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HomeMy WebLinkAbout05_BSP_Water_Rights Irrigation Change Application No. 41H 30103245 Technical Report Page 1 of 7 Irrigation Change Application Technical Report Technical Report Compiled by: Brent Zundel, Water Resource Specialist Date: February 5, 2016 This Technical Report IS: A collection of facts that the DNRC has gathered independent of what was provided in the application materials. These data will be used later in the process to analyze the criteria. This Technical Report IS NOT: An analysis or discussion of whether the application meets the criteria (85-2-402, MCA). Application Information: Applicant name: Norton Properties LLC, Norton Ranch Homes LLC, and J&D Family LP Consultant name: DMS Natural Resources LLC Application number: 41H 30103245 Source: West Gallatin River Water right numbers proposed for change: TABLE 1: Summary of Water Rights Proposed for Change Water Right Number (Basin 41H) Purpose Flow Rate (GPM) Period of Use Point of Diversion1 Place of Use Priority Date Acres 30023118 Irrigation 372.5 6/1 – 10/31 SWNWNW, Sec. 11, T03 S, R04 E E½SW, W½SE, SENW, & SWNE, Sec. 9, T02 S, R05 E 10/15/1866 237.27 30023119 Irrigation 168.75 6/1 – 10/31 6/15/1881 237.27 30023120 Irrigation 561 5/1 – 10/1 6/1/1867 237.27 NOTES: 1Farmer’s Canal headgate. Change description: This application proposes to change the place of use (POU) of irrigation water that was historically used on 112.2 acres of the Norton Ranch in Section 9, T02 S, R05 E, Gallatin County, just west of Bozeman. It also seeks to add a place of storage. Water was historically diverted from the West Gallatin River into the Famer’s Canal and thence into the E. Minder Lateral before being applied to the POU. This application would change the POU to the City of Bozeman Sports Complex off Flanders Mill Road and add an irrigation reservoir. Water would be conveyed through Farmer’s Canal, thence into the Maynard Border Ditch, and finally applied to the new POU. Other: The remaining 26.4 acres under the subject water rights are being retired out of irrigation to provide mitigation for municipal use for a Big Sky-area development in Application to Change an Existing Irrigation Water Right No. 41H 30102910 (Norton-Bostwick). That mitigation plan has already been approved as part of permit 41H 30025398 by Bostwick Properties Inc. Irrigation Change Application No. 41H 30103245 Technical Report Page 2 of 7 Information that will be used for criteria analysis: Historic Use (ARM 36.12.1902) DNRC employee who compiled this section: Brent Zundel, Water Resource Specialist Water right numbers: 41H 30023118, 41H 30023119, and 41H 30023120 Supplemental water rights: 41H 30023118, 41H 30023119, and 41H 30023120 are supplemental because they share the same point of diversion, purpose, and POU. Also supplemental are groundwater claims 41H 138898-00, 138899, 138902, and 138903, which are for irrigation from waste and seepage water, because their claimed POU overlaps with the POU of the subject water rights. However, the groundwater claims are not included in this change because the Applicant’s historic use description shows that the POU of these four groundwater rights doesn’t overlap with the three subject water rights. Water Resources Survey acres found: 240 Note: The Gallatin County Water Resources Survey indicates that all of the pre-1973 POU was irrigated by water from Farmer’s Canal and from private irrigation. USDA Photo 179-270R, dated 1979, maximum acres found: 240 NAPP-8376 Photo 066, dated 8-1995, maximum acres found: 240 Photo 2005 NAIP, dated 2005, maximum acres found: 240 Maximum historic acres for this water right: 138.63 Note: 237.27 acres were defined by the Water Court during the 2015 split. The Applicant further clarifies in this application that 138.63 acres have been irrigated since completion of Change Authorization 42H 929502 in 1988. Maximum historic flow rate for water rights: 1,102.25 GPM. The pump capacity at the field as of 1988 was 800 GPM. The pump was capable of delivering some water from all three rights: 41H 30023118, 41H 30023119, and 41H 30023120. A loss of 302.25 GPM between the headgate and the field (8.6 miles) is reasonable. Ditch loss is shared among many users. TABLE 2: Historic Flow Rates Water Right Number ( - ) Flow Rate (GPM) 41H 30023118 372.5 41H 30023119 168.75 41H 30023120 561 TOTAL = 1,102.25 Historic consumptive use (volume) for all three water rights: 204.78 AF. All three water rights were used on the same 138.63 acres and all priority dates are of sufficient seniority such that none have been subject to call. Farmer’s Canal shares were used in the early season to provide conveyance water. Therefore, all of the consumptive use can be attributed to the three water rights proposed for change. Historic consumptive use is calculated as follows: Crop Consumptive Use Bozeman Experiment Farm weather station Irrigation Water Requirements (IWR) for alfalfa = 16.84 inches (in) Gallatin County Management Factor (1973 – 2006 MF for post-1988 change conditions) = 92.1% 16.84 in / 12 in per ft * 0.921 = 1.292 ft per acre 1.292 ft per acre * 138.63 acres = 179.18 AF Water Applied to Field 70% efficiency for sprinkler systems Water applied to field = consumptive use / 70% efficiency = 179.18 AF / 0.70 = 255.96 AF Irrigation Change Application No. 41H 30103245 Technical Report Page 3 of 7 Irrecoverable Losses 10% loss for sprinkler systems Irrecoverable loss = water applied to field * irrecoverable loss percent = 255.96 AF *0.10 = 25.60 AF Total Historic Consumptive Volume on 138.63 acres Total historic consumptive volume = crop consumptive use + irrecoverable loss = 179.18 AF + 25.60 AF = 204.78 AF Table 3 below specifies the consumptive volume associated with each right according to the right’s flow rate proportional to the total flow rate. TABLE 3: Consumptive Volume Water Right Number ( - ) Percent of Total Flow (%) Consumptive Volume (AF) 41H 30023118 33.8 69.22 41H 30023119 15.3 31.33 41H 30023120 50.9 104.23 TOTAL = 100 204.78 Historic diverted volume for all three water rights: 444.50 AF. The Applicant provided diverted volume calculations as Exhibit 10 of the application. The Applicant calculated diverted volume from the following three components: (1) conveyance losses over the 72-day irrigation period, (2) excess water spilled to Aajker Creek, and (3) the volume applied to the field (255.96 AF). Conveyance losses were calculated for two 36-day periods: an early season when all rights, including Farmer’s Canal rights, are in priority (June – July 17) and a late season (July 18 – October) when only the Applicant’s rights remain in priority and they have ceased using Farmer’s shares. Conveyance losses in the Farmer’s Canal and the E. Minder lateral were attributed to the subject water rights in proportion to the other rights and shares in the ditch. Conveyance losses were calculated according to the Department’s 2012 historic diverted volume memo. A general description of the calculations is provided below: Diverted volume = portion of total conveyance losses + water spilled to Aajker Creek + irrigation applied volume Portion of total conveyance losses = 100.8 AF (91 AF lost in Farmer’s Canal and 9.8 AF lost in E. Minder during late season. Applicant’s canal shares account for all early season ditch loss.) Water spilled to Aajker Creek = total flow of water rights delivered to E. Minder – irrigation application (i.e., pump capacity) – E. Minder late season ditch loss = [(2.46 CFS – 1.78 CFS) * 1.983 AF/CFS-day * 72.6 days] – 9.8 AF = 87.7 AF Diverted volume = 100.8 + 87.7 + 255.96 = 444.50 AF Table 4 below specifies the diverted volume associated with each right according to the right’s flow rate proportional to the total flow rate. TABLE 4: Historic Diverted Volume Water Right Number ( - ) Percent of Total Flow (%) Diverted Volume (AF) 41H 30023118 33.8 150.24 41H 30023119 15.3 68.01 41H 30023120 50.9 226.25 TOTAL = 100 444.50 New (proposed) diverted volume for this water right: 405.50 AF. The Applicant proposes to continue diverting the entire volume under these water rights, with the exception of no longer diverting the 39 AF that are proposed to be left instream for mitigation under pending change application 41H 30102910. The water will continue to be diverted into the Farmer’s Canal, but instead of being diverted into the E. Minder Lateral, it will be diverted into the Maynard Border Ditch, which is Irrigation Change Application No. 41H 30103245 Technical Report Page 4 of 7 located approximately 1 mile farther down Farmer’s Canal. Water will be applied to the City’s property at the new Sports Complex. In total, the full volume that was historically diverted minus the volume changed to mitigation will be diverted: 444.5 – 39 = 405.5 AF. Each right will divert a portion of that volume, according to the proportion of the right’s flow rate to the total flow rate. Table 5 below specifies the diverted volume associated with each right. TABLE 5: New (Proposed) Diverted Volume Water Right Number ( - ) Percent of Total Flow (%) Diverted Volume (AF) 41H 30023118 33.8 137.06 41H 30023119 15.3 62.04 41H 30023120 50.9 206.4 TOTAL = 100 405.5 Adverse Effect (ARM 36.12.1903) DNRC employee who compiled this section: Brent Zundel, Water Resource Specialist Historic consumptive use (volume): 204.78 AF (total for all three water rights). Proposed new use consumptive use (volume): 165.26 AF. This application contains two consumptive use components: (1) irrigation of 65 acres of turf grass and (2) the addition of a place of storage. The Department considers net Irrigation Water Requirements (IWR) for turf grass to be fully consumptive. Using the USDA NRCS Irrigation Water Requirements (IWR) Program, pasture grass requires 18.27 in for a dry year with 80 percent occurrence. Consumed volume = 18.27 in * 1 ft/12 in * 65 acres = 98.96 AF The Applicant proposes to fill the irrigation reservoir twice per season. Additionally, they request to extend the period of use to March 1 – November 30, outside the unchanged period of diversion, which would allow them to apply stored water during warm spring and fall days. The volume used to fill the pond twice will be consumed from the system, as will evaporation. Evaporation is calculated after Potts (1988) using a 75%Eo value of 3.15 ft for the Bozeman weather station. According to the application, the pond has a 30 AF capacity with 2 acres of surface area and a maximum depth of 30 ft. Two fills = 2 * volume = 2 * 30 = 60 AF Annual evaporation = surface area * 75%Eo = 2 acres * 3.15 ft = 6.30 AF Thus, the total consumed volume for the proposed new use is 98.96 + 60 + 6.30 = 165.26 AF. The new consumptive use of 165.26 AF is less than the historic consumptive use of 204.78 AF. Note: 39 AF of consumed volume will be left instream in the West Gallatin River for mitigation purposes under pending change 41H 30102910. This application proposes to change the POU of 165.26 AF of consumed volume, so the total consumptive volume being changed from these rights is therefore 204.26, which is less than the total historic consumptive use. All acreage that was historically irrigated on the Norton Ranch will be retired and the POU will not be irrigated with the supplemental groundwater claims or Farmer’s Canal shares. The following are hydraulically connected surface waters for the purpose of evaluating return flows: Aajker and Baxter Creeks. Irrigation Change Application No. 41H 30103245 Technical Report Page 5 of 7 Monthly volume that returned to hydraulically connected surface waters under historic practices: TABLE 6: Historic Return Flow Calculations for 138.63 Acres IWR (in) Management Factor, 1973-2006 (0.921) Historic CU on 138.63 acres (AF) Applied Volume on 138.63 acres (AF) Irrecoverable Loss, Sprinkler (10%) Return Flows (AF) Jan 0.00 0.921 0.00 0.00 0.00 0.00 Feb 0.00 0.921 0.00 0.00 0.00 0.00 Mar 0.00 0.921 0.00 0.00 0.00 0.00 Apr 0.00 0.921 0.00 0.00 0.00 0.00 May 0.32 0.921 3.40 4.86 0.49 0.97 Jun 4.17 0.921 44.37 63.38 6.34 12.68 Jul 6.14 0.921 65.33 93.33 9.33 18.67 Aug 5.26 0.921 55.97 79.95 8.00 15.99 Sep 0.96 0.921 10.21 14.59 1.46 2.92 Oct 0.00 0.921 0.00 0.00 0.00 0.00 Nov 0.00 0.921 0.00 0.00 0.00 0.00 Dec 0.00 0.921 0.00 0.00 0.00 0.00 TOTAL = 16.85 – 179.28 256.12 25.61 51.22 Monthly volume that will return to hydraulically connected surface waters under new practice and loss of return flows as a result of the proposed change: TABLE 7: Proposed (New) Return Flow Calculations for 26.4 Acres (Retirement of 112.23 Acres) IWR (in) Management Factor, 1973-2006 (0.921) Historic CU on 26.4 acres (AF) Applied Volume on 26.4 acres (AF) Irrecoverable Loss, Sprinkler (10%) Return Flows (AF) Loss of Return Flows from Historic Conditions (AF) Jan 0.00 0.921 0.00 0.00 0.00 0.00 0.00 Feb 0.00 0.921 0.00 0.00 0.00 0.00 0.00 Mar 0.00 0.921 0.00 0.00 0.00 0.00 0.00 Apr 0.00 0.921 0.00 0.00 0.00 0.00 0.00 May 0.32 0.921 0.65 0.93 0.09 0.19 0.78 Jun 4.17 0.921 8.45 12.07 1.21 2.41 10.27 Jul 6.14 0.921 12.44 17.77 1.78 3.55 15.12 Aug 5.26 0.921 10.66 15.23 1.52 3.05 12.94 Sep 0.96 0.921 1.95 2.78 0.28 0.56 2.36 Oct 0.00 0.921 0.00 0.00 0.00 0.00 0.00 Nov 0.00 0.921 0.00 0.00 0.00 0.00 0.00 Dec 0.00 0.921 0.00 0.00 0.00 0.00 0.00 TOTAL = 16.85 – 34.14 48.77 4.88 9.75 41.47 The proposed change to retire 112.23 acres of irrigation will result in the loss of 41.75 AF of return flows (51.22 – 9.75 = 41.47 AF). Irrigation Change Application No. 41H 30103245 Technical Report Page 6 of 7 Other: The Applicant has proposed to retire/withdraw groundwater claims 41H 138898-00, 138899, 138902, and 138903 to alleviate the loss of return flows. These rights are for waste and seepage and have a claimed POU that is supplemental to the three claims being changed in this application. The Applicant submitted historical use evidence that these rights were exercised independently and on a distinct POU from that of the subject water rights. Right 41H 138898-00 claimed 70 acres and 1.25 CFS; 138989 claimed 17 acres and 1.25 CFS; 138902 claimed 45 acres and 1.25 CFS; 135903 claimed 18 acres and 1.25 CFS. The Applicant submitted evidence that these were historically used in combination on 44.5 acres in the SWNE and portions of the N½NWSE of Section 9. The Gallatin County Water Resources Survey confirms historical use as of its publication in 1953. Aerial imagery from 1981, 1995, and 2001 further support historical use on 44.5 acres. The Applicant proposes to fully retire or withdraw these rights. Under the proposal, water would no longer be diverted and would instead be rerouted to drain the property, with water being conveyed to Aajker and Baxter Creeks (see Exhibit 22 in the application). No irrigation would take place on the historic POU. Because these are existing statements of claim with no subsequent changes, their historic use must be evaluated prior to July 1, 1973, pursuant to ARM 36.12.1902(1)(a). Thus, the following calculations are made for historic use on 44.5 acres. Crop Consumptive Use Bozeman Experiment Farm weather station Irrigation Water Requirements (IWR) for alfalfa = 16.84 in Gallatin County Management Factor (pre-July 1, 1973) = 73.5% 16.84 in / 12 in per ft * 0.735 = 1.03145 ft per acre 1.03145 ft per acre * 44.5 acres = 45.90 AF Water Applied to Field 65% efficiency for graded border with 0.75 – 1.5% slope Water applied to field = consumptive use / 65% efficiency = 45.90 AF / 0.65 = 70.61 AF Irrecoverable Losses 5% loss for flood systems (claims are actually controlled subirrigation) Irrecoverable loss = water applied to field * irrecoverable loss percent = 70.61 AF *0.05 = 3.53 AF Total Historic Consumptive Volume on 44.5 acres Total historic consumptive volume = crop consumptive use + irrecoverable loss = 45.90 AF + 3.53 AF = 49.43 AF Total Historic Diverted Volume = 70.61 AF Note: The remaining 26.4 acres on this POU are proposed for retirement under a separate pending change application, 41H 30102910. Adequacy of Diversion (ARM 36.12.1904) DNRC employee who compiled this section: Brent Zundel, Water Resource Specialist No information relating to the adequacy of the diversion has been compiled in addition to what was submitted on the application. Beneficial Use (ARM 36.12.1801) DNRC employee who compiled this section: Brent Zundel, Water Resource Specialist No information relating to the beneficial use has been compiled in addition to what was submitted on the application. Irrigation Change Application No. 41H 30103245 Technical Report Page 7 of 7 Possessory Interest (ARM 36.12.1802) DNRC employee who compiled this section: Brent Zundel, Water Resource Specialist This application includes a copy of a Memorandum of Agreement for Norton Ranch Subdivision Water Adequacy Requirements between the Applicant and the City of Bozeman. This memorandum indicates that the City consents to the transfer of the water rights to the proposed new POU at the City Sports Complex upon successful completion of the water right change process. July 18, 2019 Page 1 of 16 STATE OF MONTANA DEPARTMENT OF NATURAL RESOURCES AND CONSERVATION 1424 9TH AVENUE P.O.BOX 201601 HELENA, MONTANA 59620-1601 CHANGE AUTHORIZATION Application From: Change Description: Volume: Acres: 2.46 CFS 336.17 AC-FT Number(s) Changed:41H-138898 41H-138899 41H-138902 41H-138903 41H-30023118 41H-30023119 41H-30023120 UPON FINDING THE REQUIREMENTS OF SECTION 85-2-402, MCA HAVE BEEN MET, APPLICATION TO CHANGE WATER RIGHT NUMBER 41H-30103245 SUBMITTED ON JUNE 7, 2016, IS APPROVED. SUBJECT WATER RIGHTS THE APPROPRIATOR IS AUTHORIZED TO CHANGE THE PLACE OF USE OF, ADD A PLACE OF STORAGE TO, AND CHANGE THE PERIOD OF USE OF STATEMENTS OF CLAIM 41H 30023118, 41H 30023119, AND 41H 30023120 (THE "SUBJECT WATER RIGHTS"). UNDER THESE THREE WATER RIGHTS, THE APPROPRIATOR MAY DIVERT UP TO 297.92 ACRE-FEET OF WATER AT A COMBINED FLOW RATE OF 2.34 CUBIC FEET PER SECOND FROM THE WEST GALLATIN RIVER AT THE FARMER'S CANAL HEADGATE IN THE SWNWNW OF SECTION 11, T03 S, R04 E, GALLATIN COUNTY. THE NEW PLACE OF USE IS 58.86 ACRES OF IRRIGATION AT THE CITY OF BOZEMAN SPORTS COMPLEX, LOCATED IN THE W2NW OF SECTION 3, T02 S, R05 E, GALLATIN COUNTY. THE SPORTS COMPLEX WILL BE BOUNDED BY BAXTER LANE, FLANDERS MILL ROAD, OAK STREET, AND COTTONWOOD ROAD. THE APPROPRIATOR IS ALSO AUTHORIZED TO ADD A 14.3-ACRE- FOOT IRRIGATION RESERVOIR IN THE SESWNW OF SECTION 3, T02 S, R05 E. NO CHANGES ARE MADE TO THE PERIOD OF DIVERSION, BUT THE PERIOD OF USE IS CHANGED TO MAY 1 TO NOVEMBER 30 TO ALLOW ADDITIONAL FLEXIBILITY IN USING STORED WATER. GROUNDWATER CLAIMS THE APPROPRIATOR IS AUTHORIZED TO CHANGE THE PURPOSE, PLACE OF USE, AND POINT OF DIVERSION OF STATEMENTS OF CLAIM 41H 138898-00, 41H 138899-00, 41H 138902-00, AND 41H 138903-00 (THE "GROUNDWATER CLAIMS"). THE APPROPRIATOR SHALL RETIRE 34.44 ACRES FROM IRRIGATION UNDER THE GROUNDWATER CLAIMS IN ORDER TO PROVIDE MITIGATION FOR THE LOSS OF RETURN FLOWS FROM THE SUBJECT WATER RIGHTS. UNDER THE GROUNDWATER CLAIMS, 38.25 ACRE-FEET AT A RATE OF 56.60 GALLONS PER MINUTE SHALL BE LEFT IN THE SUBSURFACE AS GROUNDWATER AND NO LONGER DIVERTED FROM JUNE 1 TO OCTOBER 31. THE NEW PLACE OF USE IS THE SAME AS THE NEW POINT OF DIVERSION: TWO POINTS, ONE ON AAJKER CREEK AND ONE ON BAXTER CREEK, AT THE DOWNSTREAM END OF NORTON PROPERTIES. THESE POINTS ARE LOCATED IN THE NWSENW AND NESWNE OF SECTION 9, T02 S, R05 E, FOR AAJKER AND BAXTER CREEKS, RESPECTIVELY. Change Application #: 41H-30103245 Flow Rate: Authorization Limits Water Right COMPLETION DEADLINE THE DEADLINE TO COMPLETE THIS AUTHORIZATION AND FILE A PROJECT COMPLETION NOTICE FOR CHANGE OF APPROPRIATION WATER RIGHT (FORM 618) IS DECEMBER 31, 2039 . IF YOU CANNOT MEET THE DEADLINE, FILE A FORM 607, APPLICATION FOR EXTENSION OF TIME, BY DECEMBER 31, 2039 . OTHERWISE, THE AUTHORIZATION IS VOID. 66.81 ACRES STATEMENT OF CLAIM STATEMENT OF CLAIM STATEMENT OF CLAIM STATEMENT OF CLAIM STATEMENT OF CLAIM STATEMENT OF CLAIM STATEMENT OF CLAIM 00 00 00 00 TypeExtWr # BOZEMAN, CITY OF LAZY J UTILITY ASSN %TIM COOPER, ATTY % KNAUB AND COMPANY PC BOZEMAN, MT 59771 1230 BIG SKY, MT 59716 1030 PO BOX 1230 PO BOX 161030 Change Authorization Additional Information: A PORTION OF THE SUBJECT WATER RIGHTS AND THE GROUNDWATER CLAIMS WAS PREVIOUSLY CHANGED UNDER RELATED APPLICATION NO. 41H 30102910. July 18, 2019 Page 3 of 16 41H 138898-00Water Right Number: JUNE 1 to OCTOBER 31 9 9 2S 2S 5E 5E GALLATIN GALLATIN NWSENW NESWNE *1 *2 Purpose (use): Period of Use: Priority Date:SEPTEMBER 15, 1919 Maximum Flow Rate:544.86 GPM Maximum Volume: MITIGATION WATER 17.15 AC-FT MITIGATION WATER Owners:LAZY J UTILITY ASSN BOZEMAN, CITY OF % KNAUB AND COMPANY PC %TIM COOPER, ATTY BIG SKY, MT 59716 1030 BOZEMAN, MT 59771 1230 PO BOX 161030 PO BOX 1230 Volume:12.00 AC-FT Version Status: Version:7 -- CHANGE AUTHORIZATION SEVERED THE INFORMATION SHOWN BELOW REFLECTS THE ENTIRE WATER RIGHT. AN ASTERISK (*) HAS BEEN PLACED NEXT TO EACH ITEM ALTERED BY THIS CHANGE AUTHORIZATION. Change Application #: 41H-30103245 *Purpose (Use): *Place of Use: STATEMENT OF CLAIM Change Authorization Enforceable Priority Date: SEPTEMBER 15, 1919 OWNERSHIP UPDATE RECEIVED WASTE & SEEPAGE, UNNAMED TRIBUTARY OF BAXTER CREEK UNNAMED TRIBUTARY OF BAXTER CREEK Source Name: Source Name: GROUNDWATER GROUNDWATER Source Type: Source Type: ID Govt Lot Qtr Sec Sec Twp Rge County *3 *4 *5 *6 9 9 9 9 5E 5E 5E 5E 2S 2S 2S 2S NWSENW NWSENW NESWNE NESWNE GALLATIN GALLATIN GALLATIN GALLATIN INSTREAM INSTREAM INSTREAM INSTREAM Diversion Means: Diversion Means: Diversion Means: Diversion Means: WASTE & SEEPAGE, UNNAMED TRIBUTARY OF BAXTER CREEK UNNAMED TRIBUTARY OF BAXTER CREEK WASTE & SEEPAGE, UNNAMED TRIBUTARY OF BAXTER CREEK UNNAMED TRIBUTARY OF BAXTER CREEK Source Name: Source Name: Source Name: Source Name: JUNE 1 TO OCTOBER 31 JUNE 1 TO OCTOBER 31 JUNE 1 TO OCTOBER 31 JUNE 1 TO OCTOBER 31 Period of Diversion: Period of Diversion: Period of Diversion: Period of Diversion: ID Govt Lot Qtr Sec Sec Twp Rge CountyAcres IMPORTANT INFORMATION UNDER SUPPLEMENTAL GROUNDWATER CLAIMS 41H 138898-00, 41H 138899-00, 41H 138902-00, AND 41H 138903-00, MITIGATION WATER IN THE AMOUNT OF 48 ACRE-FEET AT A CONTINUOUS RATE OF 71.02 GALLONS PER MINUTE SHALL BE LEFT IN THE SUBSURFACE AS GROUNDWATER FROM JUNE 1 TO OCTOBER 31 TO MITIGATE ADVERSE EFFECT FROM THE LOSS OF RETURN FLOWS FROM WATER RIGHTS 41H 30023118, 41H 30023119, AND 41H 30023120. 544.86 GPMHistorical Flow Rate: 17.15 AC-FT 12.00 AC-FT Historical Diverted Volume: Historical Consumptive Volume: *Point of Diversion and Means of Diversion: July 18, 2019 Page 4 of 16 Change Application #: 41H-30103245 Change Authorization OWNERSHIP UPDATE TYPE 608 # 41802 RECEIVED 09/05/2006. OWNERSHIP UPDATE TYPE 641 # 148931 RECEIVED 09/28/2016. OWNERSHIP UPDATE TYPE 641 # 151302 RECEIVED 12/12/2016. OWNERSHIP UPDATE TYPE 641 # 157815 RECEIVED 12/12/2016. OWNERSHIP UPDATE TYPE WATER COURT ORDER # 155233 RECEIVED 04/19/2017. OWNERSHIP UPDATE TYPE 608 # 178292 RECEIVED 10/11/2018. OWNERSHIP UPDATE TYPE 608 # 187844 RECEIVED 06/06/2019. July 18, 2019 Page 5 of 16 41H 138899-00Water Right Number: JUNE 1 to OCTOBER 31 9 9 2S 2S 5E 5E GALLATIN GALLATIN NWSENW NESWNE *1 *2 Purpose (use): Period of Use: Priority Date:SEPTEMBER 15, 1919 Maximum Flow Rate:544.86 GPM Maximum Volume: MITIGATION WATER 17.15 AC-FT MITIGATION WATER Owners:LAZY J UTILITY ASSN BOZEMAN, CITY OF % KNAUB AND COMPANY PC %TIM COOPER, ATTY BIG SKY, MT 59716 1030 BOZEMAN, MT 59771 1230 PO BOX 161030 PO BOX 1230 Volume:12.00 AC-FT Version Status: Version:7 -- CHANGE AUTHORIZATION SEVERED THE INFORMATION SHOWN BELOW REFLECTS THE ENTIRE WATER RIGHT. AN ASTERISK (*) HAS BEEN PLACED NEXT TO EACH ITEM ALTERED BY THIS CHANGE AUTHORIZATION. Change Application #: 41H-30103245 *Purpose (Use): *Place of Use: STATEMENT OF CLAIM Change Authorization Enforceable Priority Date: SEPTEMBER 15, 1919 OWNERSHIP UPDATE RECEIVED OWNERSHIP UPDATE TYPE 608 # 41802 RECEIVED 09/05/2006. OWNERSHIP UPDATE TYPE 641 # 148933 RECEIVED 09/28/2016. OWNERSHIP UPDATE TYPE 641 # 157817 RECEIVED 12/12/2016. OWNERSHIP UPDATE TYPE 641 # 151305 RECEIVED 12/12/2016. OWNERSHIP UPDATE TYPE WATER COURT ORDER # 155233 RECEIVED 04/19/2017. OWNERSHIP UPDATE TYPE 608 # 178292 RECEIVED 10/11/2018. OWNERSHIP UPDATE TYPE 608 # 187844 RECEIVED 06/06/2019. WASTE & SEEPAGE, UNNAMED TRIBUTARY OF BAXTER CREEK Source Name: GROUNDWATERSource Type: ID Govt Lot Qtr Sec Sec Twp Rge County *2 *3 9 9 5E 5E 2S 2S NWSENW NESWNE GALLATIN GALLATIN INSTREAM INSTREAM Diversion Means: Diversion Means: JUNE 1 TO OCTOBER 31 JUNE 1 TO OCTOBER 31 Period of Diversion: Period of Diversion: ID Govt Lot Qtr Sec Sec Twp Rge CountyAcres IMPORTANT INFORMATION UNDER SUPPLEMENTAL GROUNDWATER CLAIMS 41H 138898-00, 41H 138899-00, 41H 138902-00, AND 41H 138903-00, MITIGATION WATER IN THE AMOUNT OF 48 ACRE-FEET AT A CONTINUOUS RATE OF 71.02 GALLONS PER MINUTE SHALL BE LEFT IN THE SUBSURFACE AS GROUNDWATER FROM JUNE 1 TO OCTOBER 31 TO MITIGATE ADVERSE EFFECT FROM THE LOSS OF RETURN FLOWS FROM WATER RIGHTS 41H 30023118, 41H 30023119, AND 41H 30023120. 544.86 GPMHistorical Flow Rate: 17.15 AC-FT 12.00 AC-FT Historical Diverted Volume: Historical Consumptive Volume: *Point of Diversion and Means of Diversion: July 18, 2019 Page 6 of 16 41H 138902-00Water Right Number: JUNE 1 to OCTOBER 31 9 9 2S 2S 5E 5E GALLATIN GALLATIN NWSENW NESWNE *1 *2 Purpose (use): Period of Use: Priority Date:SEPTEMBER 15, 1919 Maximum Flow Rate:544.86 GPM Maximum Volume: MITIGATION WATER 17.15 AC-FT MITIGATION WATER Owners:LAZY J UTILITY ASSN BOZEMAN, CITY OF % KNAUB AND COMPANY PC %TIM COOPER, ATTY BIG SKY, MT 59716 1030 BOZEMAN, MT 59771 1230 PO BOX 161030 PO BOX 1230 Volume:12.00 AC-FT Version Status: Version:7 -- CHANGE AUTHORIZATION SEVERED THE INFORMATION SHOWN BELOW REFLECTS THE ENTIRE WATER RIGHT. AN ASTERISK (*) HAS BEEN PLACED NEXT TO EACH ITEM ALTERED BY THIS CHANGE AUTHORIZATION. Change Application #: 41H-30103245 *Purpose (Use): *Place of Use: STATEMENT OF CLAIM Change Authorization Enforceable Priority Date: SEPTEMBER 15, 1919 OWNERSHIP UPDATE RECEIVED OWNERSHIP UPDATE TYPE 608 # 41802 RECEIVED 09/05/2006. OWNERSHIP UPDATE TYPE 641 # 148935 RECEIVED 09/28/2016. OWNERSHIP UPDATE TYPE 641 # 157819 RECEIVED 12/12/2016. OWNERSHIP UPDATE TYPE 641 # 151307 RECEIVED 12/12/2016. OWNERSHIP UPDATE TYPE WATER COURT ORDER # 155233 RECEIVED 04/19/2017. OWNERSHIP UPDATE TYPE 608 # 178292 RECEIVED 10/11/2018. OWNERSHIP UPDATE TYPE 608 # 187844 RECEIVED 06/06/2019. WASTE & SEEPAGE, UNNAMED TRIBUTARY OF BAXTER CREEK Source Name: GROUNDWATERSource Type: ID Govt Lot Qtr Sec Sec Twp Rge County *2 *3 9 9 5E 5E 2S 2S NWSENW NESWNE GALLATIN GALLATIN INSTREAM INSTREAM Diversion Means: Diversion Means: JUNE 1 TO OCTOBER 31 JUNE 1 TO OCTOBER 31 Period of Diversion: Period of Diversion: ID Govt Lot Qtr Sec Sec Twp Rge CountyAcres IMPORTANT INFORMATION UNDER SUPPLEMENTAL GROUNDWATER CLAIMS 41H 138898-00, 41H 138899-00, 41H 138902-00, AND 41H 138903-00, MITIGATION WATER IN THE AMOUNT OF 48 ACRE-FEET AT A CONTINUOUS RATE OF 71.02 GALLONS PER MINUTE SHALL BE LEFT IN THE SUBSURFACE AS GROUNDWATER FROM JUNE 1 TO OCTOBER 31 TO MITIGATE ADVERSE EFFECT FROM THE LOSS OF RETURN FLOWS FROM WATER RIGHTS 41H 30023118, 41H 30023119, AND 41H 30023120. 544.86 GPMHistorical Flow Rate: 17.15 AC-FT 12.00 AC-FT Historical Diverted Volume: Historical Consumptive Volume: *Point of Diversion and Means of Diversion: July 18, 2019 Page 7 of 16 41H 138903-00Water Right Number: JUNE 1 to OCTOBER 31 9 9 2S 2S 5E 5E GALLATIN GALLATIN NWSENW NESWNE *1 *2 Purpose (use): Period of Use: Priority Date:SEPTEMBER 15, 1919 Maximum Flow Rate:544.86 GPM Maximum Volume: MITIGATION WATER 17.15 AC-FT MITIGATION WATER Owners:LAZY J UTILITY ASSN BOZEMAN, CITY OF % KNAUB AND COMPANY PC %TIM COOPER, ATTY BIG SKY, MT 59716 1030 BOZEMAN, MT 59771 1230 PO BOX 161030 PO BOX 1230 Volume:12.00 AC-FT Version Status: Version:7 -- CHANGE AUTHORIZATION SEVERED THE INFORMATION SHOWN BELOW REFLECTS THE ENTIRE WATER RIGHT. AN ASTERISK (*) HAS BEEN PLACED NEXT TO EACH ITEM ALTERED BY THIS CHANGE AUTHORIZATION. Change Application #: 41H-30103245 *Purpose (Use): *Place of Use: STATEMENT OF CLAIM Change Authorization Enforceable Priority Date: SEPTEMBER 15, 1919 OWNERSHIP UPDATE RECEIVED OWNERSHIP UPDATE TYPE 608 # 41802 RECEIVED 09/05/2006. OWNERSHIP UPDATE TYPE 641 # 148937 RECEIVED 09/28/2016. OWNERSHIP UPDATE TYPE 641 # 151309 RECEIVED 12/12/2016. OWNERSHIP UPDATE TYPE 641 # 157821 RECEIVED 12/12/2016. OWNERSHIP UPDATE TYPE WATER COURT ORDER # 155233 RECEIVED 04/19/2017. OWNERSHIP UPDATE TYPE 608 # 178292 RECEIVED 10/11/2018. OWNERSHIP UPDATE TYPE 608 # 187844 RECEIVED 06/06/2019. WASTE & SEEPAGE, UNNAMED TRIBUTARY OF BAXTER CREEK Source Name: GROUNDWATERSource Type: ID Govt Lot Qtr Sec Sec Twp Rge County *2 *3 9 9 5E 5E 2S 2S NWSENW NESWNE GALLATIN GALLATIN INSTREAM INSTREAM Diversion Means: Diversion Means: JUNE 1 TO OCTOBER 31 JUNE 1 TO OCTOBER 31 Period of Diversion: Period of Diversion: ID Govt Lot Qtr Sec Sec Twp Rge CountyAcres IMPORTANT INFORMATION UNDER SUPPLEMENTAL GROUNDWATER CLAIMS 41H 138898-00, 41H 138899-00, 41H 138902-00, AND 41H 138903-00, MITIGATION WATER IN THE AMOUNT OF 48 ACRE-FEET AT A CONTINUOUS RATE OF 71.02 GALLONS PER MINUTE SHALL BE LEFT IN THE SUBSURFACE AS GROUNDWATER FROM JUNE 1 TO OCTOBER 31 TO MITIGATE ADVERSE EFFECT FROM THE LOSS OF RETURN FLOWS FROM WATER RIGHTS 41H 30023118, 41H 30023119, AND 41H 30023120. 544.86 GPMHistorical Flow Rate: 17.15 AC-FT 12.00 AC-FT Historical Diverted Volume: Historical Consumptive Volume: *Point of Diversion and Means of Diversion: July 18, 2019 Page 8 of 16 41H 30023118Water Right Number: OFF STREAM 5E32S Govt Lot Qtr Sec Sec Twp Rge County SESWNW GALLATIN Purpose (use): 15.00 FEET 2.00 ACRES 14.30 ACRE-FEET Depth: Surface Area: Current Capacity: Priority Date:OCTOBER 15, 1866 Maximum Flow Rate:370.53 GPM Maximum Volume: Maximum Acres: MITIGATION WATER IRRIGATION IRRIGATION 66.81 118.82 AC-FT Owners:LAZY J UTILITY ASSN BOZEMAN, CITY OF % KNAUB AND COMPANY PC %TIM COOPER, ATTY BIG SKY, MT 59716 1030 BOZEMAN, MT 59771 1230 PO BOX 161030 PO BOX 1230 Version Status: Version:4 -- CHANGE AUTHORIZATION ACTIVE THE INFORMATION SHOWN BELOW REFLECTS THE ENTIRE WATER RIGHT. AN ASTERISK (*) HAS BEEN PLACED NEXT TO EACH ITEM ALTERED BY THIS CHANGE AUTHORIZATION. Change Application #: 41H-30103245 *Reservoir: STATEMENT OF CLAIM Change Authorization Enforceable Priority Date: OCTOBER 15, 1866 Ditch Name: FARMERS CANAL WEST GALLATIN RIVERSource Name: SURFACE WATERSource Type: ID Govt Lot Qtr Sec Sec Twp Rge County 1 2 11 11 4E 4E 3S 3S SWNWNW SWNWNW GALLATIN GALLATIN HEADGATE INSTREAM Diversion Means: Diversion Means: JUNE 1 TO OCTOBER 1 OCTOBER 2 TO OCTOBER 31 JUNE 1 TO OCTOBER 1 OCTOBER 2 TO OCTOBER 31 Period of Diversion: Period of Diversion: Period of Diversion: Period of Diversion: Flow Rate: Flow Rate: Flow Rate: Flow Rate: 354.32 GPM 337.52 GPM 16.21 GPM 33.01 GPM 370.53 GPMHistorical Flow Rate: 118.82 AC-FT 68.84 AC-FT Historical Diverted Volume: Historical Consumptive Volume: Point of Diversion and Means of Diversion: July 18, 2019 Page 9 of 16 JUNE 1 to OCTOBER 31 JUNE 1 to OCTOBER 31 MAY 1 to NOVEMBER 30 11 2 3 35 34 26 27 23 14 15 10 11 2 3 34 35 27 22 15 16 9 4 5 32 31 30 19 29 9 3 7.95 58.86 3S 3S 3S 2S 2S 2S 2S 2S 2S 2S 2S 2S 2S 2S 1S 1S 1S 1S 1S 1S 1S 1S 1S 1N 1N 1N 1N 1N 2S 2S 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 5E 5E GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN NESW W2NW 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 *1 Period of Use: Period of Use: Period of Use: Purpose (Use): Purpose (Use): MITIGATION WATER IRRIGATION IRRIGATION HISTORICAL PLACE OF USE CITY OF BOZEMAN SPORTS COMPLEX Purpose Clarification: Purpose Clarification: Total: Total: 7.95 58.86 Volume: Volume: Volume: 13.18 AC-FT 4.96 AC-FT 100.68 AC-FT Climatic Area: Climatic Area: 4 - MODERATELY LOW 4 - MODERATELY LOW SPRINKLER SPRINKLER Irrigation Type: Irrigation Type: Change Application #: 41H-30103245 *Purpose (Use): Place of Use: Place of Use: *Place of Use: Change Authorization ID ID ID Govt Lot Govt Lot Govt Lot Qtr Sec Qtr Sec Qtr Sec Sec Sec Sec Twp Twp Twp Rge Rge Rge County County County Acres Acres Acres July 18, 2019 Page 10 of 16 Change Application #: 41H-30103245 Change Authorization OWNERSHIP UPDATE RECEIVED OWNERSHIP UPDATE TYPE 608 # 42301 RECEIVED 10/23/2006. OWNERSHIP UPDATE TYPE 641 # 126121 RECEIVED 10/16/2014. OWNERSHIP UPDATE TYPE WATER COURT ORDER # 127325 RECEIVED 12/18/2014. OWNERSHIP UPDATE TYPE 641 # 157823 RECEIVED 12/12/2016. OWNERSHIP UPDATE TYPE 641 # 151314 RECEIVED 12/12/2016. OWNERSHIP UPDATE TYPE WATER COURT ORDER # 152962 RECEIVED 02/07/2017. OWNERSHIP UPDATE TYPE 608 # 178292 RECEIVED 10/11/2018. OWNERSHIP UPDATE TYPE 642 # 190204 RECEIVED 06/10/2019. OWNERSHIP UPDATE TYPE 642 # 190162 RECEIVED 06/10/2019. IMPORTANT INFORMATION OPERATION OF MITIGATION-PURPOSE FLOW RATES FOR SUBJECT WATER RIGHTS: IN THE EVENT THAT THE APPLICANT MAKES A CALL FOR WATER OR A WATER COMMISSIONER IS APPOINTED, THE FOLLOWING OPERATION REPRESENTING UNDIVIDED, CONTINUOUS FLOW RATES OF THE WATER RIGHTS SHALL BE FOLLOWED. WATER RIGHT NO. PERIOD OF USE FLOW RATE (GPM) 41H 30023118 5/1 - 5/31 0.00 6/1 - 10/1 16.21 10/2 - 10/31 33.01 41H 30023119 5/1 - 5/31 0.00 6/1 - 10/1 7.34 10/2 - 10/31 14.95 41H 30023120 5/1 - 5/31 47.96 6/1 - 10/1 24.41 10/2 - 10/31 0.00 TOTAL AT ANY TIME DURING SEASON: 47.96 July 18, 2019 Page 11 of 16 41H 30023119Water Right Number: OFF STREAM 5E32S Govt Lot Qtr Sec Sec Twp Rge County SESWNW GALLATIN Purpose (use): 15.00 FEET 2.00 ACRES 14.30 ACRE-FEET Depth: Surface Area: Current Capacity: Priority Date:JUNE 15, 1881 Maximum Flow Rate:167.86 GPM Maximum Volume: Maximum Acres: MITIGATION WATER IRRIGATION IRRIGATION 66.81 53.83 AC-FT Owners:LAZY J UTILITY ASSN BOZEMAN, CITY OF % KNAUB AND COMPANY PC %TIM COOPER, ATTY BIG SKY, MT 59716 1030 BOZEMAN, MT 59771 1230 PO BOX 161030 PO BOX 1230 Version Status: Version:4 -- CHANGE AUTHORIZATION ACTIVE THE INFORMATION SHOWN BELOW REFLECTS THE ENTIRE WATER RIGHT. AN ASTERISK (*) HAS BEEN PLACED NEXT TO EACH ITEM ALTERED BY THIS CHANGE AUTHORIZATION. Change Application #: 41H-30103245 *Reservoir: STATEMENT OF CLAIM Change Authorization Enforceable Priority Date: JUNE 15, 1881 Ditch Name: FARMERS CANAL WEST GALLATIN RIVERSource Name: SURFACE WATERSource Type: ID Govt Lot Qtr Sec Sec Twp Rge County 1 2 11 11 4E 4E 3S 3S SWNWNW SWNWNW GALLATIN GALLATIN HEADGATE INSTREAM Diversion Means: Diversion Means: JUNE 1 TO OCTOBER 1 OCTOBER 2 TO OCTOBER 31 JUNE 1 TO OCTOBER 1 OCTOBER 2 TO OCTOBER 31 Period of Diversion: Period of Diversion: Period of Diversion: Period of Diversion: Flow Rate: Flow Rate: Flow Rate: Flow Rate: 160.52 GPM 152.91 GPM 7.34 GPM 14.95 GPM 167.86 GPMHistorical Flow Rate: 53.83 AC-FT 31.18 AC-FT Historical Diverted Volume: Historical Consumptive Volume: Point of Diversion and Means of Diversion: July 18, 2019 Page 12 of 16 JUNE 1 to OCTOBER 31 JUNE 1 to OCTOBER 31 MAY 1 to NOVEMBER 30 11 2 3 35 34 26 27 23 14 15 10 11 2 3 34 35 27 22 15 16 9 4 5 32 31 30 19 29 9 3 7.95 58.86 3S 3S 3S 2S 2S 2S 2S 2S 2S 2S 2S 2S 2S 2S 1S 1S 1S 1S 1S 1S 1S 1S 1S 1N 1N 1N 1N 1N 2S 2S 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 5E 5E GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN NESW W2NW 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 *1 Period of Use: Period of Use: Period of Use: Purpose (Use): Purpose (Use): MITIGATION WATER IRRIGATION IRRIGATION HISTORICAL PLACE OF USE CITY OF BOZEMAN SPORTS COMPLEX Purpose Clarification: Purpose Clarification: Total: Total: 7.95 58.86 Volume: Volume: Volume: 5.97 AC-FT 2.25 AC-FT 45.61 AC-FT Climatic Area: Climatic Area: 4 - MODERATELY LOW 4 - MODERATELY LOW SPRINKLER SPRINKLER Irrigation Type: Irrigation Type: Change Application #: 41H-30103245 *Purpose (Use): Place of Use: Place of Use: *Place of Use: Change Authorization ID ID ID Govt Lot Govt Lot Govt Lot Qtr Sec Qtr Sec Qtr Sec Sec Sec Sec Twp Twp Twp Rge Rge Rge County County County Acres Acres Acres July 18, 2019 Page 13 of 16 Change Application #: 41H-30103245 Change Authorization OWNERSHIP UPDATE RECEIVED OWNERSHIP UPDATE TYPE 608 # 42299 RECEIVED 10/23/2006. OWNERSHIP UPDATE TYPE 641 # 126123 RECEIVED 10/16/2014. OWNERSHIP UPDATE TYPE WATER COURT ORDER # 127325 RECEIVED 12/18/2014. OWNERSHIP UPDATE TYPE 641 # 151317 RECEIVED 12/12/2016. OWNERSHIP UPDATE TYPE 641 # 157825 RECEIVED 12/12/2016. OWNERSHIP UPDATE TYPE WATER COURT ORDER # 152964 RECEIVED 02/07/2017. OWNERSHIP UPDATE TYPE 608 # 178292 RECEIVED 10/11/2018. OWNERSHIP UPDATE TYPE 642 # 190209 RECEIVED 06/10/2019. OWNERSHIP UPDATE TYPE 642 # 190210 RECEIVED 06/10/2019. IMPORTANT INFORMATION OPERATION OF MITIGATION-PURPOSE FLOW RATES FOR SUBJECT WATER RIGHTS: IN THE EVENT THAT THE APPLICANT MAKES A CALL FOR WATER OR A WATER COMMISSIONER IS APPOINTED, THE FOLLOWING OPERATION REPRESENTING UNDIVIDED, CONTINUOUS FLOW RATES OF THE WATER RIGHTS SHALL BE FOLLOWED. WATER RIGHT NO. PERIOD OF USE FLOW RATE (GPM) 41H 30023118 5/1 - 5/31 0.00 6/1 - 10/1 16.21 10/2 - 10/31 33.01 41H 30023119 5/1 - 5/31 0.00 6/1 - 10/1 7.34 10/2 - 10/31 14.95 41H 30023120 5/1 - 5/31 47.96 6/1 - 10/1 24.41 10/2 - 10/31 0.00 TOTAL AT ANY TIME DURING SEASON: 47.96 July 18, 2019 Page 14 of 16 41H 30023120Water Right Number: OFF STREAM 5E32S Govt Lot Qtr Sec Sec Twp Rge County SESWNW GALLATIN Purpose (use): 15.00 FEET 2.00 ACRES 14.30 ACRE-FEET Depth: Surface Area: Current Capacity: Priority Date:JUNE 1, 1867 Maximum Flow Rate:558.04 GPM Maximum Volume: Maximum Acres: MITIGATION WATER IRRIGATION IRRIGATION 66.81 178.95 AC-FT Owners:LAZY J UTILITY ASSN BOZEMAN, CITY OF % KNAUB AND COMPANY PC %TIM COOPER, ATTY BIG SKY, MT 59716 1030 BOZEMAN, MT 59771 1230 PO BOX 161030 PO BOX 1230 Version Status: Version:5 -- CHANGE AUTHORIZATION ACTIVE THE INFORMATION SHOWN BELOW REFLECTS THE ENTIRE WATER RIGHT. AN ASTERISK (*) HAS BEEN PLACED NEXT TO EACH ITEM ALTERED BY THIS CHANGE AUTHORIZATION. Change Application #: 41H-30103245 *Reservoir: STATEMENT OF CLAIM Change Authorization Enforceable Priority Date: JUNE 1, 1867 Ditch Name: FARMERS CANAL WEST GALLATIN RIVERSource Name: SURFACE WATERSource Type: ID Govt Lot Qtr Sec Sec Twp Rge County 1 2 11 11 4E 4E 3S 3S SWNWNW SWNWNW GALLATIN GALLATIN HEADGATE INSTREAM Diversion Means: Diversion Means: MAY 1 TO MAY 31 JUNE 1 TO OCTOBER 1 MAY 1 TO MAY 31 JUNE 1 TO OCTOBER 1 Period of Diversion: Period of Diversion: Period of Diversion: Period of Diversion: Flow Rate: Flow Rate: Flow Rate: Flow Rate: 510.08 GPM 533.63 GPM 47.96 GPM 24.41 GPM 558.04 GPMHistorical Flow Rate: 178.95 AC-FT 103.67 AC-FT Historical Diverted Volume: Historical Consumptive Volume: Point of Diversion and Means of Diversion: July 18, 2019 Page 15 of 16 MAY 1 to OCTOBER 1 MAY 1 to OCTOBER 1 MAY 1 to NOVEMBER 30 11 2 3 35 34 26 27 23 14 15 10 11 2 3 34 35 27 22 15 16 9 4 5 32 31 30 19 29 9 3 7.95 58.86 3S 3S 3S 2S 2S 2S 2S 2S 2S 2S 2S 2S 2S 2S 1S 1S 1S 1S 1S 1S 1S 1S 1S 1N 1N 1N 1N 1N 2S 2S 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 4E 5E 5E GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN GALLATIN NESW W2NW 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 *1 Period of Use: Period of Use: Period of Use: Purpose (Use): Purpose (Use): MITIGATION WATER IRRIGATION IRRIGATION HISTORICAL PLACE OF USE CITY OF BOZEMAN SPORTS COMPLEX Purpose Clarification: Purpose Clarification: Total: Total: 7.95 58.86 Volume: Volume: Volume: 19.85 AC-FT 7.47 AC-FT 151.63 AC-FT Climatic Area: Climatic Area: 4 - MODERATELY LOW 4 - MODERATELY LOW SPRINKLER SPRINKLER Irrigation Type: Irrigation Type: Change Application #: 41H-30103245 *Purpose (Use): Place of Use: Place of Use: *Place of Use: Change Authorization ID ID ID Govt Lot Govt Lot Govt Lot Qtr Sec Qtr Sec Qtr Sec Sec Sec Sec Twp Twp Twp Rge Rge Rge County County County Acres Acres Acres July 18, 2019 Page 16 of 16 Change Application #: 41H-30103245 Change Authorization OWNERSHIP UPDATE RECEIVED OWNERSHIP UPDATE TYPE 608 # 42230 RECEIVED 10/17/2006. OWNERSHIP UPDATE TYPE 641 # 126125 RECEIVED 10/16/2014. OWNERSHIP UPDATE TYPE WATER COURT ORDER # 127328 RECEIVED 12/18/2014. OWNERSHIP UPDATE TYPE 641 # 157827 RECEIVED 12/12/2016. OWNERSHIP UPDATE TYPE 641 # 151319 RECEIVED 12/12/2016. OWNERSHIP UPDATE TYPE WATER COURT ORDER # 153034 RECEIVED 02/07/2017. OWNERSHIP UPDATE TYPE 608 # 178292 RECEIVED 10/11/2018. OWNERSHIP UPDATE TYPE 642 # 190213 RECEIVED 06/10/2019. OWNERSHIP UPDATE TYPE 642 # 190212 RECEIVED 06/10/2019. IMPORTANT INFORMATION OPERATION OF MITIGATION-PURPOSE FLOW RATES FOR SUBJECT WATER RIGHTS: IN THE EVENT THAT THE APPLICANT MAKES A CALL FOR WATER OR A WATER COMMISSIONER IS APPOINTED, THE FOLLOWING OPERATION REPRESENTING UNDIVIDED, CONTINUOUS FLOW RATES OF THE WATER RIGHTS SHALL BE FOLLOWED. WATER RIGHT NO. PERIOD OF USE FLOW RATE (GPM) 41H 30023118 5/1 - 5/31 0.00 6/1 - 10/1 16.21 10/2 - 10/31 33.01 41H 30023119 5/1 - 5/31 0.00 6/1 - 10/1 7.34 10/2 - 10/31 14.95 41H 30023120 5/1 - 5/31 47.96 6/1 - 10/1 24.41 10/2 - 10/31 0.00 TOTAL AT ANY TIME DURING SEASON: 47.96 Revised 07-2016 Preliminary Determination to Grant Page 1 of 52 Application to Change Water Right No. 41H 30103245 BEFORE THE DEPARTMENT OF NATURAL RESOURCES AND CONSERVATION OF THE STATE OF MONTANA * * * * * * * APPLICATION TO CHANGE WATER RIGHT NO. 41H 30103245 BY NORTON PROPERTIES LLC, NORTON RANCH HOMES LLC, AND J&D FAMILY LP ) ))) PRELIMINARY DETERMINATION TO GRANT CHANGE * * * * * * * On August 10, 2015, Norton Properties LLC, Norton Ranch Homes LLC, and J&D Family LP (Applicant) submitted Application to Change an Existing Irrigation Water Right No. 41H 30103245 to change Water Right Claim Nos. 41H 30023118, 41H 30023119, and 41H 30023120 to the Bozeman Regional Office of the Department of Natural Resources and Conservation (Department or DNRC). The Applicant proposes to change the place of use of use of the three Water Right Claims from the Norton Ranch to the City of Bozeman Sports Complex, add a place of storage, and expand the period of use of the rights to enable the use of stored water. The Department published receipt of the Application on its website. A pre-application meeting was held for this Application and the concurrent Norton-Bostwick Change Application 41H 30102910 on March 19, 2015. The Department sent the Applicant a deficiency letter under §85-2-302, Montana Code Annotated (MCA), dated December 2, 2016. The Applicant responded with information dated December 12, 2016. The Application was determined to be correct and complete as of February 5, 2016. The Applicant submitted a Waiver of Statutory Timelines on May 20, 2016, extending the deadline for a Preliminary Determination until 45 days after the Applicant submitted additional information for consideration. The Applicant submitted additional information in the form of a major Amendment to the Application, on June 7, 2016, to incorporate Water Right Claim Nos. 41H 138898-00, 41H 138899-00, 41H 138902-00, and 41H 138903-00 into this Change Application. This major Amendment reset statutory timelines for the Application. The Applicant submitted a minor Amendment to this application, which reduced the transferable volume, on November 7, 2016. The Department sent the Applicant a deficiency letter for the Amended Application on December 2, 2016. The Applicant responded with information dated December 12, 2016. The Applicant submitted another minor Amendment to this Application on January 1, 2017, which again reduced the transferable Revised 07-2016 Preliminary Determination to Grant Page 2 of 52 Application to Change Water Right No. 41H 30103245 volume. The Amended Application was determined to be correct and complete as of January 12, 2018. An Environmental Assessment for this Application was completed on May 8, 2018. INFORMATION The Department considered the following information submitted by the Applicant, which is contained in the administrative record. Application as Filed: • Application to Change Water Right, Form 606 IR • Change in Place of Storage Addendum • Exhibits 1 through 25; 27 through 51; and 53 through 55 Information Received after Application Filed • Exhibit 26, “City of Bozeman’s Farmer’s Canal Company Share Certificates,” received May 27, 2016. • Exhibit 52, “City of Bozeman and Maynard Border Pipeline Group Conveyance Agreement,” received November 4, 2016. • “Norton Change Applications – Replacement Exhibit,” October 5, 2015, email from Deborah Stephenson (DMS) to Troy Benn (Department) containing Farmer’s Canal ditch rider notes to replace the originally submitted notes, Exhibit 24. • “Bylaws of the Farmer’s Canal Company of Gallatin County,” received via email on April 15, 2016, from Deborah Stephenson (DMS) to Brent Zundel (Department). • Motion to Amend, submitted by the Applicant to the Montana Water Court on April 29, 2016, clarifying the historical place of use of both the subject water rights and the groundwater claims. • Amendment to the Application; email from Deborah Stephenson (DMS) to Brent Zundel (Department) received June 7, 2016, and signed hard copy received June 15, 2016; proposing to incorporate the retirement of the groundwater claims into the current Application. • Appendices A, B, and C for June 7, 2016, Amendment. • Waiver of Statutory Timelines, included with Amendment to the Application, received June 7, 2016, extending the statutory timelines for an additional 45 days from the receipt of the letter (until July 22, 2016). • “Revised Table 10 – Diversion Volume Calculations,” received July 12, 2016, calculating historical diverted volume for the subject water rights. Revised 07-2016 Preliminary Determination to Grant Page 3 of 52 Application to Change Water Right No. 41H 30103245 • Amendment to Application; email from Deborah Stephenson (DMS) to Brent Zundel and Kerri Strasheim (Department) received November 1, 2016; modifying the transferable volumes and the proposed new use at the City Sports Complex. • Amendment to Application; email from Deborah Stephenson (DMS) to Brent Zundel and Kerri Strasheim (Department) received January 18, 2017; modifying the transferable volumes and the proposed new use at the City Sports Complex. • Phone call between Brian Heaston (City of Bozeman) and Kerri Strasheim (Department), dated May 7, 2018, confirming irrigation pond design and operation. • Emails and phone calls between Brian Heaston (City of Bozeman) and Brent Zundel (Department), dated May 7 – 8, 2018, confirming measurements, period of use, and project completion timeline. Information within the Department’s Possession/Knowledge • 1953 Gallatin County Water Resources Survey (Aerial Photographs from 1947, Field Mapping, Field Notes, and Published Survey). • USDA Aerial Photos (1979, 1995, 2005). • Farmer’s Canal Company Articles of Incorporation. • “Flow Rates to Accomplish Mitigation,” notes from Troy Benn (Department), dated November 11, 2015, meeting with Deborah Stephenson (DMS), indicating mitigation flow rates and periods of diversion. • Analysis of existing water rights on Aajker and Baxter Creeks, spreadsheet by Troy Benn (Department). • February 5, 2016, Irrigation Change Application Technical Report by Brent Zundel (Department). • Revised January 12, 2018, Irrigation Change Application Technical Report by Brent Zundel (Department). • The Department also routinely considers the following information. The following information is not included in the administrative file for this Application, but is available upon request. Please contact the Bozeman Regional Office at 406-586-3136 to request copies of the following documents. o “Policy Memo – Return Flows” o “DNRC Consumptive Use Methodology” Memorandum o “Development of standardized methodologies to determine Historic Diverted Volume” Memorandum Revised 07-2016 Preliminary Determination to Grant Page 4 of 52 Application to Change Water Right No. 41H 30103245 The Department has fully reviewed and considered the evidence and argument submitted in this Application and preliminarily determines the following pursuant to the Montana Water Use Act (Title 85, chapter 2, part 3, part 4, MCA). PRELIMINARY MATTERS This Application is the second of two recent change applications for the three surface water and the four groundwater rights involved. The original application, 41H 30102910 (“Norton-Bostwick”), was received June 4, 2015; the present application (“Norton-Bozeman”) was received August 10, 2015. The intent was to process both applications concurrently, since they proposed to change the full volume available under all rights in two steps. Given high development pressures and multiple amendments to the applications, the first application was prioritized. A Preliminary Determination to Grant for Norton- Bostwick was issued July 14, 2017. Processing of the present Application was affected by three Amendments submitted. The first Amendment incorporated the groundwater claims into the application, and the latter two Amendments reduced the transferable volume of water due to ownership issues. These Amendments are discussed at length in the Preliminary Determination below. WATER RIGHTS TO BE CHANGED FINDINGS OF FACT Subject Water Rights 1. The Applicant seeks to change Water Right Claims 41H 30023118, 41H 30023119, and 41H 30023120. Table 1, below, summarizes the rights proposed for change as currently reflected in the Department’s water rights database. All three water rights (the “subject rights”) are fully supplemental, claiming irrigation on the same 137.90 acres. Water is diverted from the West Gallatin River at the Farmer’s Canal headgate and conveyed to the place of use through the Farmer’s Canal and the E. Minder Lateral. Each right has a unique priority date, and the combined flow rate of all three claims is 1,096.43 GPM (2.44 CFS). Claims 41H 30023118 and 30023119 have the same period of use and period of diversion from 6/1 – 10/31, while 41H 30023120 is from 5/1 – 10/1. Revised 07-2016 Preliminary Determination to Grant Page 5 of 52 Application to Change Water Right No. 41H 30103245 Table 1: Subject Rights Proposed for Change Water Right No. Purpose Source Flow Rate Period of Use Point of Diversion1 Place of Use Priority Date Acres (41H) ( – ) ( – ) (GPM) ( – ) ( – ) ( – ) ( – ) (ac) 30023118 Irrigation West Gallatin River 370.53 6/1 – 10/31 SWNWNW, Sec. 11, T03 S, R04 E E½SW, W½SE, SENW, SWNE, Sec. 9, T02 S, R05 E 10/15/1866 137.90 30023119 167.86 6/1 – 10/31 6/15/1881 137.90 30023120 558.04 5/1 – 10/1 6/1/1867 137.90 Notes: 1Farmer’s Canal headgate. This table reflects the water rights after the Water Court proceedings described in the Historical Use Section of this document, but the figures above include the portions of the water rights changed under related Change Authorization 41H 30102910 (Norton-Bostwick). 2. The three subject water rights; 41H 30023118, 41H 30023119, and 41H 30023120; derive from 2006 splits of parent claims 41H 138901-00, 41H 138900-00, and 41H 9295-00, respectively. The place of use of 41H 9295-00 was changed to the Norton Ranch in 1988. Three child rights; 41H 30069703, 41H 30069704, and 41H 30069705; were created from the subject water rights in a 2015 split. The Applicant submitted Divided Interest Ownership Update Forms on December 12, 2016, to split off an additional 0.73 acres. The 1988 place of use change, 2006 split, 2015 split, and 2016 split are addressed in greater detail in the Historical Use Section. Groundwater Claims 3. The original Application as filed by the Applicant included the retirement of four water rights (the “groundwater claims”) as part of the plan to prevent adverse effect from the proposed change. While the four groundwater claims were part of the correct and complete change application and analysis contained therein, the Applicant proposed to withdraw the associated groundwater rights rather than obtain a change authorization for those rights. The Applicant submitted a June 7, 2016, Amendment to this Application. The Amended Application proposes to obtain a change authorization for the groundwater claims 41H 138898-00, 41H 138899-00, 41H 138902-00, and 41H 138903-00 in order to prevent adverse effect to other appropriators due to a loss of return flows. Although a separate change application would usually be required for the four groundwater claims pursuant to Rule 36.12.1901(7), ARM, under the limited procedural circumstances of this case, where the original application included Revised 07-2016 Preliminary Determination to Grant Page 6 of 52 Application to Change Water Right No. 41H 30103245 analysis of these groundwater rights as part of the proposed change and was accepted as correct and complete, the proposed change of the groundwater rights will be analyzed as part of the Amended Application. 4. These four claims were filed for controlled subirrigation of groundwater and waste and seepage from an unnamed tributary of Baxter Creek. Their originally claimed place of use overlapped with that of the subject water rights. The Applicant provided substantial and credible evidence that these claims were exercised independently on a separate place of use located in the SWNE and portions of the N½NWSE of Section 9, T02 S, R05 E. Furthermore, the Applicant filed a Motion to Amend with the Montana Water Court on April 29, 2016, to clarify the above-described place of use of the groundwater claims, the place of use of the subject water rights, and the lack of a supplemental relationship between the subject water rights and the groundwater claims. The Motion to Amend was adopted in two different Master’s Reports dated November 16, 2016, and December 21, 2016. The place of use and independent operation of the groundwater claims is analyzed in greater detail in the Historical Use Section. The June 7, 2016, Amendment to the Application proposed to include these groundwater claims as part of the current Application. Table 2, below, reflects the elements of groundwater claims proposed for change. Table 2: Groundwater Claims Proposed for Change Water Right No. Purpose Source of Water Flow Rate Period of Use Point of Divers.1 Place of Use1 Priority Date Acres (41H) ( – ) ( – ) (CFS) ( – ) ( – ) ( – ) ( – ) (ac) 138898 Irrigation Unnamed Tributary of Baxter Creek; Waste & Seepage, Unnamed Tributary of Baxter Creek 1.21 6/1 – 10/31 SWNWSE SWNE, SENW, NWSE 9/15/1919 43.22 138899 Waste & Seepage, Unnamed Tributary of Baxter Creek 1.21 6/1 – 10/31 9/15/1919 43.22 138902 1.21 6/1 – 10/31 9/15/1919 43.22 138903 1.21 6/1 – 10/31 SESWNE 9/15/1919 43.22 Notes: 1All Section 9, T02 S, R05 E, Gallatin County. Revised 07-2016 Preliminary Determination to Grant Page 7 of 52 Application to Change Water Right No. 41H 30103245 5. The place of use was also served by Farmer’s Canal shares. The Applicant addressed how the subject water rights, Farmer’s shares, and groundwater claims were operated in a discussion of historical use. See the Historical Use Section. 6. The place of use of right 41H 9295-00 was moved in Change Application 41H 929502, which was completed in 1988. Right 41H 30023120 was subsequently split from parent right 41H 9295-00 in 2006. The verification process was begun when the Notice of Completion was received but never finalized, so this change authorization was certified on March 1, 2016, using a February 24, 2000, Report of Findings; information in the file; and aerial imagery available to the Department. None of the other subject water rights or groundwater claims has been subject to a change authorization, except for the concurrently processed Norton-Bostwick Change Application 41H 30102910, discussed in the Preliminary Matters section. The Farmer’s Canal water rights have been subject to a previous change, but that change does not directly affect the historical use discussion for this Application. CHANGE PROPOSAL FINDINGS OF FACT 7. The Applicant proposes to change the place of use of, add a place of storage to, and expand the period of use of the subject water rights: 41H 30023118, 41H 30023119, and 41H 30023120. They propose to change the place of use of 103.55 acres of historical irrigation at the Norton Ranch to 58.86 acres of new irrigation at the proposed City of Bozeman Sports Complex. The Norton Ranch was historically irrigated in Section 9, T02 S, R05 E, Gallatin County; the City of Bozeman Sports Complex is located in Section 3, T02 S, R05 E. See Figure 1, on the next page, for an overview of the proposed changes. Revised 07-2016 Preliminary Determination to Grant Page 8 of 52 Application to Change Water Right No. 41H 30103245 Figure 1: Overview map showing the proposed changes. Application Exhibit 40. 8. The point of diversion will remain the Farmer’s Canal headgate in the SWNWNW of Section 11, T03 S, R04 E. Water will continue to be diverted into Farmer’s Canal, but instead of being diverted into the E. Minder Lateral, it will now be diverted into the Maynard Border Ditch, which is located approximately one mile down-ditch in the Farmer’s Canal relative to the E. Minder. Water will then be conveyed approximately 1.5 miles down the Maynard Border Ditch to the Maynard Border Pipeline. From there, a valve will direct water to the proposed irrigation reservoir, and water will be applied to the new Sports Complex place of use via a pumping facility. 9. A place of storage is proposed at the Sports Complex. Submitted designs for the irrigation reservoir indicate that it would have a surface area of 2 acres, a maximum depth of 15 feet, and a capacity of 14.3 AF. The operation of the reservoir includes pumping directly from the reservoir to irrigate the Revised 07-2016 Preliminary Determination to Grant Page 9 of 52 Application to Change Water Right No. 41H 30103245 Sports Complex, and the water stored in the reservoir is part of the City’s irrigation demand. The only additional water consumed by the pond is the surface evaporation of 6.30 AF. In a May 7, 2018, phone call between the City of Bozeman and the Department, the City clarified that the irrigation reservoir will be unlined. 10. The Application originally proposed to expand the period of use of the subject water rights to March 1 through November 30. The period of diversion for each right would remain unchanged. In May 7 – 8, 2018, emails and phone calls, the City of Bozeman confirmed that they will begin diversion of water under the subject water rights on May 1, the earliest date at which direct flow delivery of the subject water rights could begin. The City owns shares in Middle Creek Reservoir, which supplies a significant portion of their municipal demand. These shares have year-round periods of use and diversion and could be used in the early season if needed. The end date for the period of use will be November 30. The expanded period of use would allow the City of Bozeman to apply stored water to the Sports Complex as climatic conditions and irrigation requirements warrant and allow them additional flexibility in their irrigation of the Sports Complex. In the same conversation, the City requested a 20-year period to complete this project, as opposed to the 15 years originally requested. 11. The water associated with 26.4 acres of the subject water rights and 8.78 acres of the groundwater claims was changed under related Change Application No. 41H 30102910 (Norton-Bostwick). 12. On June 7, 2016, the Department received an Amendment to the Application that proposed to modify the Application to include the four groundwater claims as a part of the change. The Application, as originally received, proposed to retire the groundwater claims in order to mitigate any adverse effect caused by the loss of return flows to Aajker and Baxter Creeks due to the retirement of the historical irrigation under the subject water rights. The Amendment proposes to include the groundwater claims as part of the change. Their purpose, point of diversion, and place of use would be changed. The new purpose is mitigation. The new point of diversion and place of use for these rights will be the same; they will be two points, one on Aajker Creek and one on Baxter Creek, at the downstream end of Norton Properties, at a likely point of connection between groundwater and surface water. These points are located in the NWSENW and NESWNE of Section 9, T02 S, R05 E, for Aajker and Baxter Creeks, respectively. Instead of being diverted for irrigation, water from the groundwater claims will be left undiverted in the ground and available to downstream users. Revised 07-2016 Preliminary Determination to Grant Page 10 of 52 Application to Change Water Right No. 41H 30103245 CHANGE CRITERIA 13. The Department is authorized to approve a change if the applicant meets its burden to prove the applicable § 85-2-402, MCA, criteria by a preponderance of the evidence. Matter of Royston, 249 Mont. 425, 429, 816 P.2d 1054, 1057 (1991); Hohenlohe v. DNRC, 2010 MT 203, ¶¶ 33, 35, and 75, 357 Mont. 438, 240 P.3d 628 (an applicant’s burden to prove change criteria by a preponderance of evidence is “more probably than not.”); Town of Manhattan v. DNRC, 2012 MT 81, ¶8, 364 Mont. 450, 276 P.3d 920. Under this Preliminary Determination, the relevant change criteria in §85-2-402(2), MCA, are: (2) Except as provided in subsections (4) through (6), (15), (16), and (18) and, if applicable, subject to subsection (17), the department shall approve a change in appropriation right if the appropriator proves by a preponderance of evidence that the following criteria are met: (a) The proposed change in appropriation right will not adversely affect the use of the existing water rights of other persons or other perfected or planned uses or developments for which a permit or certificate has been issued or for which a state water reservation has been issued under part 3. (b) The proposed means of diversion, construction, and operation of the appropriation works are adequate, except for: (i) a change in appropriation right for instream flow pursuant to 85-2-320 or 85-2-436; (ii) a temporary change in appropriation right for instream flow pursuant to 85-2-408; or (iii) a change in appropriation right pursuant to 85-2-420 for mitigation or marketing for mitigation. (c) The proposed use of water is a beneficial use. (d) The applicant has a possessory interest, or the written consent of the person with the possessory interest, in the property where the water is to be put to beneficial use or, if the proposed change involves a point of diversion, conveyance, or place of use on national forest system lands, the applicant has any written special use authorization required by federal law to occupy, use, or traverse national forest system lands for the purpose of diversion, impoundment, storage, transportation, withdrawal, use, or distribution of water. This subsection (2)(d) does not apply to: (i) a change in appropriation right for instream flow pursuant to 85-2-320 or 85-2-436; (ii) a temporary change in appropriation right for instream flow pursuant to 85-2-408; or (iii) a change in appropriation right pursuant to 85-2-420 for mitigation or marketing for mitigation. 14. The evaluation of a proposed change in appropriation does not adjudicate the underlying right(s). The Department’s change process only addresses the water right holder’s ability to make a different use of that existing right. E.g., Hohenlohe, at ¶¶ 29-31; Town of Manhattan, at ¶8; In the Matter of Application to Change Appropriation Water Right No.41F-31227 by T-L Irrigation Company (DNRC Final Order 1991). Revised 07-2016 Preliminary Determination to Grant Page 11 of 52 Application to Change Water Right No. 41H 30103245 HISTORICAL USE AND ADVERSE EFFECT FINDINGS OF FACT – Historical Use Background Subject Water Rights 15. The place of use in this change has a fairly complex history with water. Prior to July 1, 1973, use involved two claims and shares from the Farmer’s Canal. An opportunity to buy an additional senior water right to ensure full-season irrigation arose in the 1980s. A change to move the place of use of this senior right to the Norton field was completed in 1988, at which point all three of the subject water rights were being exercised on the Norton place of use. This significantly changed the water use on the field: The shares were no longer necessary, though the Applicant and the Applicant’s predecessors retained the shares after completing this change until the year 2006. Due to this change, a decision has been made to focus the historical use analysis and to calculate historical use from the completion of the change to present day. Because all three rights were comingled and operated as part of the same system, historical consumptive use is calculated as of the 1988 completion of the change. Full historical use, going back to pre-July 1, 1973, is briefly analyzed to confirm that no expansion occurred. Groundwater Claims 16. The four groundwater claims included in this change were exercised on a separate place of use of 43.22 acres and operated with an independent irrigation system composed of tile drains, sunken concrete headgates, and drain ditches, which allowed for control of the groundwater. Because these rights represent historical claims that have not been subject to any previous changes – except for the concurrently processed Norton-Bostwick Change Application 41H 30102910, discussed in the Preliminary Matters section – and because their irrigation system was operated independently from that of the subject water rights, historical use is analyzed prior to July 1, 1973. Point of Diversion and Means of Conveyance Subject Water Rights 17. The source of water for the subject place of use has always been the West Gallatin River. Rights 41H 30023118 and 41H 30023119 have always historically been diverted into the Farmer’s Canal and conveyed to this place of use. Water right 41H 30023120 served a different place of use and was conveyed through the West Gallatin (Kleinschmidt) Canal until a 1988 change. The goal of this change was to procure more senior water for full season irrigation. This water was conveyed through the Revised 07-2016 Preliminary Determination to Grant Page 12 of 52 Application to Change Water Right No. 41H 30103245 Farmer’s Canal to the current place of use after the 1988 change authorization approval and subsequent notice of completion. 18. Water was conveyed 7.9 miles in the Farmer’s Canal. The Farmer’s Canal headgate is located in the SWNWNW of Section 11, T03 S, R04 E. The West Gallatin River is a major source of irrigation water in the Gallatin Valley; typically, the district court appoints a water commissioner every year to administer water rights. Likewise, the Farmer’s Canal is a major irrigation canal in the Valley and employs a ditch rider. Water entering the Farmer’s Canal is measured by two 10-foot Parshall flumes, located approximately 300 feet down the ditch from the headgate. In a clarification submitted with the June 7, 2016, Amendment, George Alberda, the current West Gallatin Water Commissioner, and Bill Tatarka, President of the Farmer’s Canal Company, estimate the capacity of the Farmer’s Canal at approximately 250 CFS. The Department’s historical records (Water Resource Survey notes) also indicate a capacity of up to 250 CFS. Records provided by Mr. Alberda and submitted with the Application showed measurements for 2005, 2006, 2007, 2009, 2010, 2012, 2013, and 2014 (more records are available upon request, but these last 10 years are sufficiently representative for historical water use analysis, encompassing both wet and dry years). According to those records, Farmer’s Canal diversion water was measured at a maximum of 103.425 CFS during those eight years. According to the Department’s records, 50 rights are conveyed in the Farmer’s Canal. Farmer’s Canal conveys approximately 37 CFS of privately held, recorded water rights with a more senior priority date to Farmer’s Canal water rights (pre-1883). Farmer’s Canal also carries 275 AF of Middle Creek storage water. Farmer’s Canal recorded water rights, ranging in priority from 1883 through 1892, account for approximately 234.5 CFS. 19. Water was conveyed through the Farmer’s Canal to the E. Minder Lateral. At this secondary point of diversion, water was diverted into the lateral via a headgate in the NWNESW of Section 16, T02 S, R05 E. Water was conveyed approximately 3,600 feet through the lateral and then applied to the field. According to 2014 measurements and modeling conducted by Spanish Peaks Engineering & Consulting LLC, the E. Minder Lateral has a capacity of 6.3 CFS and was flowing at full capacity on August 7, 2014. A Parshall flume and staff gage measure flow in E. Minder. According to the Department’s records and information provided in the Application, the E. Minder conveys the subject water rights (2.45 CFS), Norton’s Farmer’s shares (7.81 CFS), and Kamp’s Farmer’s shares (3 2/3 shares at 89 2/7 MI each = 8.18 CFS). Aerial imagery and materials related to the 1988 change application indicate that the capacity of the E. Minder Lateral did not change between 1973 and 2006. Beginning in 2006, the Applicant began to Revised 07-2016 Preliminary Determination to Grant Page 13 of 52 Application to Change Water Right No. 41H 30103245 subdivide portions of the Norton Ranch. When describing the adequacy of the proposed means of diversion and conveyance in 1988, the Applicant stated that the change would only “lengthen the period of use of existing facilities, without increasing the maximum amount they are required to handle.” Therefore, the measurements conducted in 2014 accurately reflect the historical capacity of the E. Minder Lateral and demonstrate that it was capable of conveying the full flow rate of the subject water rights. Groundwater Claims 20. The sources of water for the groundwater claims are an unnamed tributary of Baxter Creek and waste and seepage, unnamed tributary of Baxter Creek, all considered groundwater. The points of diversion are two sunken concrete box headgates used to control the tile drain system. The means of diversion and conveyance for these claims are a tile drain system, sunken concrete headgates, and drain ditches. The Applicant provided a photograph of a concrete headgate used to control the drain ditch system, Farm Service Administration (FSA) maps, and maps of the historical place of use showing the location of infrastructure associated with the groundwater claims. 21. The diversion and conveyance system consists of the drain tiles, headgates, and drain ditches. According to the Applicant, the underground concrete headgates are approximately 4 feet wide by 6 feet long and are buried 5 to 6 feet below the ground surface. This is supported by two notarized Notices of Water Right, one from 1920 and the other from 1934, that are included in the claim files. Water was collected in the drain tile and drain ditch system and the headgates were closed to back up groundwater in order to irrigate portions of the property. The 1934 Notice of Water Right further claims that; in addition to the drain tiles, headgates, and drain ditches; a pump “sufficient in size to carry” the claimed flow rate was also used to divert groundwater. The means of diversion and conveyance allowed the Applicant to exercise control over the groundwater for the purpose of irrigation. Priority Date Subject Water Rights 22. Water right 41H 30023118 is based upon a water right previously decreed to A.D. Weaver for 467 miner’s inches (MI) with an October 15, 1866, priority date in the West Gallatin River Decree, Bell v. Armstrong, Case No. 3850, Gallatin County, dated October 7, 1909. Water right 41H 30023119 is based upon a water right previously decreed to D.P. Stone for 80 MI with a June 15, 1881, priority date also in the 1909 West Gallatin River Decree. Water right 41H 30023120 is based upon a water right previously decreed to O.T. Crawford for 101 MI with a June 1, 1867, priority date, again in the 1909 West Gallatin River Decree. Revised 07-2016 Preliminary Determination to Grant Page 14 of 52 Application to Change Water Right No. 41H 30103245 23. Provided by West Gallatin Water Commissioner George Alberda, Exhibit 24 in the Application materials is a list of calls from 2005 to 2014 that indicates the date at which water rights with varying priority dates were cut off. The subject rights are of sufficient seniority such that they were not subject to a call at any time during those 10 years. Furthermore, the Applicant stated that these three rights provide full-service irrigation and have never been subject to a call for water. The Department has no knowledge of a call for water being made against these rights. Groundwater Claims 24. The four groundwater claims are filed historical rights with a claimed priority date of September 15, 1919. The Application states that “[i]n 1919, drain tile was installed to control the groundwater on the property.” The priority date claimed on the Statement of Claims when they were filed was September 15, 1919, and the files include copies of a notarized Notice of Water Right indicating that water was first put to use under these rights on September 15, 1919. The Gallatin County Water Resources Survey confirm historical use of the groundwater claims as of the March 4, 1953, date that the Norton place of use was surveyed. The survey includes notes regarding an appropriation of “Drainage and Waste Water” by John E. Norton and an appropriation of “Drainage” by Roger Huffine. The Montana Water Court decreed a priority date for these claims of September 15, 1919. Place of Use Subject Water Rights 25. Prior to 1988, claims 41H 138900-00 and 41H 138901-00 were used to irrigate the Norton Ranch in Sections 8 and 9, T02 S, R05 E. In 1988, 41H 9295-00 was moved from its place of use on the Sime Ranch in Sections 25, 30, and 36 of T02 S, R04 E, to the current place of use in Sections 8 and 9 via change application 41H 929502, which was completed in 1988. The verification process was begun at that time but never finalized, so this change authorization was certified on March 1, 2016, using a February 24, 2000, Report of Findings; information in the file; and aerial imagery available to the Department. Portions of the Norton Ranch were sold off, so the Montana Water Court split the claims in Case 41H-412. The three rights proposed for change are 41H 30023118, 41H 30023119, and 41H 30023120, which have a claimed a place of use of 237.27 acres. 26. Figure 2, on page 16, shows a map of the historical irrigated acres under the subject rights. Of the claimed place of use, only 140 acres were actually historically irrigated with the subject water rights after completion of the 1988 change. The Applicant asserts that the rest of the claimed place of use was not irrigated under the subject rights. This assertion is supported by FSA maps from 2002 – 2014 and an Revised 07-2016 Preliminary Determination to Grant Page 15 of 52 Application to Change Water Right No. 41H 30103245 affidavit from longtime neighbor, farmer, and former Montana State University Agricultural Experiment Station employee Al Lien, who is knowledgeable of irrigation practices on the Norton Ranch and in the greater Gallatin Valley. The FSA maps delineate field boundaries that align with the Applicant’s map of which fields were irrigated with Big Gun sprinkler systems and wheel line sprinkler systems. Furthermore, some of the FSA maps call out portions of the SENW of Section 9 as being “to [sic] wet to seed” or being “wet!!!”. In his affidavit, Mr. Lien claims that the “northern and southeastern portions of the property located approximately in the SENW, SWNE, NWNWSE and SESWSE of section 9 … was [sic] historically not irrigated with water from Farmer’s Canal due to subirrigation.” Four groundwater claims, discussed in more detail later in this document, were historically used for irrigation on much of the acreage in the northern portion of the place of use but were operated independently and did not overlap with the actual, 140-acre place of use of the subject rights. The groundwater claims were operated with a system of drain tiles, underground concrete box headgates, and drain ditches. The Applicant filed a Motion to Amend with the Montana Water Court on April 29, 2016, to reflect this information. The Motion to Amend was adopted in two different Master’s Reports dated November 16, 2016, and December 21, 2016. Revised 07-2016 Preliminary Determination to Grant Page 16 of 52 Application to Change Water Right No. 41H 30103245 Figure 2: Map of the claimed place of use and the place of use that was actually historically irrigated under the subject water rights. Application Exhibit 5. 27. Between 2006 and 2014, portions of the Norton Ranch were subdivided, and the appurtenant water rights were inadvertently conveyed to individual owners. Not all of these rights were re-acquired, so three child rights; 41H 30069703, 41H 30069704, and 41H 30069705; were created to represent the 2.73 acres of the claimed place of use that were conveyed to multiple individual owners. Of the 140 acres that were historically irrigated, 1.37 actual irrigated acres (of the claimed 2.73 acres) were conveyed to the three child rights. Therefore, 138.63 historically irrigated acres remained with the subject water rights. After this process was completed, the Applicant failed to file a number of the deeds involved. The proportionate share of the water rights was conveyed to the lot owners by operation of law. The Applicant submitted Form 641: Divided Interest Ownership Update to the Department on December 12, 2016, to split off another 0.73 acres from the subject water rights. Thus, the remaining acreage under these water Revised 07-2016 Preliminary Determination to Grant Page 17 of 52 Application to Change Water Right No. 41H 30103245 rights is 140 – 1.37 – 0.73 = 137.90 acres. Of this acreage, the water corresponding to 26.40 acres was changed in the related Norton-Bostwick Change Application. No groundwater claims are available to mitigate the lost return flows associated with 7.95 acres, so the acreage remaining for the City of Bozeman Sports Complex is 103.55 acres (137.90 – 26.40 – 7.95 = 103.55 acres). The 137.90 acres are located within the E½SW, W½SE, SENW, and SWNE of Section 9. On April 29, 2016, the Applicant filed a Motion to Amend with the Montana Water Court, clarifying the place of use of the subject water rights as the 138.63 acres described previously. This was reduced, as stated, by a further 0.73 acres. For further discussion, see the Supplemental Rights and Non-Use Sub-Section in this Historical Use Section. 28. The Gallatin County Water Resources Survey (1953) and USDA aerial photos (1979, 1995, and 2005) confirm irrigation on the historical 137.90 acres. Rights 41H 30023118 and 41H 30023119 have historically been exercised on the acreage since appropriation. The Water Resources Survey provides evidence that the field was irrigated under these rights prior to July 1, 1973. Right 41H 30023120 was used on the place of use after being changed in 1988 to supplement the existing rights and extend the irrigation period for low-water years, as described elsewhere in this document. USDA aerial photos, additional aerial photos available to the Department, FSA maps, an affidavit from long-time neighbor Al Lien, and interviews of the previous two farmers of the property (from 1996 – 2011) clearly indicate that the place of use has been irrigated up until the present. Groundwater Claims 29. As originally filed, the groundwater claims each listed different acreages and were supplemental to the subject water rights. The Applicant provided substantial and credible evidence that these claims were exercised independently on a separate place of use of 44.50 acres located in the SWNE and portions of the N½NWSE of Section 9, T02 S, R05 E. The Applicant provided a map of the infrastructure, showing the location of the Big Gun sprinkler system; the wheel line sprinkler system; and the tile drain, sunken headgate, and drainage ditch system – and the areas that were irrigated under each. Interviews conducted by the Applicant’s consultant with two previous farmers of the property, Pat Ward (1996 – 2002) and Josh Jones (2003 – 2011) indicated that the groundwater system was operated on the northern third of the property (the SWNE and N½NWSE of Section 9). Longtime neighbor and former MSU Agricultural Experiment Research Station employee Al Lien submitted an affidavit supporting the historical use of the groundwater claims in this area. The Gallatin County Water Resources Survey and associated field notes confirm that a groundwater appropriation by John E. Norton was in use at the time of the 1953 field inspection. Historical aerial imagery; as well as later imagery from 1981, 1995, and Revised 07-2016 Preliminary Determination to Grant Page 18 of 52 Application to Change Water Right No. 41H 30103245 2001; also supports historical use of the groundwater claims on 43.22 acres. The Applicant filed a Motion to Amend with the Montana Water Court on April 29, 2016, to clarify the place of use of the groundwater claims. The Motion to Amend was adopted in two different Master’s Reports dated November 16, 2016, and December 21, 2016. 30. As the Norton Ranch was subdivided and sold, the Applicant inadvertently conveyed portions of the groundwater claims to individual lot owners, as was done with the subject water rights. See Finding of Fact 27 for a full discussion. After the 2015 and 2016 splits, the acreage remaining under the groundwater claims is 43.22 acres. Of this acreage, the water corresponding to 8.78 acres was changed in the related Norton-Bostwick Change Application. The remaining acreage is 43.22 – 8.78 = 34.44 acres. Periods of Diversion and Use Subject Water Rights 31. The period of diversion and use for 41H 30023118 and 41H 30023119 is June 1 – October 31, as decreed in Bell v. Armstrong, Case No. 3850, Gallatin County, dated October 7, 1909. The period of diversion and use for 41H 30023120 is May 1 – October 1, as decreed in Bell v. Armstrong, Case No. 3850, Gallatin County, dated October 7, 1909. These same periods of diversion and use are reflected in the 1985 Temporary Preliminary Decree issued by the Montana Water Court for the Gallatin River Basin and in the Priority Date Indices published as part of the West Gallatin Enforcement Project. The Application materials included interviews with the previous two farmers of the property (from 1996 – 2011) and long-time neighbor Al Lien, which confirmed that these rights have historically been exercised across their periods of use and diversion from May to October. 32. Prior to 2006, the entire place of use (claimed 480 acres) was associated with 3.5 Farmer’s Canal shares. According to information in the Application and the Bylaws of the Farmer’s Canal Company, each share is worth 89 2/7 MI, for a total of 7.81 CFS. The property split in 2006, gave the Applicant approximately 3.91 CFS. Farmer’s shares have 1890, 1891, and 1892 priority dates and are usually curtailed by early July, according to call records from Water Commissioner George Alberda. Therefore, these shares were historically exercised in the early season, until approximately the middle of July. Once the change took place in 1988, the shares were not required for any portion of the irrigation. See the Historical Consumptive Use Sub-Section below for further discussion. Revised 07-2016 Preliminary Determination to Grant Page 19 of 52 Application to Change Water Right No. 41H 30103245 Groundwater Claims 33. The periods of diversion and use for the four groundwater claims are from June 1 – October 31. These periods of diversion and use are the same as that for subject water rights 41H 30023118 and 41H 30023119. 34. While the irrigation systems for the subject water rights and the groundwater claims were operated independently, Pat Ward and Josh Jones, previous farmers of the property from 1996 – 2011, indicated in the Application materials that the groundwater irrigation system was operated during the same time periods as the surface water rights were being exercised. The Application materials included interviews with Pat Ward, Josh Jones, and long-time neighbor Al Lien, which confirmed that these rights have historically been exercised across their periods of use and diversion. Flow Rate Subject Water Rights 35. Water was historically diverted from the West Gallatin River into the Farmer’s Canal and conveyed 7.9 miles to the E. Minder lateral (see Figure 3, on the next page). Once in the lateral, water was conveyed 3,600 feet to the Applicant’s pump, which supplied the sprinkler system. As discussed, Farmer’s shares were held by the Applicant until 2006, but the shares did not substantively contribute to irrigation after the change authorization in 1988. See the Historical Consumptive Use Sub-Section for further discussion of the role of the shares. Pre-2006 data and post-2006 data show that the ditch rider delivered the full flow rate of the private water rights to the secondary diversion point (E. Minder Lateral). In this Application, the subject water rights are not credited with any conveyance losses along Farmer’s Canal. The Applicant chose to attribute only late-season losses in the E. Minder Lateral to the subject water rights because the shares provided carriage water in the early season. Using the Department’s 2012 Historical Diverted Volume memorandum, the Applicant calculated a value of 9.8 AF for the subject rights’ late-season conveyance losses in E. Minder. Travel distance in the lateral was 3,600 feet. The Montana Bureau of Mines and Geology (MBMG) calculates average ditch loss in the Gallatin Valley as approximately 1.1 CFS/mile. Spreading the 9.8 AF of E. Minder conveyance loss across the 3,600-foot lateral over the 36-days of late season irrigation results in a loss rate of 0.20 CFS/mi, which is reasonable when compared with the Valley-wide MBMG estimate above. The pump has a capacity of 800 GPM, which is based on a 75-HP Cornell pump (model 5WB75-2). The total combined flow rate under these rights is 1,096.43 GPM. With the flow rate of the rights minus the flow rate lost to conveyance in the lateral being available at the pump station, the excess water was discharged to Aajker Creek on the Revised 07-2016 Preliminary Determination to Grant Page 20 of 52 Application to Change Water Right No. 41H 30103245 west edge of the property. In order to function properly, sprinkler irrigation systems typically require water to be available at least in the amount of their operating flow rate, if not more. In this instance, where the Applicant was pumping out of a ditch lateral, it is reasonable that a greater flow rate was required in the ditch than the capacity of the sprinkler system itself in order to ensure that the system functioned properly and that no air was introduced due to a lack of water. The excess water that was not diverted by the pump was then spilled to Aajker Creek. Therefore, the full claimed flow rate of 1,096.43 GPM between the three subject rights is reasonable and required for the beneficial use of irrigation. Figure 3: Map of historical place of use and conveyance system for the subject water rights. Water is diverted from the West Gallatin into Farmer’s Canal and thence into the E. Minder Lateral. Water is applied to the field from the lateral, and excess water is discharged to Aajker Creek. Application Exhibit 30. Revised 07-2016 Preliminary Determination to Grant Page 21 of 52 Application to Change Water Right No. 41H 30103245 Groundwater Claims 36. The Montana Water Court does not decree flow rates for natural subirrigation claims; however, water in this system has always been controlled by a system of drain tiles, sunken concrete headgates, and drain ditches, as indicated by the evidence in the file and the information submitted in this Application. Based on this information, the Water Court decreed the claimed 1.25 CFS for each of these claims prior to the splits received. (The flow rate for the remaining 43.22 acres is 1.21 CFS.) According to information and evidence submitted in the Application, the four groundwater claims are supplemental and employ the same infrastructure to divert water. The claim files for 41H 138902-00 and 41H 138903-00 indicate that a 500 GPM (1.11 CFS) pump was used to divert water. Pumps typically require water to be available at least in amount of their operating flow rate, if not more. In this instance, it is reasonable that the appropriator required water to be available slightly in excess of the pump’s operating flow rate so as to ensure the system functioned properly and to avoid introducing air into the pump. Therefore, a flow rate of 1.21 CFS is reasonable. Based on the available information, these four rights have an undivided interest in the remaining 1.21 CFS flow rate. Applying the Department’s adjudication guideline of 17 GPM per acre to the 43.22 acres that were historically irrigated with the groundwater claims results in 1.64 CFS. The claimed flow rates are below the Department’s guideline. The Application materials state that the sunken concrete headgates are approximately 4 feet by 6 feet, which would be sufficient to back up the claimed flow rate. Groundwater in the project vicinity is shallow (less than 6 feet) and abundant – the place of use is currently being subdivided for housing development and requires dewatering. The claimed flow rate of 1.21 CFS is reasonable for the beneficial use of irrigating 43.22 acres. Historical Consumptive Use Subject Water Rights 37. 41H 30023120 was subject to Change Application 41H 929502, which moved the place of use for its parent right from the Sime Ranch in Sections 25, 30, and 36 of T02 S, R04 E, to the current place of use on the Norton Ranch in Section 9, T02 S, R05 E. This change was completed in 1988, and the goal was to “supplement existing rights on the described land” and “extend the period of time this land will be irrigated,” as described by the Applicant in Change Application 41H 929502. Historical use is calculated for all three rights as of the date of completion of change 41H 929502 in 1988 because all three rights were historically exercised in conjunction on the same place of use and are therefore completely supplemental. The 1988 change did not constitute an enlargement of the parent right for 41H 30023120; rather, it allowed for full-season irrigation of the same historically irrigated acreage. Water rights 41H Revised 07-2016 Preliminary Determination to Grant Page 22 of 52 Application to Change Water Right No. 41H 30103245 30023118 and 41H 30023119 have been exercised on the place of use since appropriation (prior to the 1988 change and prior to the July 1, 1973, effective date of the Montana Water Use Act) as evidenced by aerial photos from 1947 and 1979. 38. The three subject water rights were historically used on the same acreage. As such, historical use has been quantified based on the total irrigated acreage. Each water right has been assigned historical use based on its flow rate proportional to the total flow rate of all three rights: 1,096.43 GPM. 39. These rights were historically used in conjunction with shares from the Farmer’s Canal Company. Prior to 1988, canal shares were more important in the operation of the irrigation system and likely provided substantial conveyance water. The explicit goal of the 1988 change was to extend the irrigation season. Farmer’s shares, as discussed previously, are typically cut off by early to mid-July, depending on the year. Based on the monthly breakdown of the crop Irrigation Water Requirements, the two rights that have always been exercised on the Norton Ranch (41H 30023118 and 41H 30023119) are capable of providing sufficient consumptive use for the historically irrigated acreage until mid- to late July. However, the shares likely played an important role in providing carriage water. The parent right for 41H 30023120 was added to the place of use in the 1988 change to extend the irrigation season. The Applicant owned shares until 2006, but the shares did not provide any substantive water to the irrigation use after the 1988 change. The shares were typically curtailed in mid-July and are being credited in this Application with only early season conveyance losses. It is important to note that the shares were for both the place of use involved in this Application and the nearby place of use in Section 8 (the originally claimed place of use for the parent rights for the three subject rights is 480 acres in Sections 8 and 9). Furthermore, the ditch rider’s notes submitted with the Application show that management practices of the Farmer’s Canal were such that the full flow rate of the private water rights was delivered to the E. Minder Lateral even after the Applicant stopped purchasing shares in 2006. Therefore, all historical consumptive use can be attributed to the subject rights, but no conveyance loss for the Farmer’s Canal is credited to them. 40. The Applicant used the historical consumptive use rules in ARM 36.12.1902 to calculate historical consumptive use. The Bozeman Experiment Farm station irrigation water requirements for alfalfa were used, in addition to the 1973 – 2006 Gallatin County Management Factor and 10% irrecoverable loss for sprinklers. For the 137.90 acres that were historically irrigated, crop consumptive use was 178.23 AF. With 70% efficiency for a sprinkler system, 254.62 AF was applied to the field, so Revised 07-2016 Preliminary Determination to Grant Page 23 of 52 Application to Change Water Right No. 41H 30103245 the irrecoverable loss was 25.46 AF. The total historical consumed volume was therefore 203.69 AF. These values were confirmed by Department hydrologist/specialist Brent Zundel in the Technical Report. 41. The typical irrigation pattern was four 10-day sets to irrigate the entire place of use. A second irrigation of the field was conducted when alfalfa was grown. According to a description of the pattern of use provided by Pat Ward and Josh Jones, the E. Minder Lateral headgate was typically opened in May and water was applied until September and October. Given the pump capacity of 800 GPM and the volume applied to the field of approximately 255 AF, irrigation took place over approximately 72 days. Groundwater Claims 42. The Applicant provided substantial and credible evidence that the four groundwater claims were exercised on the same 43.22 acres as part of the same irrigation system. As these rights were exercised independently of the subject water rights and have not been subject to a change authorization, their historical use is evaluated prior to July 1, 1973. The historical consumptive use rules in ARM 36.12.1902 were employed with the Bozeman Experiment Farm station irrigation water requirements for alfalfa were used, the 1964 – 1973 Gallatin County Management Factor, and 5% irrecoverable loss for flood systems. With 65% efficiency for graded border flood irrigation, the field applied volume was 68.60 AF. The total volume consumed by 43.22 acres of crops was therefore 44.58 AF, with an additional 3.42 AF of irrecoverable loss, for a total of 48.00 AF of consumed volume. These values were calculated by Department hydrologist/specialist Brent Zundel in the Technical Report. 43. The four groundwater claims were historically used on the same acreage. As such, historical use has been quantified based on the total irrigated acreage. Each water right has been assigned an equivalent one-fourth portion of the historical use because the Applicant provided substantial, credible evidence that these rights were fully supplemental, comingled, dependent upon the same infrastructure, and exercised on the same 43.22 acres. Diverted Volume Subject Water Rights 44. The Applicant provided calculations for the diverted volume in Exhibit 10 of the Application and in an updated version of Exhibit 10. These calculations were analyzed in the Technical Report. The Applicant calculated the diverted volume using three components: (1) conveyance losses over the 72-day irrigation period, (2) excess water spilled to Aajker Creek, and (3) the volume applied to the field. Conveyance losses were calculated for two 36-day periods: (a) an early season when all rights are in priority (June – July 17) and Farmer’s shares were used for conveyance water and (b) a late season (July Revised 07-2016 Preliminary Determination to Grant Page 24 of 52 Application to Change Water Right No. 41H 30103245 18 – October) when only the Applicant’s subject water rights were still in priority. The Applicant calculated conveyance losses in the Farmer’s Canal and the E. Minder Lateral according to the Department’s 2012 historical diverted volume memo and attributed the losses to the subject water rights in proportion to the other rights and shares in the ditch. However, additional information presented in the Application indicates that the subject water rights did not contribute to ditch losses in the Farmer’s Canal. 45. While conveyance loss calculations represent a standard scenario, the Applicant has shown that, under the Farmer’s Canal management practices, the full flow rate of the subject rights is delivered at the E. Minder Lateral. This full flow rate was delivered both when shares were purchased prior to 2006 and after that year, when shares were no longer purchased. While the Farmer’s Canal might generously be delivering full flow now, future management has no guarantees. In this Application, the subject rights are not credited with any conveyance losses in Farmer’s Canal, either early or late season. In the early season, the shares provided all of the carriage water. By the late season, shares were no longer in priority, so the private water rights being conveyed through Farmer’s had to provide carriage water. However, records show that the ditch rider delivered the full flow rate of the subject rights to the E. Minder Lateral even in the late season, so the subject rights are not credited with any conveyance losses in this Application. With respect to conveyance losses in the E. Minder Lateral, shares provided early season carriage water, but the subject rights are credited with late season conveyance water along the E. Minder (9.8 AF). The Technical Report shows updated calculations for diverted volume. The diverted volume is calculated as the volume of water applied to the field plus the volume of water spilled to Aajker Creek plus the volume of water lost to conveyance in the E. Minder Lateral or, respectively, 254.62 AF + 87.18 AF + 9.8 AF = 351.60 AF. On July 12, 2016, the Applicant submitted “Revised Table 10 – Diversion Volume Calculations” to the Department, updating the diverted volume calculations. Groundwater Claims 46. For graded border systems with 0.75 – 1.5% slope, a standard scenario is 65% application efficiency. Therefore, the diverted volume is calculated as 68.60 AF using the Department’s standard methodology. Return Flows 47. The Technical Report found that the historical practices of irrigation on 137.90 acres under the subject rights would have resulted in the accrual of 50.95 AF to Aajker and Baxter Creeks. Under the retirement of 103.55 acres as proposed in this Application, 12.70 AF of return flows would continue to accrue. Therefore, 38.25 AF of return flows would no longer accrue as a result of this Application. The Revised 07-2016 Preliminary Determination to Grant Page 25 of 52 Application to Change Water Right No. 41H 30103245 additional acreage of 26.40 acres was retired in the concurrent Norton-Bostwick Change Application. 7.95 acres are not bing changed. The June 7, 2016, Amendment proposes to change the groundwater claims to mitigate any adverse effect from the loss of these return flows. See the Adverse Effect Section for further discussion. Supplemental Rights, Parent Rights, and Non-Use 48. See Figure 4, on the next page, for a map of the historical place of use and diversion and conveyance systems for the groundwater claims. Figure 5, on page 27, contrasts the claimed place of use for the groundwater rights and the place of use that was historically irrigated by the subject water rights. Groundwater claims 41H 138898-00, 41H 138899-00, 41H 138902-00, and 41H 138903-00 were originally supplemental to the subject water rights because their claimed places of use overlapped. However, the Applicant provided evidence that the groundwater claims were historically exercised independently on 43.22 acres in the SWNE and portions of the N½NWSE of Section 9. The Applicant filed a Motion to Amend with the Water Court on April 29, 2016, to clarify the above-described place of use of the groundwater claims and to remove the supplemental remarks. The Motion to Amend was adopted in two different Master’s Reports dated November 16, 2016, and December 21, 2016. Thus, the three subject water rights are supplemental to each other, and the four groundwater claims are supplemental to each other, but the subject rights are not supplemental to the groundwater claims. No overlap occurred between acreage irrigated under the groundwater claims and acreage irrigated under the subject water rights. Figure 6, on page 28, shows the location of the Big Gun sprinkler and the wheel line sprinkler systems that were used to irrigate the acreage under the subject water rights. Drain tiles were installed in 1919, and the Applicant provided photographs of underground concrete headgates used to control groundwater for irrigation. Interviews conducted by the Applicant’s consultant with two previous farmers of the property, Pat Ward (1996 – 2002) and Josh Jones (2003 – 2011) indicated that the groundwater system was operated independently on the northern third of the property (the SWNE and N½NWSE of Section 9). Furthermore, longtime neighbor and former MSU Agricultural Experiment Research Station employee Al Lien submitted an affidavit supporting the historical use of the groundwater claims in this area. FSA maps from 2002 – 2014 indicate high groundwater levels in this area. Finally, the Gallatin County Water Resources Survey and the associated field notes confirm historical use as of 1953, mentioning an appropriation of “Seepage and Waste Water” by John E. Norton and an appropriation of “Drainage [water]” by Roger Huffine. The field map produced by the Water Resources Survey indicates that private irrigation water, not water supplied by Farmer’s Canal, was used Revised 07-2016 Preliminary Determination to Grant Page 26 of 52 Application to Change Water Right No. 41H 30103245 on the groundwater claims’ place of use. Later aerial imagery from 1981, 1995, and 2001 further supports historical use on 43.22 acres. Figure 4: Map of historical place of use and system of tile drain ditches and headgates for the groundwater claims. Application Exhibit 48. Revised 07-2016 Preliminary Determination to Grant Page 27 of 52 Application to Change Water Right No. 41H 30103245 Figure 5: Map of claimed groundwater place of use and the place of use that was actually historically irrigated under the subject rights. Application Exhibit 11. Revised 07-2016 Preliminary Determination to Grant Page 28 of 52 Application to Change Water Right No. 41H 30103245 Figure 6: Location of Big Gun sprinklers and wheel line sprinklers, and the location of acreage irrigated under both systems. Application Exhibit 29. 49. Between 2006 and 2014, as portions of the place of use were subdivided and sold, the Applicant did not reserve the appurtenant water rights and, by operation of Montana law, inadvertently conveyed a proportionate share of the water rights to the lot owners. The Applicant sought reconveyance of the water rights from the lot owners; most agreed, but some did not respond, could not be located, or refused. The Applicant submitted Form 641: Divided Interest Ownership Update, and three separate child rights were created for those property owners: 41H 30069703, 41H 30069704, and 41H 30069705. The claimed place of use of these child rights is 2.73 acres, but of the place of use that was actually historically irrigated under these rights, only 1.37 acres were conveyed to the child rights, leaving a remainder of 138.63 acres. After this process, the Applicant failed to file a number of deeds, so the proportionate share was conveyed to these lot owners by operation of law. The Applicant again submitted Form 641: Divided Interest Revised 07-2016 Preliminary Determination to Grant Page 29 of 52 Application to Change Water Right No. 41H 30103245 Ownership Update to the Department on December 12, 2016, to split off another 0.73 acres from the subject water rights. The remaining acreage actually irrigated under the subject water rights is 140 – 1.37 – 0.73 = 137.90 acres. 50. The property was last fully irrigated nine years ago in 2006. Since this period is less than 10 years from the date of submission of this Change Application, non-use is not evaluated. Overview 51. Based on the findings above, historical use for the subject water rights is quantified in Table 3, below. Table 3: Historical Use of Subject Water Rights Water Right No. Purpose (Acres) Flow Rate Div. Volume Cons. Use Period of Use Point of Diversion Place of Use Priority Date (41H) ( – ) (GPM) (AF) (AF) ( – ) ( – ) ( – ) ( – ) 30023118 Parent 138901-00 Irrigation (137.90) 370.53 118.82 68.84 6/1 – 10/31 SWNWNW Sec. 11, T0 3S, R04 E (Farmer’s Canal headgate) E½SW, W½SE, SENW, SWNE, Sec. 9, T02 S, R05 E 10/15/1866 30023119 Parent 138900-00 Irrigation (137.90) 167.86 53.83 31.18 6/1 – 10/31 6/15/1881 30023120 Parent 9295-00 Irrigation (137.90) 558.04 178.95 103.67 5/1 – 10/1 6/1/1867 Total = 137.90 1,096.43 351.60 203.69 184 days (5/1 – 10/31) -- -- -- 52. Based on the findings above, historical use for the groundwater claims is quantified in Table 4, on the next page. Revised 07-2016 Preliminary Determination to Grant Page 30 of 52 Application to Change Water Right No. 41H 30103245 Table 4: Historical Use of Groundwater Claims Water Right No. Purpose (Acres) Flow Rate1 Div. Volume Cons. Use Period of Use Point of Diversion Place of Use Priority Date (41H) ( – ) (CFS) (AF) (AF) ( – ) ( – ) ( – ) ( – ) 138898-00 Irrigation (43.22) 1.21 17.15 12.00 6/1 – 10/31 SWNWSE, Sec. 9, T02 S, R05 E SWNE, SENW, NWSE, Sec. 9, T02 S, R05 E 9/15/1919 138899-00 Irrigation (43.22) 1.21 17.15 12.00 6/1 – 10/31 SWNWSE, Sec. 9, T02 S, R05 E 9/15/1919 138902-00 Irrigation (43.22) 1.21 17.15 12.00 6/1 – 10/31 SWNWSE, Sec. 9, T02 S, R05 E 9/15/1919 138903-00 Irrigation (43.22) 1.21 17.15 12.00 6/1 – 10/31 SESWNE, Sec. 9, T02 S, R05 E 9/15/1919 Total = 43.22 1.21 68.60 48.00 184 days (5/1 – 10/31) -- -- -- Notes: 1Undivided interest in the total flow rate of 1.21 CFS. FINDINGS OF FACT – Adverse Effect 53. The Applicant proposes to change the place of use of 103.55 of the 137.90 acres that were historically irrigated under the subject water rights in order to irrigate 58.86 new acres at the Sports Complex. Water will be pumped out of an irrigation reservoir with a capacity of 14.3 AF and a surface area of 2 acres. The irrigation demand includes the capacity of the reservoir. The only additional volume consumed by the reservoir will be evaporation of 6.30 AF. The purpose will remain irrigation. An additional 26.40 acres were changed in a concurrent application, 41H 30102910 (Norton-Bostwick). According to the Department’s Technical Report, return flows historically accrued approximately evenly to Aajker and Baxter Creeks, which are located on the western and eastern property boundaries, respectively. Groundwater in the project vicinity is shallow (less than 6 feet) and is hydraulically connected to Aajker and Baxter Creeks. 54. Return flows accrue within the same month as they were applied to the field because of the close proximity to and hydraulic connection with Aajker and Baxter Creeks and the need for tile drains in the Revised 07-2016 Preliminary Determination to Grant Page 31 of 52 Application to Change Water Right No. 41H 30103245 downflow field. Department hydrologist/specialist Brent Zundel performed the calculations and analysis for these return flows using Department methods. The following table, Table 5, summarizes the return flow analysis. Table 5: Return Flow Analysis Month ( – ) Return Flows under Historical Conditions on 137.90 acres (AF) Return Flows under Proposed Conditions on 34.35 acres (AF) Loss of Return Flows from Historical Conditions (AF) Loss of Return Flows from Historical Conditions (GPM) Jan 0.00 0.00 0.00 0.00 Feb 0.00 0.00 0.00 0.00 Mar 0.00 0.00 0.00 0.00 Apr 0.00 0.00 0.00 0.00 May 0.97 0.24 0.73 5.33 Jun 12.61 3.14 9.47 71.43 Jul 18.57 4.62 13.94 101.76 Aug 15.91 3.96 11.94 87.16 Sep 2.90 0.72 2.18 16.44 Oct 0.00 0.00 0.00 0.00 Nov 0.00 0.00 0.00 0.00 Dec 0.00 0.00 0.00 0.00 TOTAL = 50.95 12.70 38.25 -- 55. The retirement of 103.55 acres will result in the loss of 38.25 AF of return flows associated with the historical irrigation. Because return flows accrued evenly, 19.12 AF would be lost from Aajker Creek, and 19.12 AF would be lost from Baxter Creek – this equates to an average rate of approximately 24 GPM over the course of the historical periods of use and diversion. Recorded water rights on Aajker and Baxter Creeks downstream of the subject property total 15.94 CFS and 43.55 CFS, respectively. Aajker and Baxter Creeks are located within the Upper Missouri River Basin, which was legislatively closed to new appropriations with an effective date of April 16, 1993. DNRC does not have any measurement information on Aajker and Baxter Creeks. In the Application as originally filed, the Applicant did not Revised 07-2016 Preliminary Determination to Grant Page 32 of 52 Application to Change Water Right No. 41H 30103245 provide any further evidence to show that the lack of return flows accruing to these sources will not cause an adverse effect. However, in the Amendment, received on June 7, 2016, the Applicant proposed to incorporate the groundwater claims into the present Application in order to mitigate potential adverse effect from the loss of return flows. 56. The Applicant did provide a plan to prevent adverse effect from return flows. The Applicant owns four groundwater Statements of Claim (41H 138898-00, 41H 138899-00, 41H 138902-00, and 41H 138903-00) that were historically used on 43.22 acres. In the Application as originally filed, the Applicant proposed that these water rights would be retired or no longer used and that the continuing dewatering of this ground into the spring creek sources would be sufficient to prevent adverse effect. The Department issued an April 29, 2016, Draft Preliminary Determination to Deny related Norton-Bostwick Change Application 41H 30102910, which had used the same proposal. In that Determination, the Department held that, without a change application, it could not make a determination regarding the adequacy of the groundwater claims to mitigate the loss of return flows and neither could the Applicant provide assurance that these rights would be used continuously into the future in this manner. Mitigation is a beneficial use of water that would require reflection in the water right for a right to use the water in that manner. In their June 7, 2016, Amendment, the Applicant proposed to incorporate a change to the groundwater claims into the present Application. 57. Other appropriators may already rely on return flows from the groundwater claims, so only the historically consumed volume may be changed to mitigate the loss of return flows from the retirement of the subject water rights. As described in the Historical Use Section of this document, the groundwater claims have a historical consumed volume of 48.00 AF and a diverted volume of 68.60 AF. 58. The groundwater claims are for groundwater, which will no longer be diverted from the subsurface via the historical system of drain tiles, sunken concrete headgates, and drain ditches. As discussed elsewhere in this document, groundwater in the area is shallow (less than 6 feet below ground surface) and hydraulically connected to Aajker and Baxter Creeks. The historical groundwater place of use and associated diversion infrastructure are located immediately adjacent to the place of use of the subject water rights. Because of the hydraulic connection and the physical proximity, if a volume of water from the groundwater claims were not diverted and were instead left in the subsurface, that volume of water would be able to effectively mitigate an equivalent volume of return flows, lost due to the subject water rights’ retirement, during the same time period in which those return flows would have accrued. Revised 07-2016 Preliminary Determination to Grant Page 33 of 52 Application to Change Water Right No. 41H 30103245 59. In this Application, the Applicant proposes to retire a consumptive volume of 38.25 AF from the groundwater claims in order to mitigate the loss of return flows associated with the 103.55 acres that are being retired under the subject rights. The groundwater claims historically irrigated 43.22 acres with a consumed volume of 48.00 AF total (1.11 AF consumed volume per acre). Therefore, 34.44 acres must be retired in order to provide 38.25 AF of consumed volume to prevent any adverse effect from the loss of return flows. Averaged out over the 153-day period of diversion and use (June 1 – October 31), this equates to an average consumed flow rate of 56.60 GPM. The retirement of 34.44 acres from the groundwater claims will be sufficient to prevent any adverse effect from the loss of return flows due to the retirement of 103.55 acres from irrigation under the subject rights. This change will not adversely affect other appropriators on Aajker or Baxter Creeks. 60. Changing the place of use of 103.55 acres will not have an adverse effect on owners of private water rights or ditch shares in the Farmer’s Canal. The volume of water historically diverted to irrigate those 103.55 acres will continue to be diverted into the Farmer’s Canal. No conveyance water in the Farmer’s Canal is being changed. From the Farmer’s Canal, the water will be diverted into the Maynard- Border ditch, which is a lateral located approximately 1 mile farther down ditch, as compared to the E. Minder. According to information in the Application, the City of Bozeman obtained one Farmer’s Canal share with the purchase of the Sports Complex and owns an additional 4.25 shares from previous purchases. The combined 5.25 shares will be used to help convey the subject water rights to the new place of use at the Sports Complex. Therefore, other rights and shares in the Farmer’s Canal that relied on conveyance water from these rights will not be affected. 61. Changing the place of use of 103.55 acres will not have an adverse effect on owners of private water rights or ditch shares in the E. Minder Lateral. There is only one other user on the E. Minder Lateral: Kamp Enterprises. According to information provided by the president of the Farmer’s Canal to the Applicant’s consultant and included in the Application materials, Kamp currently owns 3 2/3 Farmer’s shares. Water is diverted from the E. Minder Lateral to the Kamp place of use well before reaching the Norton field. According to aerial imagery, the E. Minder Lateral traverses approximately 880 feet from the headgate on the Farmer’s Canal to the Kamp place of use. The effect of the loss of any conveyance water associated with the Norton rights on Kamp’s ability to continue to convey their shares through the E. Minder Lateral over such a short distance will not interfere with Kamp’s ability to reasonably exercise its water rights. Revised 07-2016 Preliminary Determination to Grant Page 34 of 52 Application to Change Water Right No. 41H 30103245 62. The Applicant has requested that the volume that was diverted but not applied to the field for the 7.95 acres for which no return flow mitigation is available also transfer to the City of Bozeman. The consumed volume and the field-applied volume for these 7.95 acres cannot be changed because no mitigation water is available to offset the loss of return flows. This leaves those 7.95 acres with no conveyance water associated with them. See Finding of Fact 70 for further discussion. 63. The Applicant has also requested to expand the period of use of the subject water rights as part of this Application. They propose to expand the period of use to May 1 through November 30 to allow irrigation as required for local climatic conditions and irrigation requirements, using stored water. Water stored in the irrigation reservoir will be used for this purpose, and no water will be diverted outside of the historical periods of diversion. The historical use of the subject rights has been determined, and no expansion of the consumed volume, diverted volume, or flow rate is occurring as a result of this change. The source of water, the West Gallatin River, will not experience any additional demand as a result of this change. The City of Bozeman also owns shares in Middle Creek Reservoir. These shares are marketed and then used for municipal purposes by the City; as such, they would not require that a change authorization account for subsequent storage in the Sports Complex irrigation reservoir. These shares have a year-round period of use and period of diversion and could be used by the City as needed for early- or late-season irrigation. As the reservoir is unlined, the City will account for any groundwater intercepted by the reservoir by filing a Notice of Completion of Groundwater Development. A Notice of Completion can be filed only after the groundwater development has been completed and the water put to use. The expansion of the period of use will not adversely affect any other water users. 64. This change application does not require measurement or reporting conditions. The West Gallatin River is an over-appropriated source with known issues – typically the district court appoints a water commissioner every year. The water commissioner admeasures and distributes water to water right holders based on priority and maintains records of the daily distribution of water. The commissioner will distribute water to the Farmer’s Canal headgate, where it leaves the source of supply. The Farmer’s Canal is an incorporated canal company and hires a ditch rider to distribute water to down-ditch users. After the West Gallatin River water commissioner turns water into the Farmer’s Canal, the ditch rider will measure and distribute water as it is conveyed to the Maynard-Border Ditch and Pipeline. The Maynard-Border Group will likewise measure and distribute water until it reaches its new place of use at the City of Bozeman Sports Complex. In May 7 – 8, 2018, emails and phone conversations, the City of Bozeman confirmed that they will measure all water pumped from the irrigation reservoir. They plan to utilize Revised 07-2016 Preliminary Determination to Grant Page 35 of 52 Application to Change Water Right No. 41H 30103245 SCADA (supervisory control and data acquisition) technology with a flowmeter and totalizer. The City is a public entity, so these measurement records will be available upon request. 65. The historical use for the subject water rights and the groundwater claims involved in this change has been determined and no expansion in use is occurring as a result of this change. 66. The Applicant has adequately shown the proposed change in appropriation right will not adversely affect the use of the existing water rights of other persons or other perfected or planned uses or developments for which a permit or certificate has been issued or for which a state water reservation has been issued. §85-2-402(2)(a), MCA. BENEFICIAL USE FINDINGS OF FACT Subject Water Rights 67. The Applicant proposes to use water for irrigation under the subject water rights. Irrigation is a beneficial use of water in the State of Montana. 68. The Applicant proposes to change the irrigation place of use of the subject water rights, add a place of storage, and expand the periods of use to enable them to use stored water from the irrigation reservoir. They propose to irrigate 58.86 acres of turf grass at the City of Bozeman Sports Complex. The City of Bozeman Sports Complex is located in Section 3, T03 S, R04 E, and will be bounded by Baxter Lane, Flanders Mill Road, Oak Street, and Cottonwood Road. The City of Bozeman’s landscape architect calculated irrigation demand at 159.37 AF of applied volume and, given the nature of the irrigation, assumed that the full volume will be consumed. The City of Bozeman’s landscape architect calculated irrigation demand at 159.37 AF of applied volume and, given the nature of turf grass irrigation, assumed that the full volume will be consumed. The landscape architect used evapotranspiration estimates from 1994 – 2004 AgriMet data, which is compiled by the U.S. Bureau of Reclamation. Assuming six days of watering per week, they computed daily evapotranspiration rates from April through October and then computed daily and monthly total consumption numbers. In addition, they computed 8-, 10-, 16-, and 24- hour daily flow rate demands. They repeated this exercise for the three types of irrigation proposed: irrigated turf, irrigated planters, and supplemental irrigation of native grasses. The full calculations were submitted as Appendix C of the November 1, 2016, Amendment. The reservoir capacity is included as part of the irrigation demand. In addition, 6.30 AF will be lost to evaporation from the irrigation reservoir. The total consumed volume for the new Sports Complex is the sum: 165.67 AF. Revised 07-2016 Preliminary Determination to Grant Page 36 of 52 Application to Change Water Right No. 41H 30103245 69. The consumed volume remaining for change is 152.95 AF, which corresponds to the 103.55 acres of the subject water rights. The Applicant has proposed to change the entire consumed volume to the new Sports Complex. With the purchase of the Sports Complex property, the City also acquired water right 41H 30108500 and one Farmer’s Canal share. Through previous property purchases and annexations, the City has additional Farmer’s shares. These additional water rights are analyzed in detail in subsequent Findings of Fact in this section. 70. The remaining diverted volume that corresponds to the 103.55 acres is 292.33 AF. The Applicant has proposed to change this entire diverted volume. In addition, they have proposed to change the diverted but not applied volume associated with the 7.95 acres for which no return flow mitigation is available. The consumed volume and the field-applied volume for these 7.95 acres cannot be changed because no mitigation water is available to offset the loss of return flows. The Technical Report calculated the difference between the diverted and the field-applied ratios for this acreage, with a result of 5.59 AF. The total diverted volume requested for change is 292.33 + 5.59 = 297.92 AF. The full diverted volume is needed for the use of irrigation at the Sports Complex and to convey the water an additional one mile down the Farmer’s Canal to the Maynard Border headgate and an additional 1.5 miles down the Maynard Border Ditch. The additional flow rate from 41H 30108500 and the Farmer’s Shares will provide sufficient conveyance through the additional length of the Farmer’s Canal and the Maynard Border Ditch. Conveyance losses through the Maynard Border Pipeline will be negligible because it is a closed system. 71. With the purchase of the Sports Complex property, the City acquired water right 41H 30108500, which has 60.57 AF of diverted volume at a flow rate of 74.50 GPM for irrigation of 80 acres, and one Farmer’s Canal share. The place of use of 41H 30108500 is the Sports Complex. The City has an additional 4.25 Farmer’s shares, acquired through previous purchases and annexations. Each Farmer’s share has a flow rate of 89 2/7 MI (2.23 CFS), so the total flow rate of Farmer’s shares available for use at the Sports Complex is 11.72 CFS. The Farmer’s shares will help provide conveyance water and applied and consumed water while the shares are in priority earlier in the irrigation season until they are cut off, typically around July 10. A portion of the applied and consumptive use will also come from the City’s water right 41H 30108500. Later in the season when the Farmer’s shares are no longer in priority, the additional historically diverted but not consumed volume from the subject water rights will provide conveyance water. The full historical diverted volume is necessary for the beneficial use of irrigation at the Sports Complex and for conveyance to the new place of use. Revised 07-2016 Preliminary Determination to Grant Page 37 of 52 Application to Change Water Right No. 41H 30103245 72. The City of Bozeman owns shares in Middle Creek Reservoir. These shares are marketed and then used for municipal purposes by the City; as such, they would not require that a change authorization account for subsequent storage in the Sports Complex irrigation reservoir. These shares have a year-round period of use and period of diversion and could be used by the City as needed for early-season irrigation at the Sports Complex before the May 1 start date for the earliest of the subject water rights or for late- season irrigation. The shares give the City flexibility in irrigating at either end of the season, as local climatic conditions and plant type warrant. As the irrigation reservoir is unlined, the City will account for any groundwater intercepted by the reservoir by filing a Notice of Completion of Groundwater Development. A Notice of Completion can be filed only after the groundwater development has been completed and the water put to use. 73. As part of the November 1, 2016, Amendment to the Application, the Applicant’s consultant used flow rate demands from the City of Bozeman’s landscape architect and compared them to the current water supplies available to the City for this project. The City’s flow rate deficit ranges across the irrigation season, but peaks in late July, with an estimated deficit of 2.55 CFS. The landscape architect calculated flow rate demand at the Sports Complex. The consultant then estimated flow rate demand at the Farmer’s Canal headgate, the main point of diversion for the subject water rights. The landscape architect calculated daily demands, and the consultant used the 16-hour per day flow rate demands to estimate use for each month. Each month was then broken up into quarters. The consultant further estimated the reliability of the Farmer’s shares and water right 41H 30108500. The reservoir will provide storage to buffer surges in demand as compared to supply. Farmer’s shares are typically cut off by early to mid-July. The subject water rights will provide 1.83 CFS, so the full flow rate from the subject water rights is needed. See the November 1, 2016, Amendment and the revised Exhibit 55 for further discussion. 74. The capacity of the reservoir is 14.3 AF with a surface area of 2 acres. The water stored in the reservoir is included as part of the irrigation demand. The expansion of the period of use to May 1 through November 30 will allow the Applicant additional flexibility in the irrigation of the City Sports Complex. Water stored in the irrigation reservoir will be applied as appropriate, given local climatic conditions and plant demands. An expanded period of use to maintain healthy turf grass fits within the beneficial use of water for irrigation purposes. Revised 07-2016 Preliminary Determination to Grant Page 38 of 52 Application to Change Water Right No. 41H 30103245 Groundwater Claims 75. The Applicant proposes to use water for mitigation under the groundwater claims. Mitigation is a beneficial use of water in the State of Montana. 76. The purpose will be changed from irrigation to water left instream (i.e., not diverted from the subsurface) for mitigation of the loss of 38.25 AF of return flows associated with the change of 103.55 acres of the subject water rights. In order to provide 38.25 AF of historical consumptive use, 34.44 acres need to be retired under the groundwater claims. Averaging the 38.25 AF volume out across the 153-day (June 1 to October 31) period of diversion and use equates to a mitigation flow rate of 56.60 GPM. Because the groundwater claims are fully supplemental, consumed volume and consumed flow rate are assigned to all four in equal proportions. See Table 7 below. Table 7: Groundwater Claims Mitigation Volume and Flow Rate by Application Water Right Number Acres Retired1 Consumed Volume Consumed Flow Rate (41H) (ac) (AF) (GPM) 138898-00 34.44 9.57 14.15 138899-00 9.56 14.15 138902-00 9.56 14.15 138903-00 9.56 14.15 TOTAL = 34.44 38.25 56.60 Notes: 1These claims are fully supplemental, so 34.44 acres will be retired from all of them. ADEQUATE DIVERSION FINDINGS OF FACT Subject Water Rights 77. The Farmer’s Canal is an important irrigation canal in the Gallatin Valley, and the West Gallatin is also an important source of irrigation water in the Valley. Two 10-foot Parshall flumes located approximately 300 feet down ditch of the Farmer’s Canal headgate measure flow into the canal. Water entering the canal is measured by the West Gallatin Water Commissioner. The West Gallatin is an over- Revised 07-2016 Preliminary Determination to Grant Page 39 of 52 Application to Change Water Right No. 41H 30103245 appropriated source with known issues – typically, the district court appoints a water commissioner every year. The findings in this document will be incorporated into the Department’s database and reflected in the water right abstracts. The Water Commissioner will be provided with an updated water right index in order to effectively distribute water to the Farmer’s Canal. Once water is diverted into the Farmer’s Canal headgate, the Canal also employs a ditch rider to distribute water deliveries to owners of private water rights conveyed in the canal and to shareholders. The ditch rider will likewise be able to employ updated records to distribute water. As discussed previously in this document, the Farmer’s Canal has an estimated maximum capacity of 250 CFS. The Farmer’s Canal is an adequate means of diversion and conveyance for the proposed project. 78. After being conveyed through the Farmer’s Canal, water under the subject rights will be conveyed approximately 1.5 miles down the Maynard Border Ditch to the Maynard Border Pipeline. From there, a valve will direct water to the proposed irrigation reservoir at the Sports Complex place of use. The Maynard Border Ditch begins at a headgate off the Farmer’s Canal in the NWSENW of Section 15, T02 S, R05 E. From there, it travels generally north, crosses Huffine Lane/U.S. Highway 191, and terminates into a pipeline in the N½N½NW of Section 10. The pipeline was constructed in 1993 as part of a cost-share program sponsored by the NRCS to improve irrigation water management. The Applicant provided copies of “Valley West Subvidision – Phase #3, Supplement to Maynard Border Ditch Intake Plans,” “Drainage Plan, Valley West Subdivision, Planned Unit Development,” and related design calculations and design drawings. All of these submittals and designs were prepared by licensed professional engineers at Morrison-Maierle Inc. and submitted to the City of Bozeman Engineering Department. The “Drainage Plan” document indicated the capacities of the Maynard Border Ditch at various points along its length: 39 CS at the Farmer’s headgate, 50 CFS at the Huffine Lane/U.S. Highway 191 crossing, and 99 CFS at the Babcock Street Crossing. The “Valley West Subdivision” supplement document indicated that the pipeline’s capacity was 33.4 CFS, but that it typically carried 16.1 CFS of irrigation water. Both the Maynard Border Ditch and the Maynard Border Pipeline are adequate means of diversion and conveyance and have the capacity to convey the additional flow rate proposed in this Application. 79. The Applicant submitted preliminary plans for the Sports Complex and the associated irrigation system. Water will be directed through a valve on the Maynard Border Pipeline to the irrigation reservoir. The reservoir’s storage will provide a continuous flow of water to the sprinkler system. From the reservoir, water will be pumped out into a sprinkler system for irrigation of approximately 58.86 acres of Revised 07-2016 Preliminary Determination to Grant Page 40 of 52 Application to Change Water Right No. 41H 30103245 turf grass. The irrigation system is being designed by Steiner-Thuesen PLLC, a landscape architecture firm whose principals are licensed landscape architects in the State of Montana. The system is being designed to apply the portion of the subject water rights being changed in this application and the additional water rights that are appurtenant to the Sports Complex. These are the water sources that are available to the City for use. The City of Bozeman maintains an Engineering Department with licensed professional engineers who will oversee the design and construction of the irrigation works described in this document and in the Application. Groundwater Claims 80. This Application proposes to change the groundwater claims to the purpose of mitigation. Pursuant to §85-2-402 (2)(b)(iii), MCA, changes for mitigation are not required to prove by a preponderance of the evidence that the proposed means of diversion, construction, and operation of the appropriation works are adequate. POSSESSORY INTEREST FINDINGS OF FACT Subject Water Rights 81. The Applicant signed the affidavit on the application form affirming the applicant has possessory interest, or the written consent of the person with the possessory interest, in the property where the water is to be put to beneficial use. 82. The City of Bozeman owns the ultimate place of use for the subject water rights. Exhibit 1 of the Application is a “Memorandum of Agreement for Norton Ranch Subdivision Water Adequacy Requirements” in which the City agrees to purchase the portion of the subject water rights identified in this document upon successful completion of a change of use application from the Department. It is clear that the ultimate user will not accept the supply without consenting to the use of water. Groundwater Claims 83. This Application proposes to change the subject water rights to the purpose of mitigation. Pursuant to §85-2-402 (2)(d)(iii), MCA, changes for mitigation are not required to prove by a preponderance of the evidence that they have a possessory interest in the property where the water is to be put to beneficial use. Revised 07-2016 Preliminary Determination to Grant Page 41 of 52 Application to Change Water Right No. 41H 30103245 CONCLUSIONS OF LAW HISTORIC USE AND ADVERSE EFFECT 84. Montana’s change statute codifies the fundamental principles of the Prior Appropriation Doctrine. Sections 85-2-401 and -402(1)(a), MCA, authorize changes to existing water rights, permits, and water reservations subject to the fundamental tenet of Montana water law that one may change only that to which he or she has the right based upon beneficial use. A change to an existing water right may not expand the consumptive use of the underlying right or remove the well-established limit of the appropriator’s right to water actually taken and beneficially used. An increase in consumptive use constitutes a new appropriation and is subject to the new water use permit requirements of the MWUA. McDonald v. State, 220 Mont. 519, 530, 722 P.2d 598, 605 (1986)(beneficial use constitutes the basis, measure, and limit of a water right); Featherman v. Hennessy, 43 Mont. 310, 316-17, 115 P. 983, 986 (1911)(increased consumption associated with expanded use of underlying right amounted to new appropriation rather than change in use); Quigley v. McIntosh, 110 Mont. 495, 103 P.2d 1067, 1072-74 (1940)(appropriator may not expand a water right through the guise of a change – expanded use constitutes a new use with a new priority date junior to intervening water uses); Allen v. Petrick, 69 Mont. 373, 222 P. 451(1924)(“quantity of water which may be claimed lawfully under a prior appropriation is limited to that quantity within the amount claimed which the appropriator has needed, and which within a reasonable time he has actually and economically applied to a beneficial use. . . . it may be said that the principle of beneficial use is the one of paramount importance . . . The appropriator does not own the water. He has a right of ownership in its use only”); Town of Manhattan, at ¶ 10 (an appropriator’s right only attaches to the amount of water actually taken and beneficially applied); Town of Manhattan v. DNRC, Cause No. DV-09-872C, Montana Eighteenth Judicial District Court, Order Re Petition for Judicial Review, Pg. 9 (2011)(the rule that one may change only that to which it has a right is a fundamental tenet of Montana water law and imperative to MWUA change provisions); In the Matter of Application to Change a Water Right No. 41I 30002512 by Brewer Land Co, LLC, DNRC Proposal For Decision and Final Order (2004).1 85. Sections 85-2-401(1) and -402(2)(a), MCA, codify the prior appropriation principles that Montana appropriators have a vested right to maintain surface and ground water conditions substantially as they existed at the time of their appropriation; subsequent appropriators may insist that prior 1 DNRC decisions are available at: http://www.dnrc.mt.gov/wrd/water_rts/hearing_info/hearing_orders/hearingorders.asp Revised 07-2016 Preliminary Determination to Grant Page 42 of 52 Application to Change Water Right No. 41H 30103245 appropriators confine their use to what was actually appropriated or necessary for their originally intended purpose of use; and, an appropriator may not change or alter its use in a manner that adversely affects another water user. Spokane Ranch & Water Co. v. Beatty, 37 Mont. 342, 96 P. 727, 731 (1908); Quigley, 110 Mont. at 505-11,103 P.2d at 1072-74; Matter of Royston, 249 Mont. at 429, 816 P.2d at 1057; Hohenlohe, at ¶¶43-45.2 86. The cornerstone of evaluating potential adverse effect to other appropriators is the determination of the “historic use” of the water right being changed. Town of Manhattan, at ¶10 (recognizing that the Department’s obligation to ensure that change will not adversely affect other water rights requires analysis of the actual historic amount, pattern, and means of water use). A change applicant must prove the extent and pattern of use for the underlying right proposed for change through evidence of the historic diverted amount, consumed amount, place of use, pattern of use, and return flow because a statement of claim, permit, or decree may not include the beneficial use information necessary to evaluate the amount of water available for change or potential for adverse effect.3 A comparative analysis of the historic use of the water right to the proposed change in use is necessary to prove the change will not result in expansion of the original right, or adversely affect water users who are entitled to rely upon maintenance of conditions on the source of supply for their water rights. Quigley, 103 P.2d at 1072-75 (it is necessary to ascertain historic use of a decreed water right to determine whether a change in use expands the underlying right to the detriment of other water user because a decree only provides a limited description of the right); Royston, 249 Mont. at 431-32, 816 P.2d at 1059-60 (record could not sustain a conclusion of no adverse effect because the applicant failed to provide the Department with evidence of the historic diverted volume, consumption, and return flow); Hohenlohe, at ¶44-45; Town of Manhattan v. DNRC, Cause No. DV-09-872C, Montana Eighteenth Judicial District Court, Order Re Petition for Judicial 2 See also Holmstrom Land Co., Inc., v. Newlan Creek Water District,185 Mont. 409, 605 P.2d 1060 (1979); Lokowich v. Helena, 46 Mont. 575, 129 P. 1063(1913); Thompson v. Harvey, 164 Mont. 133, 519 P.2d 963 (1974)(plaintiff could not change his diversion to a point upstream of the defendants because of the injury resulting to the defendants); McIntosh v. Graveley, 159 Mont. 72, 495 P.2d 186 (1972)(appropriator was entitled to move his point of diversion downstream, so long as he installed measuring devices to ensure that he took no more than would have been available at his original point of diversion); Head v. Hale, 38 Mont. 302, 100 P. 222 (1909)(successors of the appropriator of water appropriated for placer mining purposes cannot so change its use as to deprive lower appropriators of their rights, already acquired, in the use of it for irrigating purposes); and, Gassert v. Noyes, 18 Mont. 216, 44 P. 959(1896)(change in place of use was unlawful where reduced the amount of water in the source of supply available which was subject to plaintiff’s subsequent right). 3A claim only constitutes prima facie evidence for the purposes of the adjudication under § 85-2-221, MCA. The claim does not constitute prima facie evidence of historical use in a change proceeding under §85-2-402, MCA. For example, most water rights decreed for irrigation are not decreed with a volume and provide limited evidence of actual historic beneficial use. §85-2-234, MCA Revised 07-2016 Preliminary Determination to Grant Page 43 of 52 Application to Change Water Right No. 41H 30103245 Review, Pgs. 11-12 (proof of historic use is required even when the right has been decreed because the decreed flow rate or volume establishes the maximum appropriation that may be diverted, and may exceed the historical pattern of use, amount diverted or amount consumed through actual use); Matter of Application For Beneficial Water Use Permit By City of Bozeman, Memorandum, Pgs. 8-22 (Adopted by DNRC Final Order January 9,1985)(evidence of historic use must be compared to the proposed change in use to give effect to the implied limitations read into every decreed right that an appropriator has no right to expand his appropriation or change his use to the detriment of juniors).4 87. An applicant must also analyze the extent to which a proposed change may alter historic return flows for purposes of establishing that the proposed change will not result in adverse effect. The requisite return flow analysis reflects the fundamental tenant of Montana water law that once water leaves the control of the original appropriator, the original appropriator has no right to its use and the water is subject to appropriation by others. E.g., Hohenlohe, at ¶44; Rock Creek Ditch & Flume Co. v. Miller, 93 Mont. 248, 17 P.2d 1074, 1077 (1933); Newton v. Weiler, 87 Mont. 164, 286 P. 133(1930); Popham v. Holloron, 84 Mont. 442, 275 P. 1099, 1102 (1929); Galiger v. McNulty, 80 Mont. 339, 260 P. 401 (1927); Head v. Hale, 38 Mont. 302, 100 P. 222 (1909); Spokane Ranch & Water Co., 37 Mont. at 351- 52, 96 P. at 731; Hidden Hollow Ranch v. Fields, 2004 MT 153, 321 Mont. 505, 92 P.3d 1185; In the Matter of Application for Change Authorization No. G (W)028708-411 by Hedrich/Straugh/Ringer, 4 Other western states likewise rely upon the doctrine of historic use as a critical component in evaluating changes in appropriation rights for expansion and adverse effect: Pueblo West Metropolitan District v. Southeastern Colorado Water Conservancy District, 717 P.2d 955, 959 (Colo. 1986)(“[O]nce an appropriator exercises his or her privilege to change a water right … the appropriator runs a real risk of requantification of the water right based on actual historical consumptive use. In such a change proceeding a junior water right … which had been strictly administered throughout its existence would, in all probability, be reduced to a lesser quantity because of the relatively limited actual historic use of the right.”); Santa Fe Trail Ranches Property Owners Ass'n v. Simpson, 990 P.2d 46, 55 -57 (Colo.,1999); Farmers Reservoir and Irr. Co. v. City of Golden, 44 P.3d 241, 245 (Colo. 2002)(“We [Colorado Supreme Court] have stated time and again that the need for security and predictability in the prior appropriation system dictates that holders of vested water rights are entitled to the continuation of stream conditions as they existed at the time they first made their appropriation); Application for Water Rights in Rio Grande County, 53 P.3d 1165, 1170 (Colo. 2002); Wyo. Stat. § 41-3-104 (When an owner of a water right wishes to change a water right … he shall file a petition requesting permission to make such a change …. The change … may be allowed provided that the quantity of water transferred … shall not exceed the amount of water historically diverted under the existing use, nor increase the historic rate of diversion under the existing use, nor increase the historic amount consumptively used under the existing use, nor decrease the historic amount of return flow, nor in any manner injure other existing lawful appropriators.); Basin Elec. Power Co-op. v. State Bd. of Control, 578 P.2d 557, 564 -566 (Wyo,1978) (a water right holder may not effect a change of use transferring more water than he had historically consumptively used; regardless of the lack of injury to other appropriators, the amount of water historically diverted under the existing use, the historic rate of diversion under the existing use, the historic amount consumptively used under the existing use, and the historic amount of return flow must be considered.) Revised 07-2016 Preliminary Determination to Grant Page 44 of 52 Application to Change Water Right No. 41H 30103245 DNRC Final Order (Dec. 13, 1991); In the Matter of Application for Change Authorization No. G(W)008323-G76l By Starkel/Koester, DNRC Final Order (Apr. 1, 1992); In the Matter of Application to Change a Water Right No. 41I 30002512 by Brewer Land Co, LLC, DNRC Proposal For Decision and Final Order (2004); Admin. R.M. 36.12.101(56)(Return flow - that part of a diverted flow which is not consumed by the appropriator and returns underground to its original source or another source of water - is not part of a water right and is subject to appropriation by subsequent water users).5 88. Although the level of analysis may vary, analysis of the extent to which a proposed change may alter the amount, location, or timing return flows is critical in order to prove that the proposed change will not adversely affect other appropriators who rely on those return flows as part of the source of supply for their water rights. Royston, 249 Mont. at 431, 816 P.2d at 1059-60; Hohenlohe, at ¶¶ 45-6 and 55-6; Spokane Ranch & Water Co., 37 Mont. at 351-52, 96 P. at 731. Noted Montana Water Law scholar Al Stone explained that the water right holder who seeks to change a water right is unlikely to receive the full amount claimed or historically used at the original place of use due to reliance upon return flows by other water users. Montana Water Law, Albert W. Stone, Pgs. 112-17 (State Bar of Montana 1994). 89. In Royston, the Montana Supreme Court confirmed that an applicant is required to prove lack of adverse effect through comparison of the proposed change to the historic use, historic consumption, and historic return flows of the original right. 249 Mont. at 431, 816 P.2d at 1059-60. More recently, the Montana Supreme Court explained the relationship between the fundamental principles of historic beneficial use, return flow, and the rights of subsequent appropriators as they relate to the adverse effect analysis in a change proceeding in the following manner: The question of adverse effect under §§ 85-2-402(2) and -408(3), MCA, implicates return flows. A change in the amount of return flow, or to the hydrogeologic pattern of return flow, has the potential to affect adversely downstream water rights. There consequently exists an inextricable link between the “amount historically consumed” and the water that re-enters the stream as return flow. . . . An appropriator historically has been entitled to the greatest quantity of water he can put to use. The requirement that the use be both beneficial and reasonable, however, proscribes this tenet. This limitation springs from a fundamental tenet of western water law-that an appropriator has a right only to that amount of water historically put to beneficial use-developed in concert with the rationale that each subsequent appropriator 5 The Montana Supreme Court recently recognized the fundamental nature of return flows to Montana’s water sources in addressing whether the Mitchell Slough was a perennial flowing stream, given the large amount of irrigation return flow which feeds the stream. The Court acknowledged that the Mitchell’s flows are fed by irrigation return flows available for appropriation. Bitterroot River Protective Ass'n, Inc. v. Bitterroot Conservation Dist. 2008 MT 377, ¶¶ 22, 31, 43, 346 Mont. 508, ¶¶ 22, 31,43, 198 P.3d 219, ¶¶ 22, 31,43(citing Hidden Hollow Ranch v. Fields, 2004 MT 153, 321 Mont. 505, 92 P.3d 1185). Revised 07-2016 Preliminary Determination to Grant Page 45 of 52 Application to Change Water Right No. 41H 30103245 “is entitled to have the water flow in the same manner as when he located,” and the appropriator may insist that prior appropriators do not affect adversely his rights. This fundamental rule of Montana water law has dictated the Department’s determinations in numerous prior change proceedings. The Department claims that historic consumptive use, as quantified in part by return flow analysis, represents a key element of proving historic beneficial use. We do not dispute this interrelationship between historic consumptive use, return flow, and the amount of water to which an appropriator is entitled as limited by his past beneficial use. Hohenlohe, at ¶¶ 42-45 (internal citations omitted). 90. The Department’s rules reflect the above fundamental principles of Montana water law and are designed to itemize the type evidence and analysis required for an applicant to meet its burden of proof. Admin.R.M. 36.12.1901 through 1903. These rules forth specific evidence and analysis required to establish the parameters of historic use of the water right being changed. Admin.R.M. 36.12.1901 and 1902. The rules also outline the analysis required to establish a lack of adverse effect based upon a comparison of historic use of the water rights being changed to the proposed use under the changed conditions along with evaluation of the potential impacts of the change on other water users caused by changes in the amount, timing, or location of historic diversions and return flows. Admin.R.M. 36.12.1901 and 1903. 91. Applicant seeks to change existing water rights represented by its Water Right Claims. The “existing water rights” in this case are those as they existed prior to July 1, 1973, because with limited exception, no changes could have been made to those rights after that date without the Department’s approval. Analysis of adverse effect in a change to an “existing water right” requires evaluation of what the water right looked like and how it was exercised prior to July 1, 1973. In McDonald v. State, the Montana Supreme Court explained: The foregoing cases and many others serve to illustrate that what is preserved to owners of appropriated or decreed water rights by the provision of the 1972 Constitution is what the law has always contemplated in this state as the extent of a water right: such amount of water as, by pattern of use and means of use, the owners or their predecessors put to beneficial use. . . . the Water Use Act contemplates that all water rights, regardless of prior statements or claims as to amount, must nevertheless, to be recognized, pass the test of historical, unabandoned beneficial use. . . . To that extent only the 1972 constitutional recognition of water rights is effective and will be sustained. 220 Mont. at 529, 722 P.2d at 604; see also Matter of Clark Fork River Drainage Area, 254 Mont. 11, 17, 833 P.2d 1120 (1992). Revised 07-2016 Preliminary Determination to Grant Page 46 of 52 Application to Change Water Right No. 41H 30103245 92. Water Resources Surveys were authorized by the 1939 legislature. 1939 Mont. Laws Ch. 185, § 5. Since their completion, Water Resources Surveys have been invaluable evidence in water right disputes and have long been relied on by Montana courts. In re Adjudication of Existing Rights to Use of All Water in North End Subbasin of Bitterroot River Drainage Area in Ravalli and Missoula Counties, 295 Mont. 447, 453, 984 P.2d 151, 155 (1999)(Water Resources Survey used as evidence in adjudicating of water rights); Wareing v. Schreckendgust, 280 Mont. 196, 213, 930 P.2d 37, 47 (1996)(Water Resources Survey used as evidence in a prescriptive ditch easement case); Olsen v. McQueary, 212 Mont. 173, 180, 687 P.2d 712, 716 (1984) (judicial notice taken of Water Resources Survey in water right dispute concerning branches of a creek). 93. While evidence may be provided that a particular parcel was irrigated, the actual amount of water historically diverted and consumed is critical. E.g., In the Matter of Application to Change Water Right No. 41H 1223599 by MGRR #1, LLC., DNRC Proposal for Decision adopted by Final Order (2005). The Department cannot assume that a parcel received the full duty of water or that it received sufficient water to constitute full service irrigation for optimum plant growth. Even when it seems clear that no other rights could be affected solely by a particular change in the location of diversion, it is essential that the change also not enlarge an existing right. See MacDonald, 220 Mont. at 529, 722 P.2d at 604; Featherman, 43 Mont. at 316-17, 115 P. at 986; Trail's End Ranch, L.L.C. v. Colorado Div. of Water Resources 91 P.3d 1058, 1063 (Colo., 2004). 94. The Department has adopted a rule providing for the calculation of historic consumptive use where the applicant proves by a preponderance of the evidence that the acreage was historically irrigated. Admin. R. M. 36.12.1902 (16). In the alternative an applicant may present its own evidence of historic beneficial use. In this case Applicant has elected to proceed under Admin. R.M. 36.12.1902. (FOF Nos. 37 – 43). 95. If an applicant seeks more than the historic consumptive use as calculated by Admin.R.M .36.12.1902 (16), the applicant bears the burden of proof to demonstrate the amount of historic consumptive use by a preponderance of the evidence. The actual historic use of water could be less than the optimum utilization represented by the calculated duty of water in any particular case. E.g., Application for Water Rights in Rio Grande County 53 P.3d 1165 (Colo., 2002) (historical use must be quantified to ensure no enlargement); In the Matter of Application to Change Water Right No. 41H 1223599 by MGRR #1, LLC., supra; Orr v. Arapahoe Water and Sanitation Dist. 753 P.2d 1217, 1223 - Revised 07-2016 Preliminary Determination to Grant Page 47 of 52 Application to Change Water Right No. 41H 30103245 1224 (Colo., 1988)(historical use of a water right could very well be less than the duty of water); Weibert v. Rothe Bros., Inc., 200 Colo. 310, 317, 618 P.2d 1367, 1371 - 1372 (Colo. 1980) (historical use could be less than the optimum utilization “duty of water”). 96. Based upon the Applicant’s evidence of historic use, the Applicant has proven by a preponderance of the evidence that the historical use of Water Right Claim Nos. 41H 30023118, 41H 30023119, and 41H 30023120 (the subject water rights) is a diverted volume of 351.60 AF, a consumed volume of 203.69 AF, and a flow rate of 1,096.43 GPM. (FOF Nos. 15 – 52) 97. Based upon the Applicant’s evidence of historic use, the Applicant has proven by a preponderance of the evidence that the historical use of Water Right Claim Nos. 41H 138898-00, 41H 138899-00, 41H 138902-00, and 41H 138903-00 (the groundwater claims) is a diverted volume of 68.60 AF, a consumed volume of 48.00 AF, and a flow rate of 1.21 CFS. (FOF Nos. 15 – 52) 98. The Applicant has proven that the proposed change in appropriation right will not adversely affect the use of the existing water rights of other persons or other perfected or planned uses or developments for which a permit or certificate has been issued or for which a state water reservation has been issued. §85-2-402(2)(b), MCA. (FOF Nos. 53 – 66). BENEFICIAL USE 99. A change applicant must prove by a preponderance of the evidence the proposed use is a beneficial use. §§85-2-102(4) and -402(2)(c), MCA. Beneficial use is and has always been the hallmark of a valid Montana water right: “[T]he amount actually needed for beneficial use within the appropriation will be the basis, measure, and the limit of all water rights in Montana . . .” McDonald, 220 Mont. at 532, 722 P.2d at 606. The analysis of the beneficial use criterion is the same for change authorizations under §85-2-402, MCA, and new beneficial permits under §85-2-311, MCA. Admin.R.M. 36.12.1801. The amount of water that may be authorized for change is limited to the amount of water necessary to sustain the beneficial use. E.g., Bitterroot River Protective Association v. Siebel, Order on Petition for Judicial Review, Cause No. BDV-2002-519, Montana First Judicial District Court (2003) (affirmed on other grounds, 2005 MT 60, 326 Mont. 241, 108 P.3d 518); Worden v. Alexander, 108 Mont. 208, 90 P.2d 160 (1939); Allen v. Petrick, 69 Mont. 373, 222 P. 451(1924); Sitz Ranch v. DNRC, DV-10-13390, Montana Fifth Judicial District Court, Order Affirming DNRC Decision, Pg. 3 (2011)(citing BRPA v. Siebel, 2005 MT 60, and rejecting applicant’s argument that it be allowed to appropriate 800 acre-feet when a typical year would require 200-300 acre-feet); Toohey v. Campbell, 24 Mont. 13, 60 P. 396 (1900)(“The policy Revised 07-2016 Preliminary Determination to Grant Page 48 of 52 Application to Change Water Right No. 41H 30103245 of the law is to prevent a person from acquiring exclusive control of a stream, or any part thereof, not for present and actual beneficial use, but for mere future speculative profit or advantage, without regard to existing or contemplated beneficial uses. He is restricted in the amount that he can appropriate to the quantity needed for such beneficial purposes.”); §85-2-312(1)(a), MCA (DNRC is statutorily prohibited from issuing a permit for more water than can be beneficially used). 100. The Department may issue a change authorization for less than the amount of water requested, but may not issue a change authorization for more water than is requested or more water than can be beneficially used without waste for the purpose stated in the application. §85-2-312, MCA; see also, McDonald v. State, 220 Mont. 519, 722 P.2d 598 (1986); Toohey v. Campbell, 24 Mont. 13, 60 P. 396 (1900). 101. The Applicant proposes to use the subject water rights for irrigation and the groundwater claims for mitigation, which are recognized beneficial uses §85-2-102(4), and -420 MCA. The Applicant has proven by a preponderance of the evidence that, under the subject water rights, a diverted volume of 297.92 AF, a consumed volume of 152.95 AF, and a flow rate of 1.83 CFS (1,096.43 GPM) are the amounts needed to sustain the beneficial use of irrigation from May 1 to October 31 at the City of Bozeman Sports Complex. The Applicant has proven by a preponderance of the evidence that, under the groundwater claims, a consumed volume of 38.25 AF at a rate of 59.60 GPM from June 1 to October 31 is the amount needed to mitigate the loss of return flows caused by the change of 103.55 acres under the subject water rights and to sustain the beneficial use of mitigation. §85-2-402(2)(c), MCA (FOF Nos. 67 – 76). ADEQUATE MEANS OF DIVERSION Subject Water Rights 102. Pursuant to §85-2-402 (2)(b), MCA, the Applicant must prove by a preponderance of the evidence that the proposed means of diversion, construction, and operation of the appropriation works are adequate. This codifies the prior appropriation principle that the means of diversion must be reasonably effective for the contemplated use and may not result in a waste of the resource. Crowley v. 6th Judicial District Court, 108 Mont. 89, 88 P.2d 23 (1939); In the Matter of Application for Beneficial Water Use Permit No. 41C-11339900 by Three Creeks Ranch of Wyoming LLC (DNRC Final Order 2002)(information needed to prove that proposed means of diversion, construction, and operation of the Revised 07-2016 Preliminary Determination to Grant Page 49 of 52 Application to Change Water Right No. 41H 30103245 appropriation works are adequate varies based upon project complexity; design by licensed engineer adequate). 103. Pursuant to §85-2-402 (2)(b), MCA, applicant has proven by a preponderance of the evidence that the proposed means of diversion, construction, and operation of the appropriation works are adequate for the proposed beneficial use. (FOF Nos. 77 – 80) Groundwater Claims 104. Pursuant to §85-2-402 (2)(b), MCA, the Applicant is not required to prove that the proposed means of diversion, construction, and operation of the appropriation works are adequate because this application involves a (iii) a change in appropriation right pursuant to 85-2-420 for mitigation or marketing for mitigation. POSSESSORY INTEREST Subject Water Rights 105. Pursuant to §85-2-402(2)(d), MCA, the Applicant must prove by a preponderance of the evidence that it has a possessory interest, or the written consent of the person with the possessory interest, in the property where the water is to be put to beneficial use. See also Admin.R.M. 36.12.1802 106. The Applicant has proven by a preponderance of the evidence that it has a possessory interest, or the written consent of the person with the possessory interest, in the property where the water is to be put to beneficial use. (FOF Nos. 81 – 83) Groundwater Claims 107. Pursuant to §85-2-402(2)(d), MCA, the applicant is not required to prove that it has a possessory interest, or the written consent of the person with the possessory interest, in the property where the water is to be put to beneficial use because this application involves a (iii) a change in appropriation right pursuant to §85-2-420 MCA for mitigation or marketing for mitigation. Salvage Water 108. This Application does not involve salvage water. Revised 07-2016 Preliminary Determination to Grant Page 50 of 52 Application to Change Water Right No. 41H 30103245 PRELIMINARY DETERMINATION Subject to the terms and analysis in this Preliminary Determination Order, the Department preliminarily determines that this Application to Change Water Right No. 41H 30103245 should be granted subject to the following. The Applicant is authorized to change the place of use of, add a place of storage to, and expand the period of use of the subject water rights: 41H 30023118, 41H 30023119, and 41H 30023120. Under these three water rights, up to 297.92 AF of water at a combined flow rate of 1.83 CFS may be diverted from the West Gallatin River at the Farmer’s Canal headgate in the SWNWNW of Section 11, T03 S, R04 E, Gallatin County, for irrigation of 58.86 acres at the City of Bozeman Sports Complex, located in the W½NW of Section 3, T02 S, R05 E. The Applicant is authorized to add a place storage: an irrigation reservoir located in the SESWNW of Section 3. The period of diversion remains unchanged, but the Applicant may pump water stored under the subject water rights from the reservoir for the purpose of irrigation during an expanded period of use from May 1 to November 30. The Applicant is further authorized to change partially the purpose, place of use, and point of diversion of groundwater claims: 41H 138898-00, 41H 138899-00, 41H 138902-00, and 41H 138903-00. Under these four rights 34.44 acres of irrigation will be retired in order to leave 38.25 AF of groundwater at a rate of 56.60 GPM in the subsurface from June 1 through October 31 at points in the NWSENW and NESWNE of Section 9, T02 S, R05 E, Gallatin County. These two points constitute the new place of use and point of diversion.