Benton County Water Conservancy Bd. v. Dep't of Ecology

CourtCourt of Appeals of Washington
DecidedFebruary 28, 2023
Docket38803-4
StatusPublished

This text of Benton County Water Conservancy Bd. v. Dep't of Ecology (Benton County Water Conservancy Bd. v. Dep't of Ecology) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Benton County Water Conservancy Bd. v. Dep't of Ecology, (Wash. Ct. App. 2023).

Opinion

NOTICE: SLIP OPINION (not the court’s final written decision)

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FILED FEBRUARY 28, 2023 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

BENTON COUNTY WATER ) No. 38803-4-III CONSERVANCY BOARD, ) ) Respondent, ) ) v. ) PUBLISHED OPINION ) WASHINGTON STATE DEPARTMENT ) OF ECOLOGY, ) ) Appellant. )

PENNELL, J. — The Benton County Water Conservancy Board petitioned the

superior court for judicial review under the Administrative Procedure Act, chapter 34.05

RCW, seeking to enjoin the Department of Ecology’s refusal to accept and record certain

agreed administrative divisions of water rights. The trial court ruled in favor of the Board,

but we reverse. The Board has not established standing to challenge Ecology’s

administrative division decisions. The petition must therefore be dismissed.

WATER RIGHTS BACKGROUND

Since the water code was initially adopted in 1917, Washington’s waters have

been considered public property, not subject to private ownership. RCW 90.03.010;

RCW 90.44.040. 1 Although private individuals cannot own water, they can acquire the

Surface water rights are addressed in chapter 90.03 RCW. Ground water rights 1

are addressed in chapter 90.44 RCW. This case involves only surface water rights. For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.

No. 38803-4-III Benton County Water Conservancy Bd. v. Dep’t of Ecology

right to appropriate water for beneficial use. Id. This is what is known as a water right.

Dep’t of Ecology v. U.S. Bureau of Reclamation, 118 Wn.2d 761, 766, 827 P.2d 275

(1992).

Water rights attach to the “land or place upon which the same is used.”

RCW 90.03.380(1). Nevertheless, in appropriate circumstances, the right “may be

transferred to another or to others and become appurtenant to any other land or place

of use.” Id. The Washington Legislature has tasked the Department of Ecology with

processing applications to change or transfer water rights. Id. The change application

process is not automatic. Before approving an application to change a characteristic of a

water right, including its place of use, Ecology must assess whether the change can be

made without injury or detriment to existing rights. Id. This involves assessing whether

the water right has been “beneficially used to its full extent.” Okanogan Wilderness

League, Inc. v. Town of Twisp, 133 Wn.2d 769, 779, 947 P.2d 732 (1997). If Ecology

approves a change application, it must issue a certificate, record the certificate internally,

and make a duplicate copy available for the county auditor. RCW 90.03.380(1).

An assessment of the term “beneficial use” is critical to understanding the contours

of a water right. “‘[B]eneficial use’ encompasses two principles. . . . First, ‘beneficial

use’ refers to the types of activities for which water may be used (e.g., irrigation or

2 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.

No. 38803-4-III Benton County Water Conservancy Bd. v. Dep’t of Ecology

agriculture) . . . . Second, ‘beneficial use’ determines the measure of a person’s water

right (i.e., a person is entitled to the amount of water he or she has traditionally put to

beneficial use).” Cornelius v. Dep’t of Ecology, 182 Wn.2d 574, 605, 344 P.3d 199

(2015).

If a water right holder ceases putting water to beneficial use, the right may

be subject to relinquishment. See RCW 90.14.130-.180; Dep’t of Ecology v. Aquavella,

131 Wn.2d 746, 757-58, 935 P.2d 595 (1997). When a water right is relinquished, it

reverts to the State of Washington. RCW 90.14.130.

A water right holder can avoid relinquishment by temporarily transferring its

water right to the State through its trust water rights program, which is managed by

the Department of Ecology. RCW 90.14.140(2)(h). “Trust water rights acquired by the

[S]tate shall be held in trust and authorized for use by the [D]epartment [of Ecology] for

instream flows, irrigation, municipal, or other beneficial uses consistent with applicable

regional plans for pilot planning areas, or to resolve critical water supply problems.”

RCW 90.42.040(1). A water right temporarily donated to the trust water rights program

eventually reverts back to the certificate holder, retaining its original use characteristics.

RCW 90.42.080(9).

Over the years, the State has adopted procedures for facilitating uncontested water

3 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.

No. 38803-4-III Benton County Water Conservancy Bd. v. Dep’t of Ecology

right transfers.

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