One Resident Already Opposes Hatchery Plans

December 02, 2009


Salmon, wild fish, the Icicle River

watershed, and millions of dollars in federal stimulus money all hang in the balance. The first public meetings

will be held today to unveil the Leavenworth National Fish Hatchery’s proposed plans for a new water


"5">       Isaac Kaplan-Woolner spoke with a longtime local watershed activist who

has been following the hatchery water issue for the past decade:

120109 hatchery


“hey you’re


Dick Rieman is Vice President of the Wild Fish Conservancy, and co-founder

of the Icicle Creek Watershed Council.

size="5">Both public meetings will be held Tuesday in the Alpine Room of the Enzian Inn in Leavenworth. The

first meeting is from 1:00 until 3:00 p.m. followed by a second meeting at 6:30.



Here is an alternative proposal for the Leavenworth National

Fish Hatchery written by Dick Rieman:





style="margin: 0in 0in 0pt" align="center">A Solution to the Coming Crisis

 at the

National Fish Hatchery


Leavenworth National Fish Hatchery appears to be faced with two critical issues:

·        The first one is excessive

phosphorus in the Hatchery’s discharge water. The October 2009 Draft Wenatchee River Watershed

Dissolved Oxygen and pH Total Maximum Daily Load Publication by the Department of Ecology (DOE) claims the

Department has measured a phosphorous concentration of 14 ppb in Leavenworth National Fish Hatchery (LNFH)

discharge water. The 401 Certification Order No. 7192 requires the Hatchery to reduce its’ phosphorous

discharge load to 5.7 ppb within five (5) years of issuing the Hatchery a National Pollution Discharge Elimination

System permit. The October 2009 Draft referred to above points out that phosphorus removal technology limits

will not allow LNFH to meet this Waste Load Allocation. 

The hatchery discharges approximately 42 cfs which

means that 1 ppb is contained in each 3 cfs the hatchery discharges into Icicle Creek (42/14 = 3). If the

only means of reaching its’ phosphorus limit turns out to be a reduction in water volume, the Hatchery would

have to reduce discharge by 24.9 cfs (14 – 5.7) x 3 = 24.9). This reduction means the Hatchery might be

required to operate on 17.1 cfs (42 – 24.9 = 17.1) instead of 42 cfs during the critical phosphorous months

July, August and September.

Phosphorous causes periphyton alga to grow in the summer months when water is warm and there is

plenty of daylight. The alga consumes enough oxygen from the water to threaten aquatic life. It is the

lack of dissolved oxygen in the water, not phosphorous, that is the root of the problem.

"margin: 0in 0in 0pt">           

style="margin: 0in 0in 0pt 1in; text-indent: -0.25in">·        The other issue is how the Hatchery plans to meet

minimum instream flows established by the State Department of Ecology (DOE). The 401 Certification Order

requires that an Instream Flow Incremental Methodology (IFIM) study be conducted and submitted within three years

of issuance of the Order. At that future date the IFIM team will recommend stream flows. Once approved

by DOE the Order requires that the USFWS incorporate the recommendations into the Final Flow Management



Hatchery has a water right to 16,000 acre feet from Snow Lakes. In 1937 a ½ mile tunnel was drilled

through a granite rock ridge that accesses the bottom of the larger of the two lakes. Because of the

topography of the lake bottom access is limited to approximately 12,000 acre feet of water. Water from Snow

Lakes is used every year by the Hatchery because the Hatchery has a junior water right to a two irrigation users

that consume most of Icicle water beginning around the middle of August. If the Hatchery consumes its’

full water right of 42 cfs from this reservoir it would consume 83 acre feet per day. Recent studies indicate

about 7,000 acre feet can be drawn out of the reservoir and still have a 65% chance of full recharge during the

winter months. A consumption of 83 acre feet per day from a reservoir of 7,000 acre feet would supply the

Hatchery for 84 days at 42 cfs. The Hatchery usually opens the valve to Snow Lakes around the middle of

August. The water is discharged into Nada Lake where it exits the lake into Snow Creek, a tributary to Icicle

Creek. The water flows down Icicle Creek .9 miles to the Hatchery’s diversion dam.

style="margin: 0in 0in 0pt 1.5in"> 

In the past no

consideration was given to flows below the Hatchery’s point of diversion. When the irrigators shut

their canals the Hatchery typically shut the Snow Lakes valve. Extra water flowing past the Hatchery’s

diversion was typically diverted into a man-made canal by closing the gates of a dam (Dam 2) located .7 miles

further downstream from the Hatchery’s diversion dam. This water was used to recharge the shallow

aquifer so that Hatchery wells located along the canal could supply water to the Hatchery beginning in

December. A one mile reach of the natural bed of Icicle Creek was essentially dewatered. 

style="margin: 0in 0in 0pt 1.5in"> 

Because the Hatchery

is now required to obtain a pollution discharge permit under the Clean Water Act past water management operations

will have to change.

The unknown is the outcome of the IFIM study and how much water the study will recommend as a

minimum flow below the Hatchery’s point of water diversion. An IFIM minimum flow of 30 cfs, for

example, would require an additional 60 acre feet per day for a total of 144 acre feet per day during the dry

summer months. Drawing this amount of water from a 7,000 acre foot reservoir would supply the Hatchery with

49 days of water.

A carefully managed Snow Lakes water budget may supply the Hatchery with its’ full water right,

recharge Hatchery wells and provide minimum flows required by the Department of Ecology.

"margin: 0in 0in 0pt 1.5in"> 

However, an analysis of

Icicle Creek flow records indicates that since 1936 there is a trend for more days at low flows (< 85 cfs) and

extending into more months. For example, between 1937 and 1972 there were 181 days when Icicle Creek flows were at

85 cfs or less at the USGS gage station. Between 1973 and 2008 there were 642 days when Icicle Creek flows

were at 85 cfs or less at the USGS gage station. (Estimations of Icicle Creek flows using 16% of Wenatchee

River flows at the USGS gage at Monitor had to be made between 1973 and 1993 because the Icicle USGS gage station

was decommissioned during that time)


"margin: 0in 0in 0pt 1.5in">Glaciers in the Stuart Range are receding which contributes to the observed lower

flows. Also the climate is changing resulting in dryer summer months. This is not limited to Icicle

Creek. This trend is prevalent throughout the Western United States.

Minimum instream flows and reduced phosphorus loading

overlap at about the same time of year from the middle of July including August and September. Phosphorus

issues begin to decline in September because of shorter days and cooling water. Low water issues are prevalent in

October and in some years extend into November and December and occasionally extend into January, February and

recently even March. 

The Department of Ecology’s Order No. 7192 did not establish firm limitations for flows in Icicle

Creek. Instead, the Department delayed minimum flow numbers for four years. Likewise, the Department

delayed compliance with phosphorus loading for another five years. 

This uncertainty places recently planned construction in

limbo. Can the Hatchery proceed with construction assuming the minimum instream flows will be low enough so

they can comply with the new limits and still supply the Hatchery with its’ full water right of 42 cfs?

 Can the Hatchery assume they will have enough water to supply their wells with water while satisfying

Ecology’s minimum instream flows and their own needs at the Hatchery? What happens if the Hatchery

cannot lower their phosphorus load to acceptable limits? If construction proceeds regardless of these

uncertainties and compliance becomes impossible in the future, will the new structures operate at only one quarter

of their operational design? There are certainly other questions that could be added to this list.

style="margin: 0in 0in 0pt"> 

It appears that the Hatchery’s

standard operating procedures of the past 70 years may have to abruptly change from the 1937 vision of producing

hatchery fish. In order for the hatchery to operate safely within the ecological limits of Icicle Creek on

which the hatchery depends, the hatchery may have to reduce its water consumption by as much as 50% during the low

flow months.  The hatchery may also have to reduce its phosphorous discharge from July to the middle of

September by reducing the amount of water it discharges into Icicle Creek.

Most residents of the Leavenworth Valley including thousands of

people outside the Valley consider the Leavenworth National Fish Hatchery an asset. People cross-country ski

on Hatchery property, the performing arts have a theater on Hatchery grounds, the Tribes have an important fishery

below the spillway dam, people bird-watch along the Hatchery’s undeveloped reach of river, people ride

horses on the 157 acre grounds, an educational facility is located on hatchery property and wildlife uses the rich

riparian ecology linked to upland terrain zoned to remain undeveloped.

The Hatchery is a good neighbor. The vast majority of

people who live here do not want to see the Hatchery fail and move to another location where there is an adequate

water supply.

One solution

to this problem would be for the hatchery to no longer raise fish in their facility.  Instead, the hatchery

would be used to imprint Coho salmon as it successfully does today and change from raising Spring Chinook salmon

to imprinting them as they do Coho salmon. 


"margin: 0in 0in 0pt">Specifically, this is how changing the hatchery to an imprinting hatchery would


1.       Spring Chinook arrive at the Hatchery around May 15.  There

is plenty of water this time of year so the hatchery could divert and discharge their full water right of 42 cfs

if needed.  Minimum flows for Icicle Creek would not be an issue and neither would phosphorus

loads. Hatchery Chinook would be attracted to hatchery discharge water.

2.      The hatchery would leave their fish ladder open for the entire period of the

run (May 15th, through June to July 7th).  Water consumption by the hatchery would be up to 42 cfs

if needed.

3.       The Tribes would fish the spillway pool for Hatchery

Chinook salmon.  Water consumption by the hatchery would be 42 cfs or as needed.

4.      Hatchery Chinook salmon in excess of what are required for broodstock and

hatchery Chinook that are not caught by the Tribal fishermen would be held in a new surplus holding pond. 

Hatchery Chinook in the surplus holding pond would be surplused to the Tribes.  (Surplused fish traditionally

go to elders of the tribes) After the middle of July when the flesh quality of the Chinook salmon is no

longer desirable for consumption the last of the surplus Chinook would be surplused and the new surplus holding

pond would be deactivated.

5.       Water consumption by the hatchery after July

7th would be reduced to 12 cfs to supply water to the Chinook broodstock collection pond. The only

fish at the hatchery would be about 1,200 Chinook broodstock.

6.       Since no fish are being raised at the hatchery and broodstock do not

feed, phosphorous concentrations would be only associated with broodstock feces resulting in phosphorous

concentrations close to zero in hatchery discharge water between the end of July through August and into September

the time when phosphorus is a problem in Icicle Creek.  Water diversion to the Hatchery during this time

would be reduced to 12 cfs. The remaining water from the Hatchery’s water right would be used as needed

to maintain Icicle at or above the flows recommended by the IFIM study.

7.      In

September adult hatchery Chinook would be killed and the broodstock holding pond would be cleaned and prepared to

receive Coho salmon that arrive toward the end of October. 

8.      Chinook salmon broodstock would be held until

the eggs are ripe (end of August and beginning of September) at which time the eggs would be fertilized and held

until the eggs are in the eyed stage (end of October).  The incubating eggs could be watered using well five

and six which are wells that draw water from the deep aquifer at an average temperature of

53OF. At these temperatures the fertilized Chinook salmon eggs would reach the eyed stage within

30 days. When salmon eggs reach the eyed stage they can be safely handled and shipped to another hatchery

where they would be raised through the various stages of development to the smolt stage. During the

incubation stage from fertilization to the eyed stage .27 cfs (121 gpm) would be used from the two


9.      The rearing

hatchery of choice would be one that is as close to the Leavenworth Hatchery as possible located on a river with

plenty of water. Here, the fish would be raised to within 3 months of the smolt stage (March of the following


10.   Beginning around October 15th Coho salmon begin to appear at the

Leavenworth Hatchery at which time the Hatchery might activate the broodstock collection holding pond and open its

ladder to collect Coho broodstock (about 600 fish).  The remainder of the returning adults would be allowed

to spawn naturally in Icicle Creek. The hatchery would operate at 10 cfs to assure that minimum instream

flows are being met and so there is enough water to operate the fish ladder. 

11.   If there are

enough returning Hatchery Coho salmon in October and November, a Tribal fishery could be operated in the spillway

pool and the surplus holding pond could be activated to receive surplus Coho salmon which would be surplused to

the Tribes. However, attracting Coho to a surplus holding pond may not harmonize with the goal of

reestablishing Coho salmon in the Wenatchee Watershed. In that event the surplus holding pond would not be


12.   Broodstock Coho salmon would be held in a maturing pond until the eggs are ripe,

(sometime in December).  During the time Coho are being held until ripe the only action at the hatchery would

be to hold the Coho which means the hatchery would operate on approximately 6 cfs.

13.   Coho eggs

would be incubated until the eyed stage is reached using well five and six. The eyed stage would be reached

toward the end of December.  The hatchery would operate on less than .27 cfs from well 5 and 6 since the only

operation at the hatchery would be to incubate the Coho salmon eggs to the eyed stage.  Coho broodstock would

have been killed by this time and surplus Coho would have been surplused or left in the river to spawn. The

surplus holding pond would be deactivated if used. 


style="margin: 0in 0in 0pt 0.75in; text-indent: -0.25in">14.   In December or January the eyed Coho

eggs would be transported to a hatchery as close to the Icicle as possible where they would be raised.

style="margin: 0in 0in 0pt"> 

15.In March the young Coho and Spring Chinook of the prior year would be transported to the

Leavenworth hatchery to be imprinted (acclimated) for a three month period, March, April and May.  The

hatchery would operate on 42 cfs of Icicle Creek water during the imprinting (acclimation) process if

needed. These fish could be fed a full diet of palletized fish food without concerns about

phosphorous. At this time of year the shallow aquifer would be fully charged so that well water could be used

to warm Icicle Creek surface water resulting in a large smolt giving them an advantage when released.

style="margin: 0in 0in 0pt"> 

16. Return to number 1 above

and start the process over again.

There would be

no need to be concerned about hatchery fish getting above the hatchery’s water intake and transmitting to

the hatchery diseases via the hatchery’s water supply because the hatchery would not be raising fish. 

In this scenario, the hatchery may be using ground water entirely to incubate the eggs so there would be no chance

of disease entering the hatchery via its’ surface water supply system.

When the hatchery is holding young fish for imprinting

(acclimation), Chinook and Coho runs are over with so there is no danger of the hatchery getting diseases from

returning adult salmon and impacting the fish being imprinted (acclimated).

The question still remains about the need for Dam 5 and the Dam

2. These dams relate to the Tribal fishery and the perceived need to contain returning Spring Chinook salmon

in the spillway pool to give Tribal fishermen every chance to catch them.

It appears there are tools available to contain most returning

Spring Chinook salmon in the spillway pool long enough to provide a quality edible fish for the Tribal fishery

without resorting to physical blockage in the Historic Channel.  Keeping the hatchery’s fish ladder

open for the entire length of the fish run while selecting a genetic cross-section and sending excess fish to a

surplus fish holding pond appears to be one method. Another method may be to separate spillway pool water

from natural Icicle water in the Historic Channel so they join further downstream making it more difficult for

fish in the spillway pool to stray up the historic channel.

However, the need for Dam 5 and Dam 2 to keep hatchery fish form

swimming above the Hatchery’s water intake and transmitting disease to the hatchery would have been

eliminated under the acclimation plan. 


"margin: 0in 0in 0pt">There is the need to find a hatchery or enlarge a hatchery to accommodate rearing

1,625,000 Chinook salmon to the smolt stage and approximately 600,000 Coho salmon to the smolt


With the need

to keep returning salmon from getting above the hatchery’s water intake no longer an issue and while

assuring a quality Tribal fishery in the spillway pool two reasons to keep Dam 5 or Dam 2 in place would be



"center">DAM 5

The footing of Dam 5 restricts the elevation of

Icicle Creek so that the stream cannot seek a natural elevation which forces the stream upstream of the dam into a

wide shallow slow moving reach. This condition elevates water temperature during the hot summer low flow

months and contributes to why Icicle Creek is listed as one of Washington State’s 303(d) list of impaired

waters not meeting state water quality standards. For this reason, Dam 5 should be replaced with a bridge

designed for light vehicle traffic. (The bridge would serve as ingress and egress to one resident)




Fish can swim past Dam 2 at certain flows but the dam restricts

fish passage at flows which would be passable if the dam was removed. While it is true the dam can be used by

managers to control flows in the Historic Channel of Icicle Creek to maintain valuable habitat that would not

normally be there, Dam 2 is not essential for that purpose. The same management goal can be achieved by

removing Dam 2 and setting the invert elevations to the Historic Channel and the Hatchery’s Canal so that

during high flows habitat in the Historic Channel is not lost. Also, the shape of the bank at the entrance to

the Historic Channel once Dam 2 is removed can help passively control flows in the Historic

Channel. Therefore, Dam 2 should be removed and replaced with a bridge designed for heavy vehicle

traffic. (The bridge would be used in connection with the Hatchery’s spillway bridge to serve single

resident construction activity and to serve construction activity on the Icicle/Peshastin Irrigation Canal via an

access road through the private residence)


"margin: 0in 0in 0pt">If the Leavenworth Hatchery was converted from a rearing hatchery to an imprinting

(acclimation) hatchery, a plan to rehabilitate the hatchery’s water supply line could be written using an EA

because no major impact to the stream would take place. The EA would include replacement of the water supply

pipeline, a modern fish screen and a new surplus fish holding pond for surplus Chinook salmon. Approximately

$6,000,000 of stimulus money would be used to complete this construction. The remaining $8,000,000 of the

$14,000,000 of stimulus money allocated to the Leavenworth Hatchery could be used to help enlarge a hatchery where

Leavenworth fish would be raised.

The current pumping plan would be abandoned in favor of supplying water to the hatchery using gravity for

the following reasons:

§         Pumping requires a new dam in place of Dam 2

to maintain the pumping pool at elevation 1130 feet above sea level.

§         The substrate where the

pumping pool is planned transmits water to the shallow aquifer at an unknown rate making it more difficult to

maintain a working pool elevation during low flows.


style="margin: 0in 0in 0pt 75pt; text-indent: -0.25in">§         The electrical cost of pumping is estimated at

$52,000 per year increasing the cost of operating the Hatchery. Gravity is free.


"font: 7pt 'Times New Roman'">         Building a new

dam in place of Dam 2 will require an EIS which will place construction outside the time limit for stimulus


§         Operating the pumps in place of a gravity

option unnecessarily places about 1,000 tons of additional carbon into the atmosphere per year.

"margin: 0in 0in 0pt"> 


Construction costs to install a pumping/pool water supply system are estimated at $10,000,000

compared to an estimated cost of $6,000,000 to replace the Hatchery’s water supply pipe.

"margin: 0in 0in 0pt"> 

Building a sluicing gate in the diversion

dam at RM 4.5 and providing proper fish passage past the diversion dam might be included in an EA. However,

if that is not possible then upgrade work on the diversion dam would have to be included in an EIS. Likewise,

performing work at the confluence of the Historic Channel and the spillway pool might be included in an EA but it

is possible that work of this nature cannot be done without an EIS. 

An EIS would need to be written to gain approval under NEPA to

remove Dam 5 and Dam 2.  However, because of the large amount of research already accomplished on Icicle

Creek this process would take less time and would be ready for implementation within two years. Other items

mentioned above might have to be included in this EIS.


style="margin: 0in 0in 0pt">The estimated cost of removing Dam 2, Dam 5, building a new light vehicle bridge in

place of Dam 5, building a new heavy vehicle bridge (H-20) in place of Dam 2, instream work at the confluence of

spillway pool and the natural channel of Icicle Creek, building a rock fish ramp and a slice gate at the gravity

feed diversion dam would cost about $4,000,000.


"margin: 0in 0in 0pt">Finally, if the Leavenworth Hatchery is converted from a rearing hatchery to an imprinting

(acclimation) hatchery, there would be no need to operate hatchery wells beyond the natural capacity of the

shallow and deep aquifers. There would be no need to divert Icicle Creek water into the Hatchery’s

Canal during low flows in Icicle Creek to charge an exhausted shallow aquifer with water.

"margin: 0in 0in 0pt"> 

The Hatchery could easily meet its

phosphorous limits and easily comply with any minimum instream flows recommended by an IFIM study.

style="margin: 0in 0in 0pt"> 

The Snow Lakes reservoir would not

have to be stressed to ultimate limits.

In January 1938 Director of Fisheries B. M. Brennan prepared a report for the Bureau of

Reclamation titled, “Report of the Preliminary Investigations Into the Possible Methods of Preserving the

Columbia River Salmon and Steelhead at the Grand Coulee Dam”. In this 121 page report it was

anticipated that 21,500,000 blue-back eggs, 14,000,000 steelhead eggs and 41,000,000 Chinook eggs for a total of

76,500,000 eggs should be planned for in the design of a hatchery. 

At that time the Leavenworth National Fish Hatchery was the

largest hatchery in the world and expectations were indeed grand. Today Leavenworth incubates 1,625,000 eggs,

and raises them to the smolt stage to be released to the ocean.

Leavenworth was an experiment based on incomplete

knowledge. Dr Brennan reports that:

“The success of this portion of the plan depends upon the correctness of the following

assumption: That salmon and steelhead that have migrated to the sea will return to the river in which

they were raised, not to the stream in which their immediate ancestors were raised; that is, that the home stream

instinct is acquired rather than hereditary.” 


style="margin: 0in 0in 0pt">Dr. Brennan goes on to describe knowledge about salmon at that time:

style="margin: 0in 0in 0pt"> 


difficulty in designing holding ponds for the quantity of fish that must be handled is enhanced by the almost

complete lack of knowledge of the actions of the fish in a natural state… Perhaps it is necessary for the

Chinook and steelhead to have a certain strength of current to fight against to use up the stored up energy and

complete the physiological process known as ‘ripening’”. 

Finally, Dr. Brennan recommended that:

"margin: 0in 0in 0pt"> 

“[i]t is

believed that the natural condition of the stream during the holding period should be duplicated as closely as

possible. It is recommended that the natural bed of Icicle Creek be used for the holding


At the very

beginning Leavenworth was scrambling for water and scrambling for a large enough facility. Today, 70 years

later, we are faced with diminishing water supplies not increasing supplies. We are faced with diminishing

water quality. 

Realistically the Hatchery cannot continue as it has in the past.
I am suggesting that we move the Hatchery from 1938 into the

21st Century and use the knowledge we have today to adjust the Hatchery to the ecology of our small valley without

sacrificing the Hatchery’s productivity.


"margin: 0in 0in 0pt">Dick Rieman



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