Prineville, Ore. – Newly-released state ethics documents show that a longtime former manager — and now board secretary and treasurer — of the Three Sisters Irrigation District engaged in a series of undisclosed conflicts of interest and prohibited uses of office tied to his ownership stake in a Prineville-based manufacturing company, actions the Oregon Government Ethics Commission (OGEC) staff says repeatedly resulted in private financial benefit.
The proposed stipulated final order — signed by Three Sisters Irrigation District Board Secretary/Treasurer and long-time former district manager Marc Thalacker — outlines multiple instances in which Thalacker directed or approved district business with Krah USA LLC, a local high-density polyethylene pipe manufacturer in which he holds a 12.5 percent ownership interest and previously worked as a consultant for Krah between 2020 and 2023 during his time as TSID’s manager.
According to the settlement findings, Thalacker:
- arranged transportation and equipment rental work with Krah USA while serving as district manager,
- directed TSID employees to perform reimbursed labor for the company across several years, and
- later, as a sitting board member, voted to approve multiple invoices paying Krah USA more than $12,000 for labor and materials without publicly declaring an actual conflict of interest or recusing himself.
Commission investigators concluded that “but for” his official position with the district, Krah USA “would not have had the same opportunities to obtain a financial benefit,” describing the conduct as prohibited use of office under state ethics law.
Under the proposed settlement, Thalacker agreed to waive his right to a contested hearing and to pay a $4,000 civil penalty, with the agreement still pending final approval by the Commission.
The formal investigation into Thalacker was launched following a unanimous vote by the Commission in July, 2025, following its initial preliminary investigation and report presented by investigators. Thalaker retained legal counsel and was represented by attorney Aaron Landau before the commission.
Pattern of undisclosed conflicts tied to business ownership
The order details that Thalacker first acquired his stake in Krah USA in December 2022 while still serving as district manager, and that the company is classified as a “business with which he is associated” under Oregon ethics law. During and after that period, TSID repeatedly purchased materials and services that benefited the company — including pipe purchases, workforce support from district employees, and reimbursed field labor — without Thalacker filing written conflict-of-interest disclosures as required.
Thalacker was also required to make disclosures of the potential or actual conflicts of interest during public meetings.
In 2024 alone, TSID paid Krah USA a total of $12,277.40 across four separate invoices that Thalacker voted to approve as a board member, despite being “met with actual conflicts of interest,” the Commission wrote in the proposed order.
The order characterizes the violations as spanning both his tenure as an employee-manager and his later role as an elected official — including failures to disclose conflicts in writing as a manager, and failures to publicly announce or refrain from participation as a board officer.
The settlement surfaces as the OGEC is already conducting a separate, ongoing investigation into TSID Board Vice President Karl Nulton, following allegations that he continued irrigating during last summer’s restricted deliveries and may have received water access “but for his position on the board,” as previously reported by the Prineville Review and our media partners at KTVZ News.
Commissioners voted in November to move that matter to a formal investigation after a preliminary review, stating more information was needed to determine whether Nulton exercised authority unavailable to other patrons during the curtailment period.
The Thalacker settlement — while procedurally distinct — significantly widens the scope of ethical issues now facing the TSID Board, showing a multi-year pattern of self-interested transactions involving senior district officials and a business.
Once approved by the Commission, the stipulated final order will serve as the final resolution of the case, with Thalacker agreeing not to challenge the findings in court.
The Prineville Review has requested comment from the Three Sisters Irrigation District, Krah USA, and Thalacker regarding the findings and whether additional policy or oversight changes will be pursued in response. We will update this story should we receive any comments.
Further details from the OGEC will become public after formal finalization of the order. There were not yet any updates on the investigation into Nulton’s alleged ethics violations.
Note: This story was updated to include links to the stipulated final order and details about the investigation by OGEC being voted on in July of 2025.
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Mr. Alderman is an investigative journalist specializing in government transparency, non-profit accountability, consumer protection, and is a subject matter expert on Oregon’s public records and meetings laws. As a former U.S. Army Military Police Officer, he brings a disciplined investigative approach to his reporting that has frequently exposed ethics violations, financial mismanagement, and transparency failures by public officials and agencies.
