on the grounds that its removal would bring environmental and economic harm to Josephine County. The Oregon Department of Environmental Quality (DEQ) should deny the NPDES General Permit 1200-C application of WaterWatch of Oregon (102523).

First, the removal of Murphy Dam would lead to contamination of the Applegate River, potentially violating the Clean Water Act (CWA). It is unclear whether applicants have received or plan to receive permission from the U.S. Environmental Protection Agency (EPA), the federal agency overseeing contaminate discharges, to conduct such an operation. Approval of such an application from DEQ before EPA gives approval could result in liability for applicants and the State of Oregon for any violation of the CWA.

Second, Murphy Dam creates a key water drawing spot for air crews fighting wildfires in the area. Multiple fires threatening Oregonians in the Wildland-Urban Interface have occurred in the nearby forests over the last decade alone. In 2025, water drawn from Murphy Dam was used in the efforts to contain the Board Shanty Fire which burned over 400 acres mere miles from the dam. Removal of Murphy Dam would remove a key tool in fighting local wildfires.

Third, Murphy Dam is a seasonal dam, and thus does not inhibit the migration of Coho Salmon. Murphy Dam is closed June through October, while Coho Salmon migration occurs in the later part of October through November. Furthermore, Murphy Dam has an adequate fish ladder to assist in migration during any seasonal overlap that may occur. The threat from Murphy Dam to these fish is not large enough to justify its removal, especially given the environmental impacts previously listed and the economic impacts next listed of its removal.

Fourth, removing Murphy Dam would cause irreparable economic harm to Josephine County. Currently, 35 farms benefit from the low-cost irrigation provided by Murphy Dam. Its removal would drastically reduce the amount of water they could draw, and any pumping system built as an alternative would have higher associated costs borne by these farms and, ultimately, the consumers to whom they sell their products.

Finally, the cost of removing Murphy Dam to taxpayers would be tremendously high. Current estimates indicate $4 million in taxpayer dollars would be spent on removal. There is no discernible payoff to Josephine County or Oregon taxpayers that comes from the removal. In fact, as listed above, the impacts to taxpayers are more environmental and economic damages.

It is clear that the removal of Murphy Dam would have devastating impacts both environmentally and economically for Josephine County. On these grounds, the Oregon Department of Environmental Quality (DEQ) should deny the NPDES General Permit 1200-C application of WaterWatch of Oregon (102523).