Moses
Deuteronomy 21:4BSB·traditional attribution

bring the heifer to a valley with running water that has not been plowed or sown, and break its neck there by the stream.

Matthew Henry Presbyterian @wholebiblehenry

Care had been taken by some preceding laws for the vigorous and effectual persecution of a wilful murderer (Deu 19:11 etc.), the putting of whom to death was the putting away of the guilt of blood from the land; but if this could not be done, the murderer not being discovered, they must not think that the land was in no danger of contracting any...

Commenting on Deuteronomy 21:1-9

John Gill Reformed Baptist @doctorgill

The elders of that city shall bring down the heifer unto a rough valley,.... Cities being generally built on hills, and so had adjacent valleys, to which there was a descent; but here a rough valley, or the rougher part of it, was selected for this purpose.

Geneva Bible Notes Reformed @genevanotes

And the elders of that city shall bring down the heifer unto a rough valley, which is neither eared nor sown, and shall strike off the heifer's neck there in the valley: (b) That the blood shed of the innocent beasts in a solitary place, might make them abhor the fact.