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HomeMy WebLinkAbout08-20-2026 Public Comment - K. Berry - Public Comment from the Open Channels Working Group- Northwest Bozeman Area Plan From: Katherine Berry To: Bozeman Public Comment;Chris Naumann Subject: [EXTERNAL]Public Comment from the Open Channels Working Group-Northwest Bozeman Area Plan Date: Thursday,August 20,2026 3:19:37 PM Attachments: 26.08.20_OCWG_Policy Memo_Northwest Bozeman Area Plan(1).pdf CAUTION:This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Hi Chris, I hope you're doing well, and I'm very excited for your presentation to the Gallatin Water Collaborative (Collaborative)this week! I am submitting a policy memo developed by the Open Channels Working Group to help inform how the Northwest Bozeman Area Plan considers irrigation infrastructure. The Open Channels Working Group is a subset of Collaborative members who work to protect and sustain the Valley's irrigation ditch infrastructure. I anticipate the larger Collaborative group will also submit a separate comment letter for the Northwest Bozeman Area Plan focused on broader water resource considerations. This letter will address recommendations we will hopefully discuss on Tuesday, such as updating watercourse setbacks and considering opportunities and locations for a wetland mitigation bank. Thank you again, and I'm looking forward to next week! Please feel free to call or email with any questions. Best, Katherine Katherine Berry, Water Policy Manager Gallatin Watershed Council www.gallatinwatershedcouncil.org katherinengallatinwatershedcouncil.org Cell: 860-558-3323 GALLATIN WATERSHED ■ C O U N C I L ■ GallatinWater ■ ■ COLLABORATIVE POLICY MEMO To: The City of Bozeman From: Open Channels Working Group Date: 08/20/2026 Re: Northwest Bozeman Area Plan -Agricultural Water User Facilities Executive Summary The Northwest Bozeman Area Plan presents an opportunity to protect agricultural water user facilities, or irrigation ditches, while planning for growth. The Open Channels Working Group recommends that the Area Plan recognize irrigation ditch infrastructure as an essential component of the region's hydrologic system by preserving open channels, recognizing aquifer recharge potential, and identifying opportunities for regional stormwater facilities. Background The City of Bozeman is developing the Northwest Bozeman Area Plan to guide future growth northwest of the current city limits. While most of the planning area remains under Gallatin County jurisdiction, the plan provides an opportunity to establish a long-term vision before urban development occurs. The plan will inform land use decisions around zoning, subdivision and site development, infrastructure planning, affordable housing, and natural resource protection. The land in the Northwest Bozeman Area Plan boundary is primarily used for agricultural purposes at this time. The area contains extensive interconnected water resources like wetlands, streams, and several active irrigation ditch companies, including Farmer's Canal (Maynard-Border), and Beck-Border. The Gallatin Water Collaborative has identified protection of irrigation infrastructure as a priority through its objective of ensuring that groundwater and surface water resources are managed collaboratively to support all water uses. The Open Channels Working Group leads efforts that address this goal. The group consists of irrigators, engineers, attorneys, conservation organizations, and technical experts with decades of experience working at the intersection of agriculture and water management in the Gallatin Valley. This policy memo provides the basis for recommendations to consider irrigation infrastructure in the Northwest Bozeman Area Plan. Issue Analysis In the mid-1800's, farmers dug ditches and canals to deliver water diverted from a source, like the Gallatin River or Middle (Hyalite) Creek, to fields miles away to irrigate crops. Today, agricultural water users continue to operate and maintain nearly 2,000 miles of irrigation ditches and canals across the Gallatin Valley. The rights of water users and ditch operators are defined in Montana Code Annotated (MCA), which recognizes a prescriptive easement for the path of the ditch and a secondary easement granted for access for operations and maintenance (MCA 70-17-112). Bozeman's development code follows the protections set forth in MCA in the process of land use planning and decision-making. Through Bozeman's code, alterations like relocation, realignment, or encroachment of a ditch are discouraged, though, as laid out in MCA 70-17-112, are allowed with written consent from the facility owner (Sec. 38.310.010. - GallatinWater ■ ■ COLLABORATIVE POLICY MEMO Agricultural water user facilities). These regulations apply to all subdivision and development applications under City jurisdiction. As Bozeman has grown, development has increasingly intersected with the valley's irrigation ditch network. Projects commonly propose relocating or piping ditches, narrowing easements, constructing road crossings, or utilizing irrigation facilities to convey stormwater runoff. While many of these modifications may be appropriate individually, the cumulative effect can impact the functionality and viability of the ditch system. Irrigation ditches are sized to carry a specific amount of deeded water. Increased flow volumes from development-related inputs like stormwater and construction dewatering can cause flooding, alter water quality, increase maintenance demands, and ultimately influence the conveyance of water to downstream users, urban creeks, and return flows to the East Gallatin River. As growth rates have increased, irrigators have reported that these additional inputs related to land use change have placed growing strain on the irrigation ditch system and those responsible for managing it. While water users and ditch companies are responsible for ditch infrastructure, their operation provides public benefits in our watershed. Beyond delivering irrigation water, these facilities have become an integral component of the Gallatin Valley's hydrologic system. As water moves through unlined canals and ditches, it infiltrates into the underlying aquifer, recharging groundwater, raising seasonal water tables, and sustaining late-season flows in our streams and creeks. While piping a ditch preserves its ability to convey deeded irrigation water, it eliminates many of the hydrologic benefits provided by open channels, including groundwater recharge through seepage. As the Northwest Bozeman Area urbanizes, planning decisions will determine whether these broader watershed functions are maintained or lost, shaping the long-term capacity of the irrigation network to support agricultural operations, groundwater recharge, and healthy stream systems. Recommendations The Northwest Bozeman Area Plan provides a unique opportunity to proactively integrate irrigation infrastructure into future land use before development patterns are established. In order to protect the watershed functions provided by the network, the Open Channels Working Group recommends the following. 1. Keep the channels open. The Area Plan should establish preservation of open irrigation channels as a guiding planning principle wherever feasible. Open channels provide groundwater recharge, flood conveyance, habitat, and future water management opportunities that are diminished when facilities are routinely piped or enclosed. Recognizing these public benefits within the plan will help ensure future development considers the long-term value of maintaining open channels. 2. Protect opportunities for managed aquifer recharge. The Gallatin Valley's ditch network is a critical source of aquifer recharge, sustaining existing and new water use for the Valley's growing population. Currently, the Gallatin Conservation District, in GallatinWater ■ ■ COLLABORATIVF POLICY MEMO partnership with the Middle Creek Ditch Company, WGM Group, and the Gallatin Water Trust, is advancing aquifer recharge projects that utilize existing ditch infrastructure to deliver surface water to constructed infiltration facilities. These aquifer recharge projects are intended to sustain critical water infrastructure, improve aquifer conditions, and create opportunities for water exchanges throughout the Gallatin Valley. These projects will be able to be implemented on existing ditch infrastructure throughout the valley, including those serving the northwest planning area. This is important to consider in the Northwest Bozeman Area Plan as the Gallatin County Future Land Use Map identifies significant recharge potential within the plan boundary through the aquifer recharge overlay layer. 3. Create regional stormwater solutions. The City has approximately 1,500 stormwater detention and retention facilities, including about 1,000 that are privately owned and maintained. Many are not functioning as intended due to deferred maintenance, high groundwater, or design limitations, increasing the risk that untreated stormwater will discharge directly to streams and irrigation ditches. A regional stormwater facility could centralize stormwater treatment and maintenance, reducing system failures that contribute to pollution and flooding. In close coordination with irrigators, portions of the ditch network could be used, where appropriate, to collect and convey stormwater to a centralized treatment facility. Where use of the ditch network is not appropriate, alternative collection and conveyance infrastructure could be incorporated into future development. 4. Continue investing in partnerships with the agricultural community. Although the Northwest Bozeman Area Plan focuses on a defined geographic area, the irrigation network that supports it extends well beyond the plan boundary. Water delivered through the planning area depends on the continued operation and maintenance of upstream irrigation facilities, many of which are experiencing increasing pressure from urban development. For example, the Middle Creek Ditch Company operates primarily outside the plan boundary but its tailwater helps supply Aajker Creek, a primary waterway flowing through the planning area. Continued collaboration with organizations such as the Association of Gallatin Agricultural Irrigators will help ensure that land use decisions reflect operational realities and preserve the regional irrigation network that underpins both agricultural production and watershed health. Conclusion The irrigation network that exists today is foundational infrastructure that already delivers agricultural water, recharges aquifers, supports streams, and connects communities to the health of the broader watershed. Growth will inevitably reshape northwest Bozeman, but we have an opportunity to look at an interconnected water network in the northwest area, and think about how we can best steward the infrastructure and services we already have in place.