An announcement posted on the Leavenworth Fish Hatchery Web site blames “deadline constraints” for the decision to re-allocate the funds. The Hatchery earlier announced that a problem with ice on fish screens had delayed publication of an environmental assessment originally promised in early November.

But numerous other obstacles stood in the way of the project, including a newly issued 401 certification order from the state Department of Ecology that held an imposing list of restrictions and deadlines for water-quality and flow quotas on the Icicle. Experts have questioned whether the Hatchery can meet the guidelines, particularly given competing demands for water from the river and global warming trends toward less water available in the river itself.

All things considered, it makes perfect sense for the Hatchery to capitulate on stimulus funding. As The Watchery pointed out repeatedly, the hatchery project never qualified for the funding in the first place. The plan offered little in the way of new jobs, was so far from “shovel ready” that a legal description of it did not even exist at the time funding was announced, and held none of the “green” ecological benefits that President Obama expressed preference for in formulating stimulus guidelines.

“Losing ARRA (stimulus) funding for the hatchery water intake is a disappointing setback, but we remain committed to working with local interests to find a solution that ensures that the hatchery continues to support commercial, recreational, and tribal salmon fisheries,” said Tim Personius, Deputy Regional Director of the BOR.

Although Hatchery officials undoubtedly are displeased with the decision, their refusal to consider public concern and input in announcing their plans in early December contributed untold community bitterness toward the proposal. In an election year, even an off-year, the political consequences of ignoring the voice of the public cannot be understated.

The real shame is that had the Hatchery shown a receptiveness to or flexibility for some of the alternatives put forward on The Watchery, especially in Dick Rieman’s series of informative and forward-looking articles, stimulus funding might have been salvaged. But a “my way or the highway” attitude that included re-damming a river on the way to restoration meant nothing but unrest, opposition and legal challenges down the road.

All that aside, it should be re-emphasized that all parties seek a solution that will keep salmon and other fish runs as well as plant life healthy and abundant on the Icicle. If the goal is to save the Leavenworth Fish Hatchery from inevitable decline or closure, then all parties will — as we’ve argued all along — have to sit down together and come up with a far-sighted, socio-economically beneficial and technologically sophisticated solution to the current impasse over the future of Icicle Creek.

On May 11, 1938, Congress passed the Mitchell Act. The Act is an exceptionally short document for an act of Congress — just one page. Its preamble says it is intended to:

“Provide for the conservation of the fishery resources of the Columbia River, establishment, operation and maintenance of one or more [‘salmon cultural’] stations in Oregon, Washington and Idaho, and for the conduct of necessary investigations, surveys, stream improvements and stocking operations for these purposes.”

The Act recognized that anadromous fish populations were in serious decline, and that the decline was caused by devastation of spawning and rearing habitat from deforestation, pollution, hydroelectric dams and diversion of water for irrigation.

In 1970 there were 25 Mitchell Act (MA) hatcheries, the majority of which were located downstream from Bonneville Dam. Today there are 17 MA hatcheries.

The Leavenworth National Fish Hatchery Complex was authorized by the Grand Coulee Fish Maintenance Project on April 3, 1937 and re-authorized by the Mitchell Act on May 11, 1938. Today the Complex consists of three upper-Columbia River anadromous fish hatcheries constructed by the Bureau of Reclamation as fish mitigation facilities for the construction of Grand Coulee Dam. Although re-authorized by the Mitchell Act, funding was provided though a transfer of budget from the Bureau of Reclamation to the USFWS until 1945. After 1945 the USFWS assumed full responsibility for funding, operations and maintenance of the Complex. The Bureau of Reclamation reassumed funding in 1994; however, the USFWS continues to operate and maintain the Complex.

The Complex is unique because the hatcheries that make it up are the furthest upstream of all original Mitchell Act hatcheries on the Columbia River. Although the Leavenworth NFH is no longer considered a Mitchell Act hatchery, an economic study of MA-funded hatcheries provides relevant information on the efficiency of Columbia River hatcheries. The study was conducted by “The Research Group” in Corvallis, Oregon (TRG) and is titled, “Economic Effects and Social Implications from Federal Mitchell Act Funded Hatcheries”.

Most Mitchell Act Hatcheries have negative benefit-cost ratios because of their relatively low smolt-to-adult survival rates (SARs). In other words, it costs more to raise the smolts than the business they generate, even with the Pacific Ocean providing free nutrition to grow the smolts into adult salmon.

The total number of Leavenworth smolts that become adults is difficult to precisely count. Some Leavenworth fish are caught at sea in the Alaska fishery. Some are caught in the Columbia River in the river fishery. Some spawn with wild fish in the Wenatchee River. Many adult fish return to the Hatchery. Biologists consider these factors as well as coded wire tag reports to arrive at a smolt to adult ratio (SAR).

Researchers from the University of Washington estimate that the Leavenworth National Fish Hatchery had an average SAR from 1974 to 2003 of 0.16%. The lowest SAR year was 1990 at .0016% and the highest SAR year was 1998 at 0.85%. An analysis of The Research Group economic study data indicates that the Leavenworth Hatchery would need an average SAR greater than .42% to bring their “Cost to Harvest Value Ratio” to a positive value. This would require an operational improvement by at least 162%. [Note: Just to clarify, the above figures represent percentages of 1 percentage point, not of 100.]

The Leavenworth Hatchery has been releasing 1.625 million smolts; a negotiated number between the Federal government and the Tribes. While the number of smolts released has recently been reduced to 1.2 smolts, the USFWS maintains that rearing fewer smolts (reduced rearing densities) will result in healthier released smolts without reducing the number of returning adults. The average adult Chinook salmon return to the hatchery was 5,649 for the period 1980 – 2005.

When the deteriorating infrastructure and antiquated technology at Leavenworth are considered along with the obstructions in the migratory path and the particular species reared, Leavenworth’s average low SAR of 0.16% is not surprising.

The Research Group points out that Mitchell Act hatcheries (here I include Leavenworth because of its historical connection to the Act) were built and operated to mitigate in a much more involved economic and social context. In other words, Mitchell Act hatcheries are not expected to generate positive benefit-cost results. TRG points out that the usefulness of benefit-cost analysis is to show economic efficiencies in different hatchery production or operation alternatives. Such an analysis helps alert managers to find better ways to produce sustainable fisheries.

The Research Group also touched on a relevant point associated with social and environmental justice rooted in federal environmental justice criteria. They point out that changes at a hatchery like Leavenworth may disproportionately affect socio-economic groups like American Indians who are particularly vulnerable to hatchery system alterations.

There is no question that the Leavenworth National Fish Hatchery must change. It will not survive the 21st Century if it doesn’t.

Last year on June 9 the House Appropriations Committee agreed to approve Congressman Norm Dicks’ request to boost funding for the seventeen Mitchell Act funded fish hatcheries on the Columbia River. The Committee approved an increase of $10 million – from $16 million to $ 26 million – for Mitchell Act hatcheries in order to fund improvements to increase production. The Committee also recognized the added responsibilities under the Endangered Species Act (ESA). Congressman Dicks was quoted as saying that “the responsibilities of the ESA require smarter and more efficient operation of these hatcheries.”

As mentioned, the Leavenworth Complex is not listed as a Mitchell Act Hatchery. Leavenworth is in an odd position; it was born out of the Mitchell Act, it is treated as if it was a Mitchell Act hatchery, it has many of the responsibilities assigned to Mitchell Act hatcheries — but it cannot receive financial support from the House Appropriations Committee because it is funded by the Bureau of Reclamation.

The counsel of Congressman Dicks applies directly to the Leavenworth Complex even though he was addressing Mitchell Act hatcheries.

Considering the social-economic conclusions of The Research Group and given the physical location of the Leavenworth Hatchery upstream of seven major dams on the Columbia, as well as its severance from the Mitchell Act, the Hatchery has no choice but to pull itself up by its own bootstraps and become as efficient and as environmentally responsible as new technologies will allow.

If this were any other time in history, improvements to the Leavenworth Hatchery would focus on maintaining the status quo. Improvements would not include the risk of new technologies. Instead, the focus would be on installing new fish ladders and dams. It might even include increasing the amount of water diverted to the Hatchery by building new reservoirs.

But this is a different time in history. It is a time when less water is the trend and the term “fish ladder” no longer fits with the term “stream ecology”. It is a time in history when advanced aquaculture technologies, including especially recirculation of water, can be applied to hatcheries to reduce their Sasquatchianly large environmental footprint. It’s a time when new technologies born out of the private sector to farm fish may actually lead hatcheries to a compatible relationship with natural systems and improved efficiencies.

It is in the best interests of everyone to accept the challenge put forth by Rep. Dicks. If the House Appropriations Committee agrees with the congressman about smarter and more efficient operation of Mitchell Act Hatcheries, then funding should be forthcoming to convert the Leavenworth National Fish Hatchery to a more efficient facility whether it is a Mitchell Act Hatchery or not.

The nation may be able to absorb the negative benefit-cost results associated with a hatchery like Leavenworth. However, we who live here no longer need to absorb the Hatchery’s negative economic externalities of exhausted streams and degraded water, when available technologies can absorb them for us.

Certification enables the federal Environmental Protection Agency to proceed with permitting the Hatchery to operate legally — something it has not done since 1979, when its permit officially expired. But certification comes with a long list of restrictions, considerations, qualifications and provisions, many with timelines attached well into the future.

Most stakeholders contacted by The Watchery deferred comment till they and their legal representatives have had a chance to review the official 10-page order. Parties have 30 days to file an official appeal.

The Big Spring Fish Culture Station, a trout fish hatchery located in Cumberland County Pennsylvania, was built in 1972. It was built on the headwaters of Big Spring Creek. It produced over 700,000 adult and about 60,000 fingerling trout for stocking in waters open to free public fishing. The Hatchery was owned by the Commonwealth of Pennsylvania and operated by the Pennsylvania Fish and Boat Commission.

The annual economic impact for the Commonwealth of the trout stocked from Big Spring Hatchery exceeded $20 million.

The Hatchery had an annual operating budget of about $725,000 and employed a staff of 10 permanent and 2 seasonal employees. It also operated under a National Pollution Discharge Elimination System permit (NPDES) issued by the Department of Environmental Protection.

The Commission acknowledged that discharges from the hatchery needed to be improved since they had chronic negative impacts on Big Spring Creek. It acknowledged that discharges from the Hatchery contributed to impacts on bottom dwelling insects in Big Spring Creek.

The Commission changed the feed formulation at the Hatchery. It also reduced the amount of feed by nearly 35 percent. The Commission added oxygen and improved seals on the raceway cleanouts. In 1998 the Commission contracted for an engineering review of the Hatchery’s waste treatment system.

In 2001 the Commission temporarily closed the Big Spring Hatchery. However, the Department of Environmental Protection did not approve an interim operations plan and this led to closure of the facility pending the installation of a recirculation hatchery in the future.

The Department of Environmental Protection suggested that any hatchery at this site be a no-discharge recirculation facility. The amount ($8.25 million) included in the capital project bill was based on the Big Spring Recirculation Study conducted by FishPro.

The information paper on the Big Spring Hatchery does not specifically mention phosphorous. However, it was probably the presence of excessive phosphorous in the Hatchery’s discharge that led to its closing.

******

A totally different hatchery is the Warm Water Hatchery operated by the Utah Division of Wildlife Resources. The Hatchery was built to meet the warm water needs of Colorado River Storage Project impacts in Utah. These needs include the June Sucker (listed as endangered under the Endangered Species Act), Least Chub, Leatherside Chub, Roundtail Chub, Bluehead Sucker and Flannelmouth Sucker, Channel Catfish and two amphibians: Spotted frog and Boreal Toad. The Least chub and Spotted Frog are considered conservation species for which conservation agreements and strategies have been developed, in accordance with the Endangered Species Act.

In 2006 another building was added to the Warm Water Hatchery where June Sucker production and stocking is ongoing. This addition included a water recirculation system, which provides a rearing temperature of 74 degrees, the temperature at which June Suckers have shown the highest growth rates. Use of the recirculation system has resulted in increased June Sucker growth rates and fish condition.

Recovery Act funds (stimulus funds) will be used to install a recirculation system to better manage temperature and water quality of flows used to raise June suckers in the hatchery.

******

A third hatchery, the Springville State Fish Hatchery, also located in Utah is the state’s oldest hatchery, built in the early 1900s. The Hatchery relies on springs that flow into the “Mill Pond” that have historically supplied an average of 7,630 gallons of water a minute (11 million gallons a day). However, because of drought the yearly average has dropped to 4,488 gallons a minute (6,470,000 gallons a day) which has lowered hatchery production and stocking.

With the continuing drought, Springville’s production has fallen from a yearly average of 180,000 pounds to an average of 120,000 pounds of fish per year, a 33 percent drop in productivity.

The addition of a recirculation system at the West Springville State Fish Hatchery is now being evaluated to see how well it may meet remaining warm water native aquatic species stocking needs.

These three hatcheries took three paths — any one of which could be taken by the Leavenworth National Fish Hatchery.

• The Leavenworth Hatchery has a water discharge issue related to phosphorous. The Hatchery is coming under the scrutiny of the Clean Water Act and the need to qualify for a NPDES permit is similar to what was required of the Big Spring Fish Hatchery. How the Leavenworth National Fish Hatchery addresses this issue will determine its future. Leavenworth has so far followed the same path as the one taken by the Big Spring Fish Hatchery.

(Leavenworth has reduced the amount of feed fed to their fish. Leavenworth has reduced the number of fish raised. Leavenworth is planning to build a new pollution abatement pond. However, Leavenworth has failed to reduce its total maximum daily phosphorous load. It stubbornly remains at 14 ppb.)

• Fish other than the ESA listed species — Spring Chinook, Steelhead and Bull trout — live in Icicle Creek. Icicle Creek has suckers and chub which are not yet listed under the ESA as they are in Utah. However, if the Leavenworth Hatchery continues to damage Icicle Creek as it has done in the past it becomes more probable that Icicle Creek Suckers and Chub not to mention Dace and Sculpins and other species such as the Pacific Sea-run Lamprey will be added to the list of endangered species. If these fish species are listed under the ESA we will no longer be able to dismiss them as unimportant. Instead, the U.S. Fish & Wildlife Service will have to include action similar to that taken at the Warm Water Hatchery in Utah.

• The West Springville State Fish Hatchery in Utah is an old hatchery — even older than the Leavenworth National Fish hatchery, built in 1938. It was built at the turn of the last century when there was more water in the West. However, less water is not limited to a few local areas — it’s prevalent throughout the West, including Icicle Creek. Imagine if the Leavenworth National Fish Hatchery had to reduce its productivity by 33 percent as happened with the West Springville State Fish Hatchery. A reduction of this magnitude would reverberate all the way to Congress because the Leavenworth Fish Hatchery is closely linked to the Tribal Trust Doctrine and Tribal Treaty Agreements centered on salmon.

This brief account shows how hatcheries faced with challenging restrictions can determine if they remain open or closed — and how they must operate if they do remain open.

The Big Spring Fish Hatchery chose to close its doors instead of installing a recirculation system. The Warm Water Hatchery chose to modernize and was obviously on a proactive path which allowed them to capture Recovery Act Funds. The Springville State Fish Hatchery did not take strong enough measures when they modernized, forcing them to reduce productivity by a third.

The U.S. Fish & Wildlife Service is rapidly approaching a time when far-reaching decisions about the Leavenworth National Fish Hatchery and its impacts on Icicle Creek will have to be made. Those decisions need to include setting Icicle Creek free from Hatchery-related diversion dams —not building more as is currently planned. They need to include increasing water supply to the Icicle during low flow times of the year — not demanding more from the Creek at these times.

U.S. Fish & Wildlife Service leaders know healthy streams are important to everyone in America. Icicle Creek is no exception. They need to act on this principle by exploring every possibility to solve the mounting issues associated with the Leavenworth Hatchery and Icicle Creek.

After 13 years studying the issues associated with the Leavenworth National Fish Hatchery and Icicle Creek, I see for the first time a beam of light shining on a solution. Aquaculture and the technology applied to the fish farming industry can easily be applied to the Leavenworth National Fish Hatchery. It has been successfully applied to fish hatcheries throughout the United States and the world over the past ten years. The technology used in aquaculture can set our river free. It can supply the water needs for a healthy stream without sacrificing the productivity of the Hatchery. These technologies open several doors to a list of possibilities hidden from view until now.

All involved agency leaders must open their minds to the environmental possibilities contained within proven fish farming technologies. I am asking the agencies to imagine the opportunities inherent in these relatively new technologies when applied to the Leavenworth National Fish Hatchery.

The Leavenworth National Fish Hatchery is at the epicenter of opposing forces poised to collide.  The U.S. Fish & Wildlife Service has two options; the reactive approach or the proactive alternative.

Three challenges face the Hatchery:

¬    Increasing Water Demands with Decreasing Supply Forecasts
¬    Elevated Phosphorous Loads in Hatchery Discharge Water
¬    A Deteriorating Water Supply Pipeline

Increasing Water Demands with Decreasing Supply Forecasts

Total water measured annually at the Peshastin USGS Gage Station has declined about 16% since 1966.  Total water for key months of July, August, September and October has declined approximately 34 % since 1937 at the Peshastin Gage station.  Center Time, the time when half of the annual flow has passed the Peshastin Gage Station, has moved from late May to mid April.  The same Center Time movement is evident for Icicle Creek but it is less certain because of a 22-year gap in data from 1971 to 1993.

As has already been pointed out on the Watchery, the Hatchery is competing with other jurisdictions for water while at the same time being faced with an apparent trend toward less water.  For example the following table shows the average minimum flows established by the Washington State Legislature during two different times in history for the summer and early fall months:

            1983        2001
July    400 cfs        550 cfs
Aug    180 cfs        370 cfs
Sept    130 cfs        275 cfs
Oct    130 cfs        267 cfs

What is interesting about 1983 and 2001 instream flow minimums is that they have actually been raised since 1983 to 2001, reflecting the quantity of water the public and scientists think should be flowing for a healthy Icicle Creek.  The recent Section 401 Certification order No. 7192, required by the Clean Water Act so the Hatchery can discharge into Icicle Creek, allows the Hatchery four (4) years to recommend minimum flows for Icicle Creek.

The process outlined by the state DOE through the 401 Certification process to determine the recommended flows is called an Instream Flow Incremental Methodology (IFIM study).  It turns out to be a combination of science and politics.  However, with 1983 and 2001 historical precedence in place, it’s entirely probable that recommended flows for Icicle Creek could be so high that the Hatchery would have to reduce its productivity to abide by the state’s directive.  If that came about, it might conflict with the fish-production treaty obligations the Federal Government has with tribes.

Added to the state’s instream flow requirement will be a minimum instream flow assigned under the Endangered Species Act, following consultation with NOAA Fisheries.  The minimum flows linked to the ESA are not negotiable and will be enforced.

What happens if the Endangered Species Act and the Clean Water Act conflict with the Tribal Trust Doctrine and the 1855 Treaties signed between the United States and the Tribes?   Is the Federal Government still obliged to try and mitigate for the loss of fish because of Grand Coulee Dam?

In other words, we have several trains steaming toward an epicenter, all scheduled to arrive at the same time.

Elevated Phosphorous Loads in Hatchery Discharge Water

The Department of Ecology’s October 2009 Wenatchee River Watershed Dissolved Oxygen and pH Total Maximum Daily Load draft Water Quality Implementation Plan (p. 33) points out the following:

“The Leavenworth National Fish Hatchery (LNFH) currently discharges approximately 25 to 30 million gallons per day and 1.27 kg/d of phosphorous to Icicle Creek.  The target phosphorous Waste Load Allocation (WLA) for LNFH is 0.48 kg/d, a 62% reduction.  This WLA is equivalent to a 5.2 ug/L total phosphorus concentration and phosphorus removal technology limits will not allow LNFH to meet this WLA.  In fact, LNFH’s current phosphorus discharge concentration of approximately14 ug/L is already below the limits of technology.  As a result, alternative effluent management will be required by LNFH.  Such alternatives might include effluent phosphorus trading or reclaimed water use; however, these activities would likely only relieve LNFH of the phosphorus WLA to a small degree, since LNFH’s discharge flows are so high.”

The language may be dry, but the point is clear. The Hatchery is at an impasse when it comes to meeting phosophorous limits.

The recent Draft Section 401 Certification Order No. 7192 referred to above allows the Hatchery five (5) years to meet a discharge limit of 5.7 ug/L total phosphorous — which DOE admits cannot be attained.

Small towns along the Wenatchee River and a couple of fruit packing houses are also being required to meet phosphorous discharge limits.  If the Hatchery continues to discharge high phosphorous loads into Icicle Creek it will place a heavier burden on small jurisdictions along the Wenatchee River, due to the confluence of Icicle Creek and the Wenatchee River being above the towns.  The Department of Ecology’s ultimate goal is to address low dissolved oxygen levels in the Wenatchee River itself, further increasing the burdens on the small towns if the Hatchery can’t meet its Waste Load Allocation.

The amount of water discharged from sewage treatment plants along the Wenatchee River is dwarfed by the amount of water discharged from the Leavenworth National Fish Hatchery.   The Leavenworth National Fish Hatchery discharges between 25 million and 27 million gallons of waste water from fish raceways into Icicle Creek each day.  During the summer and early fall months most of the water volume in Icicle Creek below the Hatchery is made up of Hatchery discharge water.

There appears to be no economical way to reduce phosphorous.  Reverse Osmosis works but costs around $350,000 to treat just 1,000 gallons.  The Clean Water Act does not allow the Hatchery to solve its phosphorous problem by mixing clean water with discharge water (to dilute their phosphorous load).  Even if this was allowed, the Hatchery doesn’t have access to enough clean water to bring the load down to acceptable limits.

One answer to the phosphorous problem is for the Hatchery to seriously consider radically reducing the volume of discharge — which would mean substantially less water flowing through the Hatchery, resulting in fewer numbers of fish.  Such an action would conflict with the Tribal Trust Doctrine and Treaty obligations and the Federal Government’s Grand Coulee Dam fish mitigation agreement.

The Department of Ecology is serious about enforcing phosphorous Waste Load Allocations.

Here we have three more trains steaming toward the same epicenter referred to previously.

A Deteriorating Water Supply Pipeline

It has been known for at least 10 years that the water supply pipeline to the Leavenworth Hatchery is falling apart.  The day will come when a piece of concrete liner will break loose and instead of being discharged into the Hatchery’s sediment settling chamber will lodge in the pipe, blocking water to the Hatchery’s raceways.

The last two times it attempted to fix the pipeline, the Hatchery tried to combine the repair with the restoration of Icicle Creek — unfortunately resulting in more negative impacts to the stream. The fact of the matter is that water supply to the Hatchery is intermingled with the flow of Icicle Creek so that the water supply pipeline cannot be fixed without negatively impacting the stream — and vice versa.

Diverting water from Icicle Creek using dams and pumps or using dams and gravity impacts stream flow and native fish migration in the Icicle.  This quandary is magnified by more frequent and increasingly lower stream flows.

If the water supply pipeline is allowed to become an emergency, there won’t be time to fully vet solutions. The result will likely be unintended consequences — a situation most managers wish to avoid.

This is one train steaming ahead with the rails missing from an unknown mile of track.

To summarize; The Leavenworth National Fish Hatchery is on a collision course with the Endangered Species Act and the Clean Water Act, as well as Mother Nature.  Coming into compliance with these two flagship pieces of legislation could place the Hatchery in conflict with the Tribal Trust Doctrine and the treaties signed between the Tribes and the United States Government.  Additionally, the Hatchery appears to be on a collision course with Climate Change and an educated public that knows the difference between a healthy river and one that is severely compromised.  And finally, the Hatchery is exposed to an increased risk of a failed water supply line.

Two alternative technologies already being used might help the U.S. Fish and Wildlife Service Leavenworth National Fish Hatchery avoid the collisions pointed out above:

¬    Partial Reuse Aquaculture Systems (PRAS)
¬    Recirculating Aquaculture Systems (RAS).

Partial Reuse Aquaculture Systems (PRAS)

Partial Reuse Aquaculture Systems use water treatment processes to allow a portion of the culture discharge water to be recycled back into the culture tanks.  For aquaculture facilities — including hatcheries — faced with limited water resources (Leavenworth), reuse technology is the next step in the technological evolution of modern aquaculture systems.

Compared to the “flow–through system” that the Leavenworth Hatchery uses, PRAS offer significant reductions in water consumption, effluent discharge volumes and potential energy consumption.

Partial Reuse Systems focus on the use of a few simple treatment technologies to provide significant reductions in water use.  These typically include gas-balancing and oxygenation, may also include solids removal and disinfection, but do not normally include ammonia removal through biofiltration.  (The main reason reuse culture systems are not as efficient at reusing water as recirculating systems is because harmful accumulations of ammonia need to be removed — which requires using additional water to flush ammonia out of the system.) Water quality where treatment is not provided is maintained within acceptable limits by flushing along with replacement of a portion of the system water. Water temperature is dependant on influent water, which may be more economically altered than in a flow-through system, due to the lower flow rate.

With reduced water use, influent treatment and effluent treatment become more economical.

Partial Reuse Systems use 50% to 75% less water than flow-through systems.  For example, the Chelan County PUD Eastbank Hatchery uses 324 gpm in its water reuse system to raise 120,000-250,000 Chinook salmon.  In contrast, traditional raceways use 1,206 gpm of water flow to raise that many fish.

Lower flow requirements would have a huge impact on the configuration of water to the Hatchery.  The reduction in water use would enable capturing waste more effectively in an effluent total four times smaller than from flow-through systems like the one the Hatchery is using.

Recirculating Aquaculture Systems (RAS)

Recirculating aquaculture systems incorporate additional treatment technologies beyond those used in PRAS, permitting reuse of significantly greater quantities of water.  Recirculation systems afford a level of control well beyond any other technology application in aquaculture and provide significant production and economic benefits.

Recirculation systems are typically used where new water supplies are limited or expensive (e.g. high pumping costs).  Also, recirculation is typically used where the risk of introducing pathogens is high, where effluent disposal capacity is limited or where operators require strict control over water temperature within the fish culture system.

Recirculation Systems have high initial capital costs.  However, in a well-designed RAS, benefits will outweigh additional costs, resulting in a lower net cost of production.

Full recirculation culture systems remove ammonia using bio-filtration.  (Remember, ammonia is the reason reuse systems conserve water at rates no higher than 75%.)  Bio-filtration provides a suitable environment for colonizing autotrophic bacteria to metabolize ammonia as the system water passes through the filter vessel.  Bio-filters enable hatcheries to operate in a near closed loop, where the only water losses are through evaporation, and solid waste removal.  Makeup water then is reduced to a relatively small fraction of the total system volume.  Just enough makeup flow (< 2%) is required to maintain acceptably low concentrations of trace minerals and salts which could otherwise accumulate to harmful levels.

It might even be possible for the Leavenworth Hatchery to produce the same number of fish it produces today using only Nature-provided, sustainable well water — no need for surface water from Icicle Creek.  Imagine the environmental good such a system would bring to the Leavenworth Hatchery. Most of all, imagine the reduction in conflict over fish and water resources!

Europe has been the leader in recirculation system development because of mature water markets and because Europe has some of the most rigorous pollution abatement standards applied to aquaculture effluent discharges anywhere in the world.

The July/August 2006 edition of Hatchery International points out that:

“In North America, commercial salmon hatcheries began adopting recirculation systems technologies over a decade ago.  Publicly funded hatchery systems, frequently with an aging infrastructure dominated by raceways, are seizing development opportunities to take advantage of water reuse technologies in the greater public interest of water conservation and to improve the effectiveness of hatchery operations.  There is a growing trend to consider water reuse as a central element of integrated and sustainable water resources worldwide, aquaculture industry leaders recognize their responsibility and are responding with appropriate, productive, and sustainable solutions.”

Australia’s Tassal Group Ltd., is building a  new Hatchery on the Huon River which will raise 4 million smolts a year.  Tassal, a privately owned company, conducted a world -wide tendering process and selected a state-of-the-art RAS technology provided by Aquatec Solutions (AQS) of Denmark for the new Huon River Hatchery.  The key reason AQS was selected was because their system provided for the least water usage along with the highest quality discharge.

The AQS RAS system includes technology for temperature control, pH balancing, and oxygen addition, water filtration via micro screens, carbon dioxide removal, ammonia removal, disinfection, de-nitrification and phosphorous removal elements.

Project capital cost is budgeted at $18.5 million. Remember, this project is designed to produce 4 million smolts. It is reasonable to assume that since the Leavenworth Hatchery produces between 1.2 million and 1.625 million smolts, the installation of an AQS RAS system would be less than $18.5m.  In fact, the Bureau of Reclamation is considering spending $10 million on a dam and pumping water supply line system on the Icicle, with no associated improvements to the fish rearing capabilities of the Hatchery.

It is hard for me to believe that over the past few years we have been designing dams and fish ladders to squeeze the last drop of water from Icicle Creek and Snow Lake when RAS and PRAS technology exists.  It is more difficult for me to understand why recirculating or reuse systems were not recommended by the Bureau of Reclamation and the Fish and Wildlife Service to solve river restoration and Hatchery productivity problems in an era when this type of technology has been and is being implemented in Canada, Australia, Denmark, Europe and more progressive parts of the United States.

It’s like being told to build a log home with an axe and a crosscut saw when chainsaws and electricity are only 50 miles away.  It’s like being required to hang a deer skin over a window opening when glass is readily available.

At Leavenworth our governmental leaders need to propose a solution that capitalizes on the new technologies described above.  If our leaders won’t do it, local citizens certainly know how to carry this ball.  We who live here should never settle for a degraded river, a compromised river or threatened aquatic life when technological solutions are only a click of the mouse away.

Over the past 70 years the Leavenworth National Fish Hatchery has struggled with the fact there was not enough water produced in the Icicle Creek Watershed to operate the hatchery at production levels desired in 1938. By 1939 — when the hatchery was built — almost all water during the summer months was allocated for irrigation. In fact even the irrigators had to build dams at several high mountain lakes for the purpose of augmenting low Icicle Creek flows during late summer and early fall.

When low flow conditions exist in Icicle Creek in mid-summer through early fall, the hatchery is entirely reliant on water from its Snow Lake reservoir, developed by the Bureau of Reclamation when the hatchery was built. Snow Lake is a high mountain lake in the Alpine Lakes Wilderness with the capacity to provide a maximum of approximately 12,000 acre feet of water. The Hatchery is reluctant to draw down the reservoir too far for fear it will not refill during the winter months.

Over the years the Hatchery has drilled several water wells fitted with pumps capable of exceeding the natural recharge rate to the well field. During low flow years the combination of pumping and low recharge rates results in an exhausted aquifer by the end of summer. The Hatchery needs to recharge the aquifer in early fall in preparation for using large amounts of well water in December. The Hatchery accomplishes this by closing the gates of a dam across the main stem of Icicle Creek, thus diverting the entire Icicle into a 4,000-foot-long man-made canal. Water leaks from the canal at high enough rates to recharge the aquifer.

For over 60 years this management scheme supplied water to the hatchery. The price paid was to block native fish migration and reduce Icicle Creek to a trickle below the last dam. In essence, these actions squeezed the last drop of water from Icicle Creek during late summer and early fall.

Only recently has the quality of water discharged from the hatchery come under scrutiny. We know that during the summer months and early fall lower Icicle Creek suffers from depressed dissolved oxygen concentrations and high pH levels that stress fish and other aquatic life. The low dissolved oxygen and high pH is caused by an exploding growth of periphyton algae caused by abnormally high levels of phosphorous. The major contributor of phosphorous has been traced to the Leavenworth National Fish Hatchery. The hatchery’s phosphorus also contributes to similar problems downstream in the Wenatchee River.

Over the past 60 years no one paid much attention to how the hatchery affected Icicle Creek. If the hatchery dried up a mile of river few people even knew about it. No one knew about the water quality problems, let alone the connection to phosphorous in hatchery discharge water. No one thought about the hatchery’s yearly struggle for adequate water and what operators had to do to meet it. There was no Endangered Species Act or Clean Water Act until the 1970s.

Today everything has changed. The Hatchery has been required under the Clean Water Act to obtain a permit to discharge their water into Icicle Creek. The permit requires the Hatchery to reduce the phosphorous load it discharges into the Icicle. (How the Hatchery proposes to meet this limit when no technology is available to reduce the Hatchery’s load remains an unsolved problem at the moment.)

Because the discharge permit is guided by the Clean Water Act, the permit also requires the Hatchery to provide minimum water flows in Icicle Creek.

When Hatchery operators close the gates of the dam to divert water into their canal, they do so without a permit. Currently, the Hatchery is being challenged on this action. The logic is that the Hatchery cannot be treated any differently than an irrigation district or company that diverts water from a natural flowing stream into a man-made canal — and therefore must be permitted with accompanying conditions.

When Icicle Creek steelhead, spring Chinook salmon and bull trout were listed as endangered and threatened under the Endangered Species Act in the late 1990s, no one challenged the Leavenworth Hatchery’s policy of leaving the dams closed. Today, blocking native fish migrations is being challenged. In addition to the Clean Water Act requirement to supply minimum instream flows, NOAA Fisheries are also requiring minimum flows under the Endangered Species Act.

These actions have spurred confrontational debates leading to litigation because the parties cannot resolve their differences.

At Leavenworth, most of these differences originate in the fact that the 1938 technology used by the Hatchery consumes most of the water. No surplus is left to satisfy new 21st Century demands. Added to all of this is a realization that low flows in our streams are increasing in frequency and that low flows are trending to be even lower. Furthermore, if the Stuart Range glaciers continue to recede at the rate they have receded over the past 20 years, they could be completely melted within three decades, which will accelerate the low water trends. Finally, there is a new public awareness demanding healthy streams and conservation of water.

Confronted with these realities, the option of closing the Hatchery has actually been discussed.

However, the Leavenworth National Fish Hatchery is special. Leavenworth is a Mitchell Act hatchery initially built to help mitigate for the loss of fish from Grand Coulee Dam. Over the years the courts have ruled that Leavenworth must produce a negotiated number of fish each year for a Tribal fishery. This decision is linked to the Tribal Treaties of 1855 and the Tribal Trust Doctrine and has the full support of the United States Congress.

When powerful Tribal interests are considered, shutting the Hatchery is not an option. (Unless the fish could be produced elsewhere — and it appears there is no “excess” hatchery capacity anywhere else in the Columbia Basin.) And yet, when the demands of the Clean Water Act and the Endangered Species Act are included along with diminished summer flows, there appears to be no resolution. Policy makers and agencies unable to make a decision acceptable to all stakeholders take the no-action alternative, which everyone knows will end in a disastrous emergency with unintended outcomes.

Over the past 12 years proposed solutions to the issues at the Leavenworth Hatchery have relied on the same engineering models and the same technology that was developed in 1938. The major reason solutions have eluded us is because the tools developed in 1938 are inadequate to solve problems of the 21st Century.

We need to break out of our box. Instead of building new dams and new fish ladders as was done in 1938, we need to look at the problem from a different perspective. Instead of thinking about hatcheries as something natural we need to squarely face the fact that a hatchery is a factory. Hatcheries are a business model that produces fish ultimately for consumption. Hatcheries have nothing to do with the natural environment, even if they are managed by the U.S. Fish and Wildlife Service. In one sense, hatcheries actually farm fish.

Hatcheries equal aquaculture.

Once that that small three-word phrase is recognized, the most fundamental improvement that can be made is to design, or retrofit, a hatchery with the most efficient use of water available. This is especially true regarding the Leavenworth National Fish Hatchery. Aquaculture technology has been operating for many years. Salmon hatcheries like Leavenworth that are managed by the USFWS are reluctant to change course because our culture is not sure where hatcheries fit. Are they part of the ecosystem or do they belong in industry along with modern agriculture? Any business, including hatcheries, resists change because change always harbors risk. However, as pointed out above, a hatchery like Leavenworth may have no other choice but to change.

If for example, Leavenworth retrofitted its current flow-through system with a recirculation/oxygen supplementation technology, it could reduce water consumption to a fraction of what it consumes today. In fact, it could raise the same number of fish it raises today on well water alone, without the need to artificially recharge the well field by diverting Icicle water into its Canal.

Recirculation culture systems remove ammonia with the addition of bio-filtration, which would enable the Hatchery to operate in a near-closed loop where the only water losses are through evaporation and solid waste removal. Recirculation’s reduction in water use would result in the ability to capture waste more effectively, which may answer the Hatchery’s phosphorous reduction requirements.

The Leavenworth National Fish Hatchery is at a tipping point.

The list below is an incomplete list of hatcheries that have adopted partial reuse, reuse, or recirculating water systems. Not all of these hatcheries are salmon hatcheries. Some produce fewer fish, some produce more fish. Some are supplementation hatcheries while others raise fish to a certain life stage. Some are experimental. But all of them conserve water and all of their fish are apparently healthy. Here is the list so far:

• Gold River, British Columbia
• 10 hatcheries in Chile
• Chelan County PUD Eastbank Hatchery
• Chelan County PUD Chiwawa Hatchery
• White River National Fish Hatchery on the Connecticut River
• Umatilla Fish Hatchery
• Wild Rose State Fish Hatchery, Wisconsin
• Fairbanks Experimental Fish Hatchery, Alaska
• Wigwam Hatchery, Wyoming
• Dan Speas Hatchery, Wyoming
• Dubois Hatchery, Wyoming
• Fisheries Experiment Station Logan, Utah
• Ruth Burnett Sport Fish Hatchery Fairbanks, Alaska

My last entry on the Watchery promoted converting the Leavenworth Hatchery to an acclimation hatchery. This proposal was met with great skepticism because there is no place left to raise fish in the Columbia Basin. All facilities are being used to the maximum. At least this is what I was told by managers I trust who work for NOAA Fisheries, the Yakima Nation and the USFWS.

Therefore, I am now promoting a technology to conserve water at Leavenworth. This solution will help restore the river by obviating any need to block fish passage, it will help restore instream flows, will allow the Hatchery to reduce its phosphorous pollution, benefiting the entire Wenatchee River basin while maintaining the long-term productivity of the Hatchery. It is 21st Century technology.

Here is an elegant and conceivably feasible solution to the Leavenworth dilemma that needs to be fully explored by people with open minds.

Dick Rieman
December 23, 2009
Leavenworth WA

In a scathing 19-page indictment, the WFC says the draft certification “fails to describe the water quality standards” for the Icicle, “fails to describe the project in sufficient detail to make clear” how the Leavenworth Fish Hatchery’s proposed project could “interfere with” water-quality standards, and fails to provide “measurable standards” for present and future hatchery operations as well as not explaining how standards that are set forth will enable the hatchery to operate within water-quality standards.

“In short, the certification does not describe what needs to be protected, namely the uses, nor does it analyze how the LNFH’s activities might impair those uses,” the WFC states. “This is arbitrary and capricious.”

Morever, the draft certification, by calling for a series of studies over 1 to 5 years, implies that not enough study has yet been done on the Icicle to adequately establish standards. Yet it offers no evidence to support the conclusion.

“Overall, (the Department of) Ecology has not met its responsibilities under the Clean Water Act and Washington State law,” the document states.

The WFC submitted its comments in response to a call for public response to the draft certification notice. DOE received about two dozen comments and plans to analyze them over the next two weeks on a fast track to submit final certification of Hatchery operations by mid-January.

Key elements of the Hatchery plan, including two dams on the Icicle, stand to kill endangered species of migratory fish on the Icicle, the WFC goes on to say. Finally, an aquatic workgroup stipulated by the draft certification needs to be far better defined in terms of skill sets, resources and personnel.

The WFC’s full comments are posted here.

If you or your group has submitted comments in response to the 401 draft certification, the Watchery is interested in reprinting them. Please contact us in the comments section. Thank you!

The founder of a key Leavenworth business, the Sleeping Lady Mountain Resort, has asked the state Department of Ecology for more specific direction in setting river flow and water quality standards for the hatchery.

“This is the chance to set real requirements to federal authorities now,” stated Harriet Bullitt, whose property adjoins the hatchery on Icicle Creek. “That would allow them to avoid the consequence later of having to negotiate for flexibility, expect variances or just ignore State law, leaving to citizens the expensive drudgery of resorting to the courts.”

The current 401 certification notice as drafted appears “to apply to present operations,” Bullitt said, and yet any new construction as planned under stimulus funding will change conditions dramatically in the river.

“All of us who live here want a win-win action, where the hatchery gets its water supply and so does the river,” Bullitt concluded.

The full text of her response, dated Dec. 19th, is here.

Response to the hatchery plan, which included a new pipeline, pump station, dams and “large roughened channel” on Icicle Creek, ranged from unhappiness to outrage. Hatchery officials have privately indicated that the project’s delayed unveiling with no public input was a public-relations fiasco. Especially damaging was failure to notify and invite participation from city of Leavenworth and Chelan County officials.

As a result, hatchery officials may be opening up the process.

Two stakeholder meetings with representatives of the Yakima nation, Icicle Creek Watershed Council and Cascade Irrigation District as well as hatchery officials have resulted in a potential rethinking of the project by Fish & Wildlife and Bureau of Reclamation officials, sources told the Watchery. While there’s nothing official yet, another meeting expected after the New Year may well yield something in the way of informal agreement on alternative paths.

The most dramatic proposal on the table would obviate the need for a new headgate dam on the Icicle by recirculating and purifying (with an ozone-based ionizing system) hatchery water. Purification would not only keep the water disease-free for fish rearing but would require far less draw-down from the Icicle. Recirculation or re-use (similar but not the same) systems are already under way at numerous hatcheries, notably the Chiwawa plant and Eastbank Hatchery just below Rocky Reach Dam north of Wenatchee. The White River Hatchery on the Connecticut River in Vermont also has installed re-use and recirculation. High-profile projects also are under way in Alaska.

The pumping station would be placed close to the hatchery spillway, a less invasive location that offers the added benefit of no new pipeline construction. And cost would be far less than the $14 million estimated for the Hatchery’s dam-and-pump station proposal.

Participants batted around the recirc/re-use approach at a four-hour meeting last Wednesday at the Sleeping Lady retreat center south of Leavenworth and adjacent to the Icicle. According to sources at the session, a turning point came when Ron Eggers, project manager for the BOR, signaled that the Hatchery may be open to new considerations.

“Ron had been saying, ‘We don’t have time to do this or that and still qualify for stimulus funding,” a source at the meeting told the Watchery. “But at one point he changed direction, indicating that it was more important to ‘do the right thing’ than rush into something just to qualify for funding.”

(The Watchery has not yet been able to obtain comment from Eggers.)

Stimulus projects must “break ground” by September 2010 to qualify for funding. While agencies consider the deadline do-or-die, history suggests that funding for viable projects will simply be extended — although there’s certainly no guarantee on that front given current economic conditions.

The hatchery’s draw from the Icicle is a key point in its future plans because of anticipated conflict over water rights and the impacts of global warming. The damming proposal would require a minimum flow of 42 cubic feet per second, a volume that during low-flow months already threatens to run the river completely dry, destroying plant and fish life.

Dick Rieman, a river activist who has been studying and documenting Iclcle flow levels, says decades-long trends are not encouraging.

“We’re beginning to see a water shortage for the hatchery in the not too distant future,” Rieman said. A recirculation system could get the flow requirement down to 15 cubic feet a second, Rieman noted.

Wild Fish Conservancy, an environmental group that has been involved in Icicle River protection for years, says scientific data indicate snow-pack levels by the end of the century will fall far short of supporting hatchery operations.

“The Bureau of Reclamation is well aware of climate-change impacts going on in the Northwest,” said Mark Hersh, a WFC water-quality specialist. “It is not a pretty picture at all.”

With recirculation, a smaller intake volume for the hatchery implies a healthier Icicle River as well as more available water for legacy irrigation, recreation and related local needs. And treatment of the water supply would solve the Hatchery’s ongoing phosphorous-level woes, a key issue in Clean Water Act certification by the state Department of Ecology.

While details ensuring future water supplies for all constituents still need to be worked out, a win-win solution that continues hatchery operation while satisfying other demands on the Icicle (including protection of endangered salmon, steelhead and bull trout species) now appears to be a unifying goal among engaged parties.

The department intends to analyze the comments with a fairly quick turnaround. Barwin said the aim is for final 401 certification by mid-January.

State certification for the Leavenworth Fish Hatchery is required by the federal Clean Water Act. The issue was raised by Icicle Creek river activists after discovering that the Hatchery had been operating without a Clean Water permit since 1979.

Issues raised by the certification process include adequate water flow to protect endangered fish species, as well as pollution and temperature factors. Of particular concern are hatchery-produced levels of phosphorous — related to fish feed and effluent — which lead to algae growth and oxygen deprivation for wild fish and native plant life in the Icicle.

Certification is a separate process legally from the Hatchery’s plans to spend $14 million in federal stimulus funds to put a new dam, pump station and water-intake facilities on the Icicle. But the two are from a practical standpoint inevitably intertwined because any new construction has impacts on the river’s water quality.

The Watchery will attempt to collect signature responses to the draft 401 certification and post them on this blog. Once final certification is issued, the order can be appealed within 30 days and subsequently enter a mediation process.