Comment on the State’s Integrated Water Resource Strategy (IWRS) Update

Note: We’re currently between Oregon Water Resources Department comment periods for the IWRS update. When the state resumes taking comments we’ll let you know — thanks!

The Oregon Water Resources Department (OWRD) will soon resume collecting public comments on its ongoing update of the state’s Integrated Water Resources Strategy (IWRS).

Originally adopted in 2012 with significant input from WaterWatch of Oregon and other conservation groups, tribes, cities, industry and other stakeholders, the IWRS serves as the blueprint for meeting Oregon’s instream and out-of-stream water needs into the future and plays a critical role in directing state priorities and legislative funding.

The IWRS is required, by statute, to be reviewed and updated periodically. The law purposefully calls for an update, not a total reworking. The 2017 version, by design, retained the original goals, objectives and guiding principles from the 2012 version, and focused that update on refreshing information, filling important gaps, and shoring up or adding new recommended actions.

Stakeholders were informed early on that would also be the scope of the 2024 update.  However, despite early representations, the OWRD made an internal decision to wholly rework the document rather than build upon the existing structure that was developed after years of inclusive, transparent, and broadly supported work.

In March, OWRD released its 2024 IWRS update for public comment. While we support some of the added directives, we do have serious concerns that the wholesale restructuring removes fundamental headings, chapters and direction, elevates planning above keystone water management, veers from the law’s directives to understand and meet both instream and out of stream needs, removes balance and otherwise undercuts the existing IWRS — a document that has been incredibly helpful over the past decade in securing funds for agency programs and moving forward on policy initiatives.

Long story short, the OWRD is attempting to fix something that is not broken — and is weakening it in the process.

We’d like you to express your concerns and make your voice heard to ensure the 2024 version of the IWRS continues to advance water management, climate change and pathways to meet instream needs as part of Oregon’s water future. Some of our suggested talking points include:

  • Support ecosystem additions: Support the addition of new actions that advance instream, ecosystem, water quality, climate change and equity initiatives.
  • Support increased funding of state agencies to do water work: Full implementation of the strategy is dependent on robust funding of state agencies, as well as state agency coordination on water work. To be clear the 2024 version does put more attention on this, and deserves support.
  • Elevate water management: OWRD must focus greater attention on water management. Rigorous, smart water management — including enforcement, regulation and the modernization of laws and policies to ensure a sustainable water future — should be front and center of any state water strategy. The 2024 version elevates attention on voluntary planning and partnerships (making it one chapter of four), but does not grant improved, smart water management the same gravitas or urgency.
  • Ensure climate change is front and center: The 2024 IWRS proposes to remove the stand alone subsection on climate change found in the 2017 version. While additional “example actions” have been included in the 2024 IWRS related to climate, which we support, the OWRD has removed the previous standalone subsection directing attention and action on climate change. This reorganization sends Oregon backwards and signals that climate change adaptation and resiliency is not a priority for the state’s water future.
  • Don’t fix what isn’t broken: We oppose the wholesale restructuring of the IWRS. This change in direction was an internal decision that did not arise out of the minimal public engagement efforts the OWRD undertook on the update of the strategy. The 2012 IWRS was developed after years of robust and transparent public engagement, with the intent being it would serve as the cornerstone framework for future iterations. The siloed decision to rework the whole document undercuts years of work that resulted in a clear and cohesive document that addressed both instream and out-of-stream needs in a balanced manner directed by governing laws.
  • Bring back balance: The new iteration removes, relocates, or rewords key directives meant to ensure balanced attention to instream and out-of-stream needs. This could dilute agency and legislative attention to instream needs. The OWRD must reinstate balance into the framework.
  • Further engagement is required: Unlike the 2012 and 2017 versions of the IWRS that were developed after years of vigorous public engagement and actual consensus hammered out after many meetings, the OWRD forged ahead with a wholesale restructuring of the 2024 version without the benefit of discussion or consensus within a policy advisory group made up of tribes, conservation groups, agricultural interests, municipal representatives, the governor’s office, state and federal agencies and other stakeholders. This siloed approach is not aligned with the OWRD’s general approach to transparent public engagement, and it is inconsistent with past public engagement on the IWRS. More work is needed.

OWRD should start over by convening a policy advisory group (PAG) that is inclusive. The PAG should update the strategy following the authorizing legislation and, as in prior iterations of the IWRS, with considerable input from a wide variety of stakeholders and interests.

Links to the 2024 draft of the IWRS can be found at the OWRD webpage for the Integrated Water Resources Strategy.

Once resumed, comments will be able to be submitted in one of three ways:

  • Online:  Use the 2024 IWRS Feedback Form at the Oregon Water Resources Department website.
  • Mail: Send your comments to the Oregon Water Resources Department, Attn.: Crystal Grinnell, 725 Summer St. NE, Suite A, Salem, OR 97301.
  • Email: Send your comments via email to

Share this with family and friends who share your concern for Oregon’s rivers and aquifers, and the fish, wildlife and people who depend upon heathy rivers, and thank you as always for your support.