Icicle Strategy SEPA Comments

SEPA Responsiveness Summary – Final

Icicle Strategy SEPA PEIS Scoping

Commenter

Comment Summary

Response

Guy Moura, Project Manager

Tribal Historic Preservation Officer

Confederated Tribes of the Colville Reservation

  1. Concern regarding protection of Tribal Treaty Fishing Rights
  2. Archaeological, ethnographic, and historical sites of significance within program area

Link to full comment

Compliance with state and federal laws, including Tribal fishing rights, is one of the Guiding Principles.

Continue consultation with the Confederated Tribes of the Colville Reservation.

The PEIS will include a cultural resource survey of areas potentially impacted by projects proposed to meeting the Guiding Principles.

Consultation with Washington Department of Archaeology and Historic Preservation.

William B. Beyers, President

Alpine Lakes Foundation

  1. Extent of water rights when the Alpine Lakes Wilderness Area was created in 1976
  2. Full or partial relinquishment of water rights before or after the creation of the Alpine Lakes Wilderness Area
  3. Relationship between storage and diversion rights, and if storage rights are subject to relinquishment if diversion right is exercised
  4. Legal ability to build or expand structures on Alpine Lakes
  5. Legal ability to construct or expand structures or tunnels upstream from the lakes
  6. Legal ability to construct a tunnel
  7. Rights granted by USFS to IPID and authority to grant those rights during a land transaction in 1990
  8. Legal ability to change the purpose of use of a water right
  9. To what extent can the IWG process supersede state and federal laws
  10. Can the Department of Ecology make objective decisions regarding status of IPIDs water rights

Link to full comment

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will evaluate reasonable alternatives.

Existing easements, in-holder agreements, and State water rights will be reviewed.

Edward Whitesell

816 Plymouth St., SW

Olympia, WA 98502

 

  1. Concern regarding infringement upon the wilderness character of the Alpine Lakes Wilderness.
  2. Concern that water management strategy activities/actions would be at odds with 1964 Wilderness Act.

Link to full comment

The PEIS will assess the potential impacts to wilderness and recreation that might result from the projects proposed to meet the Guiding Principles.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

Derek Poon

400 Boylston Ave E, #2

Seattle, WA 98102

206-729-9378 cell, derekcpoon@gmail.com

206-602-6565 land line

  1. How and when will federal provisions and ESA regulations be incorporated into the Icicle Strategy?
  2. Are the ESA recovery plan voluntary roadmaps to recovery (delisting) already incorporated into the Icicle Strategy?
  3. Have designated use (DU) protections been accommodated within the Icicle Strategy? will my DU matrix be used and published (Alpine Lake 2-17-15, attached)?
  4. If the Icicle Strategy cannot adequately protect certain DUs, are economic exemptions planned or have already been explored under the CWA Use Attainability Analysis (UAA, also see CWA Watershed Academy, p. 11), ESA God Squad Decision, or Congressional exemptions?  

Attachments:

  1. ESA Section 4F Recovery Plan criteria, GAO summary.pdf
  2. Alpine Lake 2-17-15 IWG mtg, with CWA DU MATRIX.pdf
  3. DP 3-4-15 letter, BNR, 3-10-15 meeting.pdf.

Link to full comment

Compliance with state and federal law is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal law, including the Endangered Species Act and Clean Water Act.

Natalie Williams

nataliesees@gmail.com

Removal of any resource from a federally-designated wilderness area is a violation of the Wilderness Act and the Alpine Lakes Wilderness Area Management Plan.

The EIS should include Alternatives that:

  1. protects and preserves the Alpine Lakes water resource in compliance with the above Act and Management Plan
  2. acknowledges the limits of the City of Leavenworth, IPID, and other users of the original purpose and legal agreement of the above Act and Management Plan
  3. establishes a water rights/volume swap water market in addition to implementing aggressive conservation measures, including raising prices, issuing limits, scheduled watering, etc.

Link to full comment

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will evaluate reasonable alternatives.

The PEIS will include narrative of the current state of water rights in the basin. For each project designed to meet the Guiding Principles, the PEIS will prescribe what existing and new permits would be necessary for the project.

Norm Stoddard

12556 Shore Street, Leavenworth, WA 98826

What will be the impact of water conservation measures on domestic water wells?

Will loss of groundwater dry up wells?

Link to full comment

The PEIS will consider impacts to groundwater for projects proposed to meet the Guiding Principles.

Steve McKenna

12490 Shore Street, Leavenworth, WA 98826

Commends the IWG for successful collaboration.

Enjoyed the presentation.

Was very pleased with the outreach and involvement of the community in the process.

Link to full comment

General support for the project noted.  Additional outreach opportunities are forthcoming at the Draft PEIS stage, Final PEIS, and related to any additional project level EIS’s.

Scot Brower

TU Leavenworth Chapter

Concerns regarding manipulation or alteration of the existing Boulder Field:

  1. Is upper Icicle Creek suitable habitat for Steelhead?
  2. Will Steelhead passage into upper Icicle Creek result in closure of existing rainbow trout fishery (due to ESA status of Steelhead)?

Link to full comment

The PEIS will consider potential aquatic habitat, habitat suitability, and recreational impacts of the projects proposed to meet the Guiding Principles.  Opportunities for fish passage improvements throughout Icicle Creek will be evaluated.

Compliance with state and federal law is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal law, including the Endangered Species Act.

Nete Olsen

836 NW 61st St

Seattle, WA 98107

  1. A Water Balance Chart should be prepared for the Icicle Creek system:
    1. baseline flows expected for Icicle Creek and the lakes during “normal” and “drought” years, and anticipated future flows related to global warming.
    2. water outputs from Icicle Creek under current operations during “normal” and “drought” years showing the locations of the diversions, maximum rates and volumes of diversion, whether the diversions are firm or interruptible, and the holders of the diversionary rights.
    3. locations of problem areas in the drainage system that the IWG is trying to address to improve instream flows.
  2. The Guiding Principles outlined by the IWG need to be ranked in order to establish the relative importance of each principle. Consider assigning “Required” and “Additional” as categories for the Guiding Principles.
  3. “Conservation First” should be added as the 10th Guiding Principle.
  4. Relocating the diversion locations along Icicle Creek must be considered as an alternative to meet the Guiding Principle of Improving Instream Flow.
  5. Transferability of water rights must be demonstrated in the Eightmile Lake Restoration Project.
  6. Limits of Inundation of Eightmile Lake perimeter should be mapped.
  7. Alpine Lakes Optimization, Modernization, and Automation operation strategy needs to be defined:
    1. How much water will be taken from each lake during a “normal” water year?
    2. Will the ease of water withdrawal increase the “baseline” withdrawal rate that currently gets drawn? For example, will irrigated acreage increase so that the needs for irrigation rise, and every year becomes a “drought” year? Providing a more regular supply may only make for more severe shortages as the impacts of global warming become clearer.
    3. How will the benefits to Instream Flows (as an interruptible flow) be balanced with the needs of irrigation (as a firm demand)?
  8. Stage/Storage data and bathymetry needs to be developed for each of the Alpine Lakes within the “optimization” program.

Link to full comment

All of the Guiding Principles have equal priority and must be met as a package to effectuate the proposal endorsed by the Icicle Workgroup. 

Existing documents provide background on baseline flows, diversions, and current conditions in the Icicle Creek Subbasin, (see county website). The PEIS will provide additional detail on streamflow, diversions, out-of-stream use, and a need statement relevant to the Guiding Principles and the projects proposed to meet the Guiding Principles.

The PEIS will evaluate reasonable alternatives.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will describe potential projects and impacts under the proposed program. Additional detail will be provided in any subsequent project level EIS.

The PEIS will include narrative of the current state of water rights in the basin. For each project designed to meet the Guiding Principles, the PEIS will prescribe what existing and new permits would be necessary for the project.

 

The PEIS will discuss proposed actions under the Guiding Principles and related projects that are required by state/federal law.

The PEIS will discuss water conservation to meet the Guiding Principles.

The PEIS will provide detail regarding Alpine Lakes Optimization, Modernization, and Automation including release rates, hydrologic inputs, changes to inundated area, and instream flow benefits.

Roy McMurtrey

We need wilderness kept pristine, get the water some other way.

Link to full comment

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will assess the potential impacts to wilderness and recreation that might result from the projects proposed to meet the Guiding Principles.

Ken Hemberry

General Manager

Peshastin Hi-Up Growers

 

Orchardists/Growers depend on a reliable source of water for irrigation. It was great to learn that the [Icicle] Work Group was focused on meeting the needs of all stakeholders through a consensus process. We both appreciate and support the Work Group’s plans and Guiding Principles.

Link to full comment

General support for project noted. 

Agricultural reliability is one of the Guiding Principles.

Jori Adkins

301 Puyallup Ave.

Tacoma, WA 98421

253-365-1459

Concern about the Icicle group’s proposal to use the Alpine Lakes as reservoirs. Wilderness areas are a place of rejuvenation and healthy hiking and wildlife watching.

Link to full comment

Using the Alpine Lakes as reservoirs is the existing condition. One of the Alternatives being considered is to improve the operation of the Alpine Lakes reservoirs to meet the Guiding Principles.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will assess the potential impacts to wilderness and recreation that might result from the projects proposed to meet the Guiding Principles.

Vic Clayson

Cashmere, WA

 

Appreciative of opportunity for public comment.

Very much in favor of increased water storage in the subbasin.

Concerned about where funding will come from.

Link to full comment

General support for project noted.  Additional outreach opportunities are forthcoming at the Draft PEIS stage, Final PEIS, and related to any additional project level EIS’s.

Storage projects will be evaluated as part of reasonable alternatives to meet the Guiding Principles.

Funding for the proposal is expected to be comprised of local, state, and federal funding sources.

Merrie Davis

 

In favor of additional water storage in the Alpine Lakes area.  I hope the proposal is a success.

Link to full comment

General support for project noted.

Storage projects will be evaluated as part of reasonable alternatives to meet the Guiding Principles.

Cristina Hill

Leavenworth, WA

 

As part of the Conservation initiative of the proposed project, the City of Leavenworth should initiate a water metering program and tiered pricing for residential customers. 

In favor of improving passage at Boulder Field.

In favor of upgrading fish screens and new rearing tanks at LNFH.

In favor of piping irrigation diversion/delivery systems.

Link to full comment

The PEIS will evaluate reasonable alternatives, including conservation incentives.

The PEIS will consider impacts on fish passage and screening of the projects proposed to meet the Guiding Principles.

General support for project noted.

Tim Gartland

9120 Woodworth Avenue

Gig Harbor, WA 98332

 

SEPA Environmental Checklist for the Project may be incomplete. The responses appear to ignore the upstream impacts. Additionally, the manipulated flows meant to provide additional water during the late summer and early fall are by definition unnatural and will have deleterious effects on wildlife, wildlife systems and humans.

Increased late-season instream flows will make Icicle Creek unsafe for upstream property owners, camp site users, and other visitors to swim, wade, or bathe themselves.

Link to full comment

The PEIS will assess the potential impacts to wildlife and recreation that might result from the projects proposed to meet the Guiding Principles.

The PEIS will provide detailed streamflow, diversions, and out-of-stream use information relevant to the Guiding Principles and the projects proposed to meet the Guiding Principles.

Ed Burns

Conservation efforts seem to have the lowest priority.

The remote control of output from the lakes would seem to be relatively innocuous; the rebuilding of the Eightmile dam less so (interesting that in the reports the “historic” level of the lake is the level after the original dam was built); and the diversion from Upper Klonaqua Lake, outrageous.

Link to full comment

All of the Guiding Principles have equal priority and must be met as a package to effectuate the proposal endorsed by the Icicle Workgroup. 

The PEIS will evaluate reasonable alternatives.

Margie Van Cleve

272 Mapleway Road

Selah, WA 98942

 

  1. Objects to the term “reservoir” to describe the lakes within the Alpine Lakes Wilderness Area and to the purpose of the project (to manage release from the reservoirs that would optimize water supply in the Icicle Creek subbasin and be coordinate among all users).
  2. Conservation of municipal water should be a higher priority. Conservation initiatives should be addressed as a primary means of increasing instream flows; optimizing, modernizing, and automating reservoir management should come secondary.
  3. Concerned that IPID’s agricultural water rights associated with the Alpine Lakes will be converted to domestic water rights.
  4. Opportunities for utilizing reclaimed water should be considered as an alternative.

Link to full comment

Using the Alpine Lakes as reservoirs is the existing condition. One of the Alternatives being considered is to improve the operation of the Alpine Lakes reservoirs to meet the Guiding Principles.

The PEIS will describe the history of the Alpine Lakes, existing reservoirs, and current operations. 

All of the Guiding Principles have equal priority and must be met as a package to effectuate the proposal endorsed by the Icicle Workgroup. 

The PEIS will evaluate reasonable alternatives.

The PEIS will evaluate projects to meet the Guiding Principles, including conservation and reclaimed water, agricultural to domestic water right conversions, and storage. 

The PEIS will provide detailed streamflow, diversions, and out-of-stream use information relevant to the Guiding Principles and the projects proposed to meet the Guiding Principles.

Fred Smith

PO Box 357

Dryden, WA 98821

509-860-3997

  1. The number one priority should be whichever project increases stream flow the greatest during mid to late summer. This should be the rebuilding of the dam at Eightmile Lake to the original height, along with installation of automated valves.
  2. Regarding the Boulder Field: learn to live with it (i.e., make no change).

Link to full comment

All of the Guiding Principles have equal priority and must be met as a package to effectuate the proposal endorsed by the Icicle Workgroup. Project phasing and timelines will be included in the PEIS.

The PEIS will provide detailed streamflow, diversions, and out-of-stream use information relevant to the Guiding Principles and the projects proposed to meet the Guiding Principles.

The PEIS will evaluate reasonable alternatives.  Opportunities for fish passage improvements throughout Icicle Creek will be evaluated.

Lisa Pelly

Director, Trout Unlimited-Washington Water Project

 

Mike Wyant

President, Icicle Valley

Chapter of Trout Unlimited

 

TU Washington Water Project

103 Palouse Street, Suite 14

Wenatchee, WA 98801

509.888.0970

 

  1. TU is concerned that the Project package meeting Icicle Creek demands through 2050 is not substantiated because no assessment has been conducted specifically addressing future water supply and climate scenarios in the subbasin. Recommends procurement of a water supply and climate change analysis from a team of experts (e.g., UW Climate Impacts Group). TU has provided an analysis of stream flow for Icicle Creek.
  2. The IWG should develop a full list of project alternatives, should any of the projects in the proposed package require replacement.
  3. Lead agency under NEPA should be identified.
  4. Flow objectives could be monitored at the USGS gauge station above the Snow Creek confluence.
  5. Concerns about changes to the Alpine Lakes Wilderness area has been expressed by various stakeholders and user groups; these concerns should be taken seriously.
  6. TU has ongoing restoration projects in the subbasin. These projects will continue to be managed independent of the IWG Strategy process.
  7. The IWG should articulate benefit/cost information for projects in the proposed package. Preferably, this analysis should be conducted independent of the IWG.

Link to full comment

The PEIS will consider climate change and its impact on proposed projects.

The PEIS will evaluate reasonable alternatives.

The PEIS will include a narrative of the current state of water rights in the Icicle Creek Subbasin. For each project designed to meet the Guiding Principles, the PEIS will prescribe what existing and new permits would be necessary for the project.

The PEIS will describe NEPA and other permitting requirements

The PEIS will assess flow improvements in Icicle Creek at multiple locations.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will assess the potential impacts to wilderness and recreation that might result from the projects proposed to meet the Guiding Principles.

The PEIS will include a narrative of projected costs and benefits of projects proposed to meet the Guiding Principles.

The PEIS will describe “Alternatives Not Considered” to meet the Guiding Principles, but could be evaluated in another environmental review.

Rob Newsom

Eightmile Creek

Leavenworth, WA 98826

Cell 509-670-3166

 

I am glad for the water use study in the Icicle. Two things of concern:

  1. Every time extra water is released from Colchuck Lake there is a tremendous sediment load suddenly flowing by in Eightmile Creek/ Mountaineer Creek. This is a completely unnatural condition for fish and people in late summer.
  2. The continued use of helicopter support and further construction of dams in the Alpine Lakes Wilderness Area is blatantly at odds with the spirit of The Wilderness Act. 

Link to full comment

General support for project noted.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will assess the potential impacts to wilderness and recreation that might result from the projects proposed to meet the Guiding Principles.

The PEIS will discuss potential water quality impacts from projects proposed to meet the Guiding Principles.

Using and maintaining the Alpine Lakes as reservoirs is the existing condition. One of the Alternatives being considered is to improve the operation of the Alpine Lakes reservoirs to meet the Guiding Principles.

Ruth Dight, AICP

(206) 283 9254

2549 11th Ave W

Seattle, WA 98119

  1. The EIS must consider a Wilderness Protection Alternative to promote wilderness values (Wilderness Act of 1964) and would not allow new water infrastructure or diversions inside the Alpine Lakes Wilderness, and would require all new water supply to be obtained outside the Alpine Lakes Wilderness.
  2. The EIS must consider a Water Conservation Alternative, to use aggressive water conservation measures (inclusive of lawn-water restrictions). This alternative should also assess transfer of water rights from irrigation districts to cities, where agricultural land-use has been replaced by residential land-use.  This alternative should also assess agricultural irrigation efficiency (e.g., replacing open gravity canals with pipes and pumps). 
  3. The EIS must consider an Irrigation District Water Right Change Alternative to evaluate moving the IPID water right diversion from Icicle Creek downstream ~3 miles to the Wenatchee River.  This measure, which would permanently fix Icicle Creek’s low flow problem, would convert the IPID diversion from gravity flow to pumping (requiring electrical power). The Icicle Work Group should therefore analyze renewable energy options to supply that power, including solar, wind and in-canal hydroelectric.
  4. The EIS must consider a Water Right Relinquishment Alternative.  Loss of potential water resulting from lower  dam at Eightmile Lake should be considered as relinquishment of water rights.

Link to full comment

Using the Alpine Lakes as reservoirs is the existing condition. One of the Alternatives being considered is to improve the operation of the Alpine Lakes reservoirs to meet the Guiding Principles.

The PEIS will evaluate reasonable alternatives.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will include narrative of the current state of water rights in the basin. For each project designed to meet the Guiding Principles, the PEIS will prescribe what existing and new permits would be necessary for the project.

W. Thomas Soeldner

Valleyford, Washington

 

  1. The EIS must consider a Wilderness Protection Alternative that would promote the wilderness values set forth in the Wilderness Act of 1964.
  2. The EIS must consider a Water Conservation Alternative.
  3. The EIS must consider an Irrigation District Water Right Change Alternative, which would involve evaluating a move of the IPID water right diversion to the Wenatchee River Downstream, converting the diversion from gravity flow to pumping. Renewable energy options should be able to supply such power.
  4. The EIS should consider a Water Right Relinquishment Alternative, since the dam at Eightmile Lake collapsed decades ago.

Link to full comment

The PEIS will evaluate reasonable alternatives.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws.

The PEIS will include a narrative of the current state of water rights in the Icicle Creek Subbasin. For each project designed to meet the Guiding Principles, the PEIS will prescribe what existing and new permits would be necessary for the project.

John de Yonge

President

Wise Use Movement

PO Box 17804

Seattle, WA

98127

Unacceptable for work group to include agency conveners.

IWG must comply with Federal Advisory Committee Act.

Programmatic EIS should not preclude project level environmental review.

NEPA is required

The PEIS should identify existing and historic hydrologic conditions in Icicle Creek.

Comments on completeness of SEPA Checklist

Request for the PEIS to describe potential affected environment and identify potential impacts of program and proposed projects.

Request for the PEIS to include mitigation measures for potential impacts.

The PEIS should address the relationship between the LNFH and Icicle Creek, including purpose and need, fish production, and water withdrawals.

The PEIS should address tribal and non-tribal harvest of wild and hatchery fish in Icicle Creek.

The PEIS should provide background and need for domestic water supply in the Icicle Creek Subbasin.

The PEIS should provide a Wilderness Alternative.

The PEIS should identify existing fish passage barriers and projects which would improve fish passage.

The PEIS should comply with all local, state, and federal laws.

Projects proposed to meet the Guiding Principles should evaluate the potential for increased irrigation efficiencies and conservation practices, water markets, operational improvements to the LNFH, and improvements to fish screening.

The PEIS should identify the locations of all proposed projects.

Link to full comment

 

General objection to the project noted.

The PEIS will evaluate reasonable alternatives.

The PEIS will describe NEPA and other permitting requirements

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

Objection to SEPA checklist noted. The checklist was an optional process the IWG elected to do in order to provide transparency. A Determination of Significance was issued.

The PEIS will provide detailed streamflow, diversions, and out-of-stream use information relevant to the Guiding Principles and the projects proposed to meet the Guiding Principles.

PEIS will include a narrative of the current state of water rights in the Icicle Creek Subbasin. For each project designed to meet the Guiding Principles, the PEIS will prescribe what existing and new permits would be necessary for the project.

The PEIS will describe potential projects and impacts under the proposed program. Additional detail will be provided in any subsequent project level EIS.

The PEIS will include background information related to the development of the Guiding Principles, current condition in the Icicle Subbasin, and a need statement. This background information will include background on information on LNFH and domestic water supply.

The PEIS will identify targets for instream flows to support spawning, rearing, and migration of ESA-listed salmon, steelhead, and bull trout in Icicle Creek.

The PEIS will assess the potential impacts to wilderness and recreation, that might result from the projects proposed to meet the Guiding Principles.

The PEIS will consider potential aquatic habitat, habitat suitability, and recreational impacts of the projects proposed to meet the Guiding Principles.  Opportunities for fish passage improvements throughout Icicle Creek will be evaluated.

 

Thomas H. Walker
3815 Bagley Ave N
Seattle, WA  98103

 

  1. The Alpine Lakes Wilderness is a shared natural resource that must be respected and protected.
  2. The EIS should include a "Wilderness Protection" alternative, which should include an alternation of public purchase (buy-back) of private water rights in the Alpine Lakes.
  3. The EIS should include a "Water Right Relinquishment" alternative.
  4. The EIS should include an alternative that recognizes Icicle Working Group members' water rights are limited to the purposes for which they were initially granted, and cannot be redirected to other purposes.
  5. The EIS should include a "Water Conservation" alternative that emphasizes aggressive water conservation measures by the local water users. 
  6. The EIS should include a "Water Right Change" alternative.
  7. The EIS should analyze each proposed action's site-specific impacts, past practices, and the restoration, mitigation, and funding that are needed in the future.  At each site, proposed construction activities and proposed water diversions need to be spelled out in detail.
  8. The EIS should discuss the hydrological and biological impacts of the current drawdown of the lakes, and any proposed changes.
  9. The EIS should provide a detailed operations, maintenance, and environmental monitoring plan for the water infrastructure, and analysis of the wilderness impacts of specific maintenance actions, including helicopter use.
  10. The EIS should fully explain the purpose and need for the water these projects would provide.
  11. The EIS should fully explain what human activities caused the degraded conditions that the projects seek to improve.
  12. The EIS should analyze adequacy of proposed in-stream flows to support spawning, rearing, and migration of steelhead and bull trout.

Link to full comment

 

The PEIS will evaluate reasonable alternatives.

The PEIS will assess the potential impacts to wilderness and recreation that might result from the projects proposed to meet the Guiding Principles.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will include a narrative of the current state of water rights in the Icicle Creek Subbasin. For each project designed to meet the Guiding Principles, the PEIS will prescribe what existing and new permits would be necessary for the project.

The PEIS will consider impacts of lake/reservoir draw-down from proposed projects

The PEIS will identify targets for instream flows to support spawning, rearing, and migration of ESA-listed salmon, steelhead, and bull trout in Icicle Creek.

The PEIS will describe potential projects and impacts under the proposed program. Additional detail will be provided in any subsequent project level EIS.

Existing documents provide background on baseline flows, diversions, and current conditions in the Icicle Creek Subbasin, (see county website). The PEIS will provide additional detail on streamflow, diversions, out-of-stream use, and a need statement relevant to the Guiding Principles and the projects proposed to meet the Guiding Principles.

The PEIS will consider monitoring, maintenance, and operation of projects proposed to meet the Guiding Principles.

The PEIS will consider monitoring, maintenance, and operation of projects proposed to meet the Guiding Principles.

Michael Wyant

12125 Emig Drive

Leavenworth, WA  98826

(509) 548 7747

 

I am concerned that the projections for water savings to reach flow targets are overly optimistic:

  • The projections rely on all of the proposed projects being completed. The suite of proposals should include additional options so that meeting the target for flows does not rely on completing all of the projects.
  • The proposed positive effects of identified water management strategies are overly optimistic given many of the climate change projections for the next 50 years.

Though I consider myself a staunch supporter of wilderness, I am in favor of the proposed changes at the lakes in the Alpine Lakes Wilderness that are managed as water storage reservoirs.

  • I support those changes because maintaining the existence of the reservoirs was grandfathered in when the wilderness was established.
  • It makes sense to use the water in those reservoirs as efficiently as possible, even though doing so intrudes and will continue to intrude on the wilderness experience.
  • I support the reconstruction of Eightmile Lake dam to its original height even though doing so will inundate land that has been above lake level for many years.
  • I oppose raising the height of the original reservoir because that would represent a change to the agreement to keep the existing reservoirs when the wilderness was established.

I would like to be assured that sufficient scientific study is in place to make it relatively certain that the project will have the positive effects that are proposed and that the possibility that the project will have unintended negative consequences has been thoroughly considered. I would also like to know that each project that has the potential to impact the icicle ecosystem includes a plan and the resources necessary to study the post-project impacts.

  • Too often projects are completed with the idea that they will improve an ecosystem when there is no post-project evidence that they actually had the intended effects and that they are not, in fact, having a negative or unintended effect.

Link to full comment

 

General support for project noted.

The PEIS will consider monitoring, maintenance, and operation of projects proposed to meet the Guiding Principles.

The PEIS will provide detailed streamflow, diversions, and out-of-stream use information relevant to the Guiding Principles and the projects proposed to meet the Guiding Principles.

 

Winnie Becker

 

  1. Please preserve the Alpine Lakes Wilderness.   To build dams and change water rights would not be in keeping with the wilderness.
  2. The EIS should include a "Wilderness Protection" alternative.   The increase of water removal from the Alpine Lakes Wilderness is not in keeping with protecting the wilderness which is so very important for generations to come.    Water should be obtained from sources outside the Wilderness.   The Wilderness Protection alternative should comply with all the provisions in the Forest Service's administrative Alpine Lakes Wilderness Management Plan, including:   " Except as provided for in Section 4(D)(4) of the Wilderness Act, watersheds will not be altered or managed to provide increased water quantity, quality or timing of discharge.
  3. The Wilderness Protection alternative should evaluate public purchase (buy-back) of private water rights in the Alpine Lakes, which would allow removal of dams and other structures from the lakes to restore the area to its true natural character.
  4. The EIS should include "Water Right Relinquishment" alternative.   The alternative should analyze existing water rights to the Alpine Lakes and acknowledge those rights that have been relinquished or abandoned.
  5. The EIS should include an alternative that recognizes IWG members" water rights are limited to the purposes for which they were initially granted (irrigation is an example) and cannot be redirected to other purposes (such as suburban development).
  6. The EIS should include a "Water Conservation" alternative that emphasizes aggressive water conservation measures by the city of Leavenworth, Icicle-Peshastin Irrigation District, the Leavenworth fish Hatchery and other water users.   This alternative should evaluate water markets that facilitate selling and trading of water rights.
  7. The Water Conservation alternative should evaluate a transfer of water rights from IPID to Leavenworth for properties within the city limits that have now converted from orchards to residential properties. This alternative should analyze how appropriate reductions in water usage (that is, not using agricultural water quantities for lawn irrigation) would save that would then be available for other Leavenworth needs.
  8. The Water Conservation alternative should evaluate how IPID spills large quantities of water back into the Wenatchee River at the end of several of its canals.   The alternative should evaluate how this 19th century irrigation practice could be replaced with modern pumping and piping technologies.  The EIS should work to reduce water demand as an alternative to water supply.
  9. The EIS should include a "Water Right Change" alternative.   This alternative would evaluate improving Icicle Creek flows by moving IPID's point of diversion downstream (to the Wenatchee River).  This measure, which would add 100 cfs of water to Icicle Creek every year, would convert the IPID diversion from gravity flow to pumping (requiring electrical power).  This alternative should therefore analyze renewable energy options to supply that power, including solar, wind and in-canal hydroelectric.
  10. The EIS should discuss the hydrological and biological impacts of the current drawdowns of the lakes, and any proposed changes.   The analysis should include a review of scientific literature on the impacts of water removals upon wildlife, vegetation, soil and wilderness values
  11. The EIS should analyze each proposed action's site-specific impacts, past practices and the restoration, mitigation and funding that are needed in the future.   At each site, proposed construction activities and proposed water diversions need to be spelled out in detail.
  12. The EIS should provide a detailed operations, maintenance and environmental monitoring   for the water infrastructure, and analysis of the wilderness impacts of specific maintenance actions including helicopter use.
  13. The EIS should fully explain the purpose and need for water these projects would provide.
  14. The EIS should fully explain what human activities caused the degraded conditions (such as low instream flows in Icicle Creek) that the projects seek to improve. 
  15. The EIS should analyze adequacy of proposed instream flows to support spawning, rearing and migration of steelhead and bull trout.

Link to full comment

Using the Alpine Lakes as reservoirs is the existing condition. One of the Alternatives being considered is to improve the operation of the Alpine Lakes reservoirs to meet the Guiding Principles.

The PEIS will evaluate reasonable alternatives.

The PEIS will assess the potential impacts to wilderness and recreation that might result from the projects proposed to meet the Guiding Principles.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will consider impacts of lake/reservoir draw-down from proposed projects.

The PEIS will identify targets for instream flows to support spawning, rearing, and migration of ESA-listed salmon, steelhead, and bull trout in Icicle Creek.

The PEIS will describe potential projects and impacts under the proposed program. Additional detail will be provided in any subsequent project level EIS.

Existing documents provide background on baseline flows, diversions, and current conditions in the Icicle Creek Subbasin, (see county website). The PEIS will provide additional detail on streamflow, diversions, out-of-stream use, and a need statement relevant to the Guiding Principles and the projects proposed to meet the Guiding Principles

The PEIS will consider monitoring, maintenance, and operation of projects proposed to meet the Guiding Principles.

The PEIS will include narrative of the current state of water rights in the basin. For each project designed to meet the Guiding Principles, the PEIS will prescribe what existing and new permits would be necessary for the project.

 

Dean and Martha Effler

 

Please do not allow any agreement to provide water to commercial or residential users that would impact the hydrology and natural beauty of the Alpine Lakes Wilderness.  A wilderness no longer is a wilderness when you drain its natural resource or flood its land.  Only allow growth in local cities and counties based on water conservation methods rather than tapping into the waters of a protected wilderness.

Link to full comment

Using the Alpine Lakes as reservoirs is the existing condition. One of the Alternatives being considered is to improve the operation of the Alpine Lakes reservoirs to meet the Guiding Principles.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will assess the potential impacts to wilderness and recreation that might result from the projects proposed to meet the Guiding Principles.

 

Jena F. Gilman, P.E. (WA 23673)

1480 SW 10th Street

North Bend, WA 98045

  1. The EIS should fully explain the purpose and need for each of the water projects outlined in the “Icicle Strategy”.
  2. The EIS should analyze each of the proposed action’s site-specific impacts, past practices, and the restoration, mitigation and funding needed in the future.  At each site, proposed construction activities need to be explained and illustrated in detail as well as how wilderness and habitat values will be maintained throughout the period of construction for Wilderness users and the complete array of fauna and flora that inhabit these areas.
  3. The EIS should discuss the hydrological and biological impacts of the current drawdowns of the lakes within the Wilderness and the incremental impacts of any proposed changes.  The analysis should include the impacts of water removals upon all wildlife, vegetation, soil and wilderness values.
  4. The EIS should provide detailed operations and maintenance plans for proposed infrastructure and an analysis of the impacts on the wilderness experience of specific maintenance actions, including helicopter operations.
  5. The EIS should consider a Wilderness Protection Alternative.  This alternative would promote wilderness values as set forth in the Wilderness Act of 1964, would not allow new water infrastructure or diversions inside the Alpine Lakes Wilderness, and would require all new water supply to be obtained outside the Alpine Lakes Wilderness.
  6. The EIS should consider a serious Water Conservation Alternative.  This alternative would assess using aggressive water conservation measures by area cities, including restrictions on lawn watering and provision for landscaping that is suited to the climate without irrigation for any new development.  This alternative should also assess transfer of water rights from irrigation districts to cities, where orchards have already been torn out and replaced with residential subdivisions.  This alternative should also assess agricultural irrigation efficiency, such as replacing open gravity canals with pipes and pumps.  This Alternative should also consider water re-use technologies.
  7. The EIS should consider an Irrigation District Water Right Change Alternative, which would fix Icicle Creek's low flow problem.  This alternative would evaluate moving the Icicle-Peshastin Irrigation District's water right diversion, which presently takes 100 cubic feet per second out of Icicle Creek, to the Wenatchee River downstream. 
  8. The EIS should consider a Water Right Relinquishment Alternative.  Removal of water from the Alpine Lakes Wilderness is an issue only because the Icicle-Peshastin Irrigation District holds water rights that were grandfathered when the Wilderness was created.  When the dam at Eightmile Lake failed the Irrigation District did not fix it because they did not need the water.  When a party doesn't use their rights, they lose them.  The "Use It or Lose It” doctrine should govern.   The EIS needs to acknowledge this issue.

Link to full comment

The PEIS will evaluate reasonable alternatives.

The PEIS will assess the potential impacts to wilderness and recreation that might result from the projects proposed to meet the Guiding Principles.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will consider impacts of lake/reservoir draw-down.

The PEIS will identify targets for instream flows to support spawning, rearing, and migration of ESA-listed salmon, steelhead, and bull trout in Icicle Creek.

The PEIS will describe potential projects and impacts under the proposed program. Additional detail will be provided in any subsequent project level EIS.

The PEIS will include background information related to the development of the Guiding Principles, current condition in the Icicle Creek Subbasin, and a need statement.

The PEIS will consider monitoring, maintenance, and operation of projects proposed to meet the Guiding Principles.

The PEIS will include narrative of the current state of water rights in the basin. For each project designed to meet the Guiding Principles, the PEIS will prescribe what existing and new permits would be necessary for the project.

Carmen Andonaegui

WDFW, Region 2 Habitat Program Manager

1550 Alder St NW

Ephrata, WA 98823

(509) 754-4624

 

  1. It is essential the PEIS describes the sequencing and timing of permittable projects and identifies the beneficiaries of in-stream and out-of-stream flow improvements.  WDFW is concerned that water will be allocated for out-of-stream uses before an adequate amount of flow improvements are made in Icicle Creek. 
  2. At the public scoping meeting held in Leavenworth it was stated by Aspect Consulting that the timeframe associated with implementing projects ranged from 5-20 years.  In order to “track” flow improvements that may occur over the next 5-20 years, a project implementation schedule should be included in the PEIS so readers can adequately provide comments, mitigation recommendations, and resource protection expectations within the context of “real water” in “real time”.
  3. Please describe the “Alternative Projects” being contemplated for replacing projects that may not be feasible. WDFW expectations are that alternative projects would be identified through a collaborative process to replace those benefits and functions intended by the project determined to be infeasible.
  4. As fisheries co-managers for the state of Washington, WDFW does not support waiting 5-20 years to upgrade the Leavenworth Hatchery.  We respect Ecology and CCNRD’s efforts to find non-litigious solutions to upgrading the hatchery to meet state and federal laws.  However, we also want to be clear that though our agency is an active member of the IWG, we are in no way advocating delaying compliance-related upgrades at the hatchery as a result of being a project element of the PEIS.  We suggest providing details within the PEIS that “cross-walks” your efforts to solve hatchery issues with the U.S. Bureau of Reclamation and U.S. Fish and Wildlife Service’s efforts. 
  5. It is essential that long-term climate change scenarios serve as the “backbone” to developing the PEIS.  Refill scenarios for the Alpine Lakes remain uncertain, as do in-stream flows influenced from timing and quantity of annual precipitation.  WDFW urges Ecology not to over-commit water for out-of-stream uses made “available” as a result of implementing any of the projects.  We would not be doing our job as a resource agency if we did not safeguard stream flows to protect fish and their habitat throughout this PEIS process.  We assume the same level of safeguarding will occur from Ecology to protect senior water right holders from harm or avoid project actions that may cause adverse impacts to stream flows or water quality.  WDFW expects to see a robust section in the PEIS that evaluates climate change effects on project operational scenarios (e.g. new water management of the Alpine Lakes) and then illustrates how stream flow improvements will be achieved while simultaneously providing additional water for out-of-stream uses (i.e. show the math).
  6. Ecology and CCNRD have indicated that some of the projects listed above may be described with a higher level of detail within the PEIS than the broader ICWRMS projects, making some projects ready for early implementation.  Evaluation of projects considered for early implementation should include an assessment of natural resource costs and benefits as a function of project sequencing/early implementation within a subsequent project-level EIS, as necessary.
  7. As you are aware, WDFW is actively working on several fish screen and diversion replacement projects in Icicle and Peshastin Creeks to protect fish life; these projects are slated to occur in the near future.  WDFW staff will continue to manage these projects and our own environmental compliance process, associated grant awards, and partnerships independent of the Icicle Strategy.  However, our WDFW team is always available to assist with project planning and/or provide expertise to support PEIS development. 
  8. Please provide a hardy, water conservation and reduction section in the PEIS.  For example, what are some ways CCNRD and Ecology will reduce the current gallon per capita per day as a tool to provide water for future growth and respond to drought effects? How will those endeavors be coordinated with investigating new water supply in the Alpine Lakes?  WDFW recommends including a plan in the PEIS by which (1) CCNRD and Ecology will partner with utility providers to offer rebates for using less water, (2) to update local regulations and/or develop ordinances to promote and/or require water savings wherever possible, and (3) to develop water conservation and reduction incentive programs.
  9. WDFW still isn’t clear how the Upper Wenatchee Community Lands Plan is linked to the ICWMRS. WDFW habitat and wildlife staff have communicated with CCNRD that parcels identified in the Upper Wenatchee Community Lands Plan for acquisition may modestly add habitat value for wildlife or watershed protection in of itself. WDFW doubts these lands will be sufficient to provide “commensurate compensation for impacts to fish and wildlife resources” in the Icicle Creek basin.  In addition to low habitat value, the scope of the Upper Wenatchee Community Plan includes Cashmere to Stevens Pass, with three sub-areas not located in the Icicle Creek Basin including: 1) Blewett Pass/Peshastin, 2) Chumstick Valley, and 3) Nason & Coulter Creek.  The Wenatchee Community Lands Plan webpage makes no clear reference to how these “out-of-basin lands” are linked to the ICWRMS.  WDFW recommends Ecology and CCNRD work with resource experts to assess lands for acquisition and/or enhancement within the Icicle Creek basin that can provide valuable fish and wildlife habitat.  As you are aware, mitigation should be similar to the resource values lost through project development; out-of-place and/or out-of-kind mitigation is only appropriate when all other in-place mitigation opportunities have been exhausted.
  10. WDFW encourages Ecology and CCNRD to identify a lead federal agency to undertake the NEPA process as soon as possible.  WDFW is unclear if federal participation on the IWG and dedication of time and personnel constitutes a “major federal action” within the meaning of NEPA.  WDFW suggests delineating projects in the PEIS that cannot proceed until NEPA has been fulfilled.  This will ensure local, state, and federal agencies, tribes, and other stakeholder groups have a clear understanding of project implementation timelines and associated in-stream flow benefits for each project (i.e. when will the water be in Icicle Creek and how much). 
  11.  
  • The WDFW Priority Habitat and Species (PHS) data layers are a tool for planning purposes. These data sources cannot be assumed complete or exhaustive in expanses of wilderness considered in the PEIS.  Lack of information for any species does not indicate a lack of presence.  If the U.S. Forest Service (USFS) does not have species presence/absence surveys, WDFW recommends terrestrial surveys be completed for species likely to occur within the project footprint. 
  • Project activities requiring the use of helicopters pose a significant disturbance threat to mountain goats in the Alpine Lakes Wilderness - flying over mountain goats is considered to be a direct disturbance.  WDFW recommends conducting surveys for concentrations of mountain goats for PEIS development.  Specific consideration should be made for the timing of helicopter use to avoid the period when females are giving birth and following weeks when raising young.  
  • Golden eagles, peregrine falcons, northern goshawks, and northern spotted owls all occupy, nest, and rear young in associated habitats in the wilderness and may be located within the project footprint.  WDFW recommends conducting surveys within the project footprint so a plan can be developed to avoid disturbing nest sites, particularly until young have fledged.  The high elevation and colder conditions of the wilderness will extend fledging dates into the summer later than warmer low elevation habitats.
  • WDFW recommends conducting surveys for pika within the project footprint and to work closely with WDFW and the USFS to avoid impacts to this species at the project planning stage.
  • Any open water habitat included within the project footprint should be surveyed for common loon nesting.  The potential for direct impacts to loon nests is high for any project activities that would result in a rise of water elevation on any lakes.
  • The USFS and WDFW are coordinating in summer of 2016 to conduct amphibian and reptile surveys at wetlands, lakes, ponds or streams located within and whereas water-levels or flows are impacted by the package of projects in the PEIS.  Data collected and information in the final report should be used to develop the Final PEIS and for future, subsequent EISs.

Habitat

  • Installation of a flow meter, with access to the data should be made publicly available to confirm proposed minimum instream flows designated for the Historic Channel in Icicle Creek are being met.
  • WDFW support CCNRDs efforts to fund and install meters on all diversions.
  • The water market being developed for Icicle Creek will need to be coordinated annually with fisheries co-managers to avoid seasonal harm to instream flows, including winter flows to protect fish life.

Fish

  • Fish passage improvements should include flow as an important component to ensure riffles are passable to upstream migrating salmonids.
  • WDFW can provide fish stocking data for the Alpine Lakes if requested.  Our agency has a vested interest in ensuring changes in operations at the lakes do not adversely impact fish
  • Modeling flow scenarios out of each and/or all of the Alpine Lakes being contemplated in the PEIS will help prioritize flows scenarios that maximize benefits to fish at each relevant life stage.  Focal species and relevant life stages include Steelhead (adult, rearing), Rainbow trout (adult, rearing), Bull Trout (adult/sub-adult, rearing), Cutthroat Trout (adult, rearing), and Lamprey (adult).
  • Bringing fish screening associated with diversions into compliance with state and federal requirements should be a nondiscretionary “early action” item of the PEIS; this action should be funded and pursued in the immediate future as a priority of the ICWRMS.

Link to full comment

Continue consultation with WDFW.

Appropriate habitat and wildlife surveys will be conducted on affected environment for each of the proposed projects.

The PEIS will provide detailed streamflow, diversions, instream and out-of-stream use information relevant to the Guiding Principles and the projects proposed to meet the Guiding Principles.

All of the Guiding Principles have equal priority and must be met as a package to effectuate the proposal endorsed by the Icicle Workgroup. Project phasing and timelines will be included in the PEIS.

The PEIS will include a narrative of projected costs and benefits of projects proposed to meet the Guiding Principles.

The PEIS will evaluate reasonable alternatives.

The PEIS will discuss proposed actions under the Guiding Principles and related projects that are required by state/federal law.

The PEIS will consider climate change and its impact on proposed projects.

The PEIS will identify and discuss early implementation items.

The PEIS will describe NEPA and other permitting requirements

The PEIS will describe “Alternatives Not Considered” to meet the Guiding Principles, but could be evaluated in another environmental review.

The Guiding Principles include robust instream flow improvement. Construction of projects designed to provide this instream flow improvement may have some terrestrial impacts, which will be evaluated in the PEIS. The adequacy of lands proposed for acquisitions under the guidance of the Upper Wenatchee Community Lands Plan will be scaled appropriately.

Fish life stages will be described in the PEIS, as well as impacts to various species based on different instream flow quantities.

Doug Scott Wilderness Consulting

1723 18th Avenue, Suite 25

Seattle, WA 98122

The Alpine Lakes Wilderness Area is a beloved part of America's National Wilderness Preservation System:

The Wilderness Area--every acre of it -- is protected with the full strength of the 1964 Wilderness Act.

The building of new dams or water diversions, however “minor” you may think they would be, is illegal.

Were your proposal to succeed, it would constitute a very serious and unacceptable precedent.

Link to full comment

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

Using the Alpine Lakes as reservoirs is the existing condition. One of the Alternatives being considered is to improve the operation of the Alpine Lakes reservoirs to meet the Guiding Principles.

 

Alpine Lakes Protection Society; Alpine Lakes Foundation; Alliance for the Wild Rockies; American Whitewater; Aqua Permanente; Center for Environmental Law & Policy; Conservation Congress; El Sendero; Endangered Species Coalition; Federation of Western Outdoor Clubs; Friends of the Bitterroot; Friends of Bumping Lake; Friends of the Clearwater; Friends of the Enchantments; Friends of Lake Kachess; Friends of Wild Sky; Great Old Broads for Wilderness; Issaquah Alps Trail Club; Kachess Homeowners Association; Kachess Ridge Maintenance Association; Kittitas Audubon Society; Kittitas County Fire District #8; The Mazamas; Middle Fork Recreation Coalition; North Cascades Conservation Council; North Central Washington Audubon Society; Olympic Forest Coalition; River Runners for Wilderness; Save Our Sky Blue Waters; Seattle Audubon Society; Sierra Club; Spokane Mountaineers; Spring Family Trust for Trails; Washington Native Plant Society; Washington Wild; Western Lands Project; Wilderness Watch; Wild Fish Conservancy; Doug Scott Wilderness Consulting; and Rachael Osborn

 

  1. We suggest several reasonable alternatives to fully evaluate project opportunities, impacts and needed mitigation. We believe that the alternatives below are reasonable and can feasibly attain or approximate a proposal’s objectives, but at a lower environmental cost or decreased level of environmental degradation:
  2. The EIS should include a “Wilderness Protection” alternative.
  3. The EIS should include a “Water Right Relinquishment” alternative.
  4. The EIS should include a “Water Conservation” alternative
  5. The EIS should include a “Water Right Change” alternative
  6. Given the fact that the Wilderness Area is federally managed, the relationship between these two different review processes should be disclosed.
  7. The impact of each alternative on Icicle Creek’s resilience to climate change, particularly with regard to changes in amount or timing of precipitation and instream flow, should be evaluated.
  8. The EIS should discuss the hydrological and biological impacts of the current drawdowns of the lakes, and how the proposed changes will affect the current situation.
  9. The EIS should provide a detailed operations, maintenance, and environmental monitoring plan for the water infrastructure, and analysis of the wilderness impacts of specific maintenance actions, including helicopter use.
  10. The EIS should fully explain the purpose and need for the water these projects would provide.
  11. The EIS should analyze each proposed action’s site-specific impacts, past practices, and the restoration, mitigation, and funding that would be needed in the future.
  12. The EIS should analyze the adequacy of proposed instream flows to support spawning, rearing and migration of steelhead, salmon and bull trout.
  13. The EIS should include maps, diagrams and photos to clearly show the current situation (including the place of diversion and amount of water diverted) at each of the lakes and other project locations and how that would change under the proposed action(s) under each alternative

Link to full comment

The PEIS will evaluate reasonable alternatives.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will consider impacts of lake/reservoir draw-down from proposed projects.

Using the Alpine Lakes as reservoirs is the existing condition. One of the Alternatives being considered is to improve the operation of the Alpine Lakes reservoirs to meet the Guiding Principles.

The PEIS will consider monitoring, maintenance, and operation of projects proposed to meet the Guiding Principles.

Existing documents provide background on baseline flows, diversions, and current conditions in the Icicle Creek Subbasin, (see county website). The PEIS will provide additional detail on streamflow, diversions, out-of-stream use, and a need statement relevant to the Guiding Principles and the projects proposed to meet the Guiding Principles

The PEIS will describe all potential projects and impacts under the proposed program in detail. Additional detail will be provided in any subsequent project level EIS.

The PEIS will identify targets for instream flows to support spawning, rearing, and migration of ESA-listed salmon, steelhead, and bull trout in Icicle Creek.

The PEIS will provide detailed streamflow, diversions, and out-of-stream use information relevant to the Guiding Principles and the projects proposed to meet the Guiding Principles.

The PEIS will include narrative of the current state of water rights in the basin. For each project designed to meet the Guiding Principles, the PEIS will prescribe what existing and new permits would be necessary for the project.

Using the Alpine Lakes as reservoirs is the existing condition. One of the Alternatives being considered is to improve the operation of the Alpine Lakes reservoirs to meet the Guiding Principles

Existing easements, in-holder agreements, and State water rights will be reviewed.

 

Jasa Holt

Data Specialist

WDNR

Washington Natural Heritage Program

1111 Washington St SE

MS 47001

Olympia, WA 98504-7001

 

A summary of information on rare plants or rare and/or high quality ecological communities in the vicinity of your project accompanies this letter (Excel file; GIS shapefile).

Link to full comment

 

Comment noted.

Information provided by WDNR will be incorporated into the PEIS.

Eric Rickerson

State Supervisor

USFWS
Washington Fish and Wildlife Office

Central Washington Field Office

215 Melody Lane, Suite 103

Wenatchee, WA 98801

1) The USFWS recommends that a single Coordination Act Report be requested for the entire proposed Project package in collaboration with Ecology, CCNRD, WDFW, and the USFWS.

2) The PEIS should include the sequencing and timing of proposed Projects. The PEIS should also develop a phased implementation schedule to facilitate Section 7(a)(2) consultation with the USFWS to assess individual and cumulative impacts of Projects.

3) ‘Early and Often’ coordination with the USFWS Central Washington Field Office and federal partners is encouraged.

4) A single federal agency should be selected to lead Section 7(a)(2) consultation and NEPA processes.

5) Please carefully consider the scoping comments provided by the WDFW.

Link to full comment

Continue consultation with the USFWS and WDFW

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

All of the Guiding Principles have equal priority and must be met as a package to effectuate the proposal endorsed by the Icicle Workgroup. Project phasing and timelines will be included in the PEIS.

The PEIS will describe NEPA and other permitting requirements

Comment noted.

American Rivers, The Wilderness Society, Washington Trails Association, The Mountaineers

 

 

1) Our organizations recommend the IWG explore non-Wilderness options for improving instream flows.

2) We are very concerned by the potential negative impacts to recreation in the Enchantment Lakes region. These impacts should be identified through the PEIS and alternatives should be provided that avoid all negative impacts to aesthetics, user experience, trails, access and camping. There should be no net loss of recreational access and experience.

3) We are concerned that the scope of the Icicle Strategy may extend beyond the valid, existing water rights as limited by relinquishment and recorded agreements. We recommend that all water rights be analyzed for valid use.

4) Our organizations recommend the evaluation of improving Icicle Creek flows by moving the Icicle-Peshastin Irrigation District’s point of diversion downstream to the Wenatchee River.

5) We recommend identification of a federal agency that will serve as the lead during NEPA processes

6) Our organizations recommend the development of a list of proposed project alternatives that will meet the Guiding Principles established by the IWG and that are practical, feasible and implementable. Project alternatives will also demonstrate that the final package contains projects that have the greatest conservation benefit for the most effective cost.

Link to full comment

The PEIS will evaluate reasonable alternatives.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will include narrative of the current state of water rights in the basin. For each project designed to meet the Guiding Principles, the PEIS will prescribe what existing and new permits would be necessary for the project.

The PEIS will assess the potential impacts to wilderness and recreation that might result from the projects proposed to meet the Guiding Principles.

The PEIS will describe NEPA and other permitting requirements

Using the Alpine Lakes as reservoirs is the existing condition. One of the Alternatives being considered is to improve the operation of the Alpine Lakes reservoirs to meet the Guiding Principles

Bob and Linda Welsh

 

  1. Please do not seek any increase in the amount of water removed from the Alpine Lakes Wilderness area.
  2. The EIS should include a Wilderness protection alternative
  3. The EIS should include a Water Conservation alternative.
  4. The EIS should include a Water Right Change alternative
  5. The EIS should analyze each proposed action’s site-specific impacts, past practices, and the restoration, mitigation, and funding that are needed in the future. 
  6. The EIS should provide a detailed operations, maintenance, and environmental monitoring plan for the water infrastructure, and analysis of the wilderness impacts of the specific maintenance actions, including helicopter use.
  7. The EIS should fully explain the purpose and need for the water these projects would provide. 
  8. The EIS should fully explain what human activities caused the degraded conditions that the projects seek to improve. 

Link to full comment

The PEIS will evaluate all reasonable alternatives.

The PEIS will assess the potential impacts to wilderness and recreation that might result from the projects proposed to meet the Guiding Principles.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will describe potential projects and impacts under the proposed program. Additional detail will be provided in any subsequent project level EIS.

Existing documents provide background on baseline flows, diversions, and current conditions in the Icicle Creek Subbasin, (see county website). The PEIS will provide additional detail on streamflow, diversions, out-of-stream use, and a need statement relevant to the Guiding Principles and the projects proposed to meet the Guiding Principles.

The PEIS will consider monitoring, maintenance, and operation of projects proposed to meet the Guiding Principles.

Chester Marler

Leavenworth

  1. The PEIS should present the documentation that establishes the historic high water line at Eightmile Lake.
  2. Mitigation for activities at Eightmile Lake might include some trail re-routing around the lake, constructing new campsites on higher ground, softening the appearance of vegetation removal for the higher reservoir, etc.
  3. PEIS need to acknowledge the goal of protecting Wilderness values, not simply meet the letter of the law—acknowledge the feelings of Wilderness enthusiasts.
  4. Optimization and modernization of the flow from the lakes are great—should have been accomplished long ago.
  5. Water conservation by IPID and COIC does not appear as robust as it could. This should be more specific. Both districts need to address the non-agricultural use of a significant portion of their water—watering of extravagant and very large “lawns”. This tends to lessen the public image of the districts, and makes one wonder if legislative changes to the state’s water rights laws are in order.
  6. At some point in the future the pressure on water resources will be much greater and I would not be surprised to see many responsible citizens asking for fundamental changes to water law. This could include reducing water rights when lands change from agricultural use to suburban. The PEIS could look ahead and discuss how some of these issues will require being more flexible and creative in finding solutions.

Link to full comment

The PEIS will provide detail regarding Alpine Lakes Optimization, Modernization, and Automation including release rates, hydrologic inputs, changes to inundated area, and instream flow benefits.

The PEIS will provide detailed streamflow, diversions, and out-of-stream use information relevant to the Guiding Principles and the projects proposed to meet the Guiding Principles.

The PEIS will consider environmental monitoring as appropriate for potential impacts of any proposed projects.

The PEIS will assess the potential impacts to wilderness and recreation that might result from the projects proposed to meet the Guiding Principles.

The PEIS will evaluate reasonable alternatives.

 

 

 

Charles Raymond

3798 NE 97th St.

Seattle, WA 98115

(206) 522-3798

cfr98115@gmail.com

  1. The PEIS needs to present a range of alternatives with significantly more extensive analysis than given in the present information for scoping.
  2. Recognition of Wilderness values. All alternatives need to account for the special circumstances for construction and maintenance of structures in Wilderness Areas.
  3. Some alternatives (at least one and perhaps all) should include the aim to enhance Wilderness values through reduction in footprint, appearance of structures and the mode of maintaining them. What is the cost benefit ratio for each of the 7 managed lakes? Could one or more of them be returned to a natural condition without significant loss of flexibility or dependability? Could there be public buyback of associated water right to enable compensating adjustment on the user end?
  4. The PEIS needs to give historical background on actual water withdrawal and use and a clear explanation of corresponding water rights including identification of purposes for which they were granted.
  5. The PEIS should evaluate alternative diversion points (e.g., outside Icicle Creek in the Wenatchee River).
  6. The PEIS should include a conservation alternative.

Link to full comment

The PEIS will evaluate reasonable alternatives.

The PEIS will assess the potential impacts to wilderness and recreation that might result from the projects proposed to meet the Guiding Principles.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will provide detailed streamflow, diversions, and out-of-stream use information relevant to the Guiding Principles and the projects proposed to meet the Guiding Principles.

Patricia Danner

Spokane County and Washington State lifelong resident and registered voter

Alpine Lakes Wilderness Hiker

Wilderness areas need to remain WILD…Please, please, please use your position and ability to protect this gem of a wilderness area…If there is not enough water for the humans, then limit the human expansion in the area.  Don't drain and destroy the wilderness!

Link to full comment

Comment noted.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

Andy Zahn,

Toutle, WA

I am especially opposed to the reconstruction of the Eightmile lake dam and any new construction on Klonaqua lakes… Such projects are not compatible with the primeval character of wilderness. These are the two parts of the proposal with which I take the most issue, but I would like to express my disapproval of most everything else it contains. I would see all the Icicle Basin dams on alpine lakes removed and the region restored to its natural state. These structures are an ugly blemish on an otherwise pristine and spectacular region. Please explore other options such as water conservation rather than cause further degradation of the Alpine Lakes Wilderness.

Link to full comment

Comment noted.

The PEIS will evaluate reasonable alternatives.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will assess the potential impacts to wilderness and recreation that might result from the projects proposed to meet the Guiding Principles.

Laurel Schandelmier

  1. The public would appreciate a better understanding of the purpose and intent of making these proposed changes to improve instream flows. The EIS should provide alternatives that minimize, or even reverse, damage to existing wilderness area.
  2. The EIS should include a "Wilderness Protection" alternative that would not increase the amount of water removed from the Alpine Lakes Wilderness, not create a disturbance or encroach on wilderness lands, and not expand easements should be considered.
  3. The EIS should evaluate the feasibility of purchasing back private water rights to the Alpine Lakes to allow removal of dams and other structures to restore the wilderness to its pre-developed state. If this is not possible, I agree that installing remotely controllable valves to allow for the controlled drawdown of lake levels over a season, responding to current weather patterns and water needs, would add flexibility and robustness to the system.
  4. The EIS should consider a "Water Right Relinquishment" option for existing water rights in the Alpine Lakes if any have been relinquished or abandoned.
  5. The EIS should consider a "Water Conservation" option emphasizing aggressive water conservation.
  6. The EIS should analyze each proposed action's site-specific impacts, past practices, and any restoration, mitigation, or funding needed in the future. For each site, proposed construction activities and water diversions should be laid out in detail.
  7. The EIS should discuss the hydrological and biological impacts of the current level of lake drawdown, as well as any proposed future changes.
  8. A detailed operations, maintenance, and environmental monitoring plan for the water infrastructure alongside an analysis of wilderness impacts of specific maintenance actions.

Link to full comment

The PEIS will evaluate reasonable alternatives.

The PEIS will assess the potential impacts to wilderness and recreation that might result from the projects proposed to meet the Guiding Principles.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will consider impacts of lake/reservoir draw-down from proposed projects.

The PEIS will describe potential projects and impacts under the proposed program. Additional detail will be provided in any subsequent project level EIS.

The PEIS will consider monitoring, maintenance, and operation of projects proposed to meet the Guiding Principles.

Philip Fenner

Seattle

I understand the rationale behind your proposal to revive the old dams on some of the lakes there. I can see why you would like to do it. But I don't think you should. Doing that ought to be the absolute LAST thing you consider if water in the Wenatchee basin runs low. And here's why: Alpine Lakes Wilderness is a sacred place, in many ways to many people.

It should not be subjected to artificial manipulation - period. Just because it was manipulated in the past is no reason to start manipulating it again now.

If you're short on water do EVERYTHING else first, starting with a ban on lawn watering and taking other such water conservation measures. And the fish hatchery is a big water waster, fix that first. It just makes NO sense to damage a natural area if anything else could be done beforehand to see if the water equation could work without damaging Wilderness.

Link to full comment

The PEIS will include background information related to the development of the Guiding Principles, current condition in the Icicle Creek Subbasin, and a need statement.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will assess the potential impacts to wilderness and recreation that might result from the projects proposed to meet the Guiding Principles.

The PEIS will evaluate reasonable alternatives.

Greg Shannon

313 Olive Street

Cashmere, WA  98815

I have concerns about the collaborative efforts by members of the Icicle Working Group and the agency participation in the study.

I also have a concern about increasing water for development (transfer of water rights) without having a detailed PEIS alternative to look at major conservation of water by all users. 

Any impacts in the Alpine Lakes Wilderness should be addressed in a specific alternative.

Link to full comment

Comment noted.

The PEIS will evaluate reasonable alternatives.

The PEIS will assess the potential impacts to wilderness and recreation that might result from the projects proposed to meet the Guiding Principles.

Robert Mullins

234 Mine St.

Leavenworth, WA

I support, actually I demand, that Icicle-Peshastin Irrigation District will fully and completely use its water rights including any related construction, transportation, use of aircraft, use of power equipment, use of all legitimate activity, equipment, and construction related to full implementation of Icicle-Peshastin Irrigation District water rights and resultant uses in the Alpine Lakes Wilderness as existed before the creation of the Alpine Lakes Wilderness. These rights pre-exist and are more important than the Alpine Lakes Wilderness and any uses of any visitors to the Alpine Lakes Wilderness.

I understand the water rights, my family and I are dependent on that water.

Link to full comment

Comment noted.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

 

Ann Fink

201 Mine Street

Leavenworth, WA 98826

northfork@nwi.net

May 11, 2016

  1. The Irrigation districts has easements on only 2 of the 4 sections that underlie Eightmile Lake.  The other two sections are wilderness and don’t appear to have “easements”.  Please explain how the IWG can flood congressionally designated wilderness lands without involving the U.S. Forest Service in these discussions.
  2. The Icicle Irrigation District should provide its records regarding its use of water from this lake.
  3. I would like to see a discussion of how the Irrigation District and its partners will mitigate some of the ugly visual effects of raising the level of the lake and then lowering well below current levels.  The effects to plants and wildlife need to also be addressed.  Improvements at other lakes also need to consider the visual and ecological effects.
  4. Remote monitoring and control of existing facilities appear to be a good modern option if the equipment needed for this activity can be blended into the surroundings without intruding on wilderness values.  
  5. The Icicle Working Groups needs to champion conservation measures and improved facilities (non-leaky) water distribution systems for rational and equitable water distribution.

Link to full comment

The PEIS will evaluate reasonable alternatives.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will assess potential impacts to aesthetics.

The PEIS will consider mitigation measures for likely impacts identified in the document.

The PEIS will consider impacts of lake/reservoir draw-down from proposed projects.

Kimberly Wells

I urge the county to consult the applicable federal laws, including NEPA, the Wilderness Act, and the Endangered Species Act, and to reconsider the proposed project before proceeding to violate them.

Link to full comment

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

Jerry Bodine

585 SW Mt. Cedar Dr.

Issaquah, WA 98027

  1. The EIS should include a “Wilderness Protection” alternative. This alternative should promote Wilderness values by not seeking any increase in the amount of water removed from the Alpine Lakes Wilderness; not expanding easements; not encroaching on wilderness lands; not using mechanical transport; and not building any structure or installation in the Wilderness. Under the Wilderness Protection alternative, any new water supplies should be obtained from sources outside the Wilderness, and use non-Wilderness options for improving instream flows (for example, the IPID change in diversion point discussed below). The Wilderness Protection alternative should comply with all provisions in the Forest Service’s administrative Alpine Lakes Wilderness Management Plan, including: “Except as provided for in Section 4(d)(4) of the Wilderness Act, watersheds will not be altered or managed to provide increased water quantity, quality or timing of discharge.”

 

  1. The Wilderness Protection alternative should evaluate public purchase (buy-back) of private water rights in the Alpine Lakes, which would allow removal of dams and other structures from the lakes to restore the Wilderness area to its true natural character.

 

  1. The EIS should include a “Water Right Relinquishment” alternative. This alternative should analyze existing water rights to the Alpine Lakes and acknowledge those rights that have been relinquished or abandoned.

 

  1. The EIS should include an alternative that recognizes IWG members’ water rights are limited to the purposes for which they were initially granted (for example, irrigation) and cannot be redirected to other purposes (such as suburban development).

 

  1. The EIS should include a “Water Conservation” alternative that emphasizes aggressive water conservation measures by the City of Leavenworth, Icicle-Peshastin Irrigation District, the Leavenworth Fish Hatchery and other water users. This alternative should evaluate water markets that facilitate selling and trading of water rights.

 

  1. The Water Conservation alternative should evaluate a transfer of water rights from IPID to Leavenworth for properties within the city limits that have now converted from orchards to residential properties. This alternative should analyze how appropriate reductions in water usage (that is, not using agricultural water quantities for lawn irrigation) would save water that would then be available for other Leavenworth needs.

 

  1. The Water Conservation alternative should evaluate how IPID spills large quantities of water back into the Wenatchee River at the end of several of its canals. This alternative should evaluate how this 19th century irrigation practice (which was required to ensure water made it to the furthermost customers) could be replaced with modern pumping and piping technologies. The EIS should consider the resulting reduction in water demand as an alternative water supply.

 

  1. The EIS should include a “Water Right Change” alternative. This alternative would evaluate improving Icicle Creek flows by moving IPID’s point of diversion downstream (to the Wenatchee River). This measure, which would add 100 cfs of water to Icicle Creek every year, would convert the IPID diversion from gravity flow to pumping (requiring electrical power). This alternative should therefore analyze renewable energy options to supply that power, including solar, wind and in-canal hydroelectric.

 

  1. The EIS should analyze each proposed action’s site-specific impacts, past practices, and the restoration, mitigation and funding that are needed in the future. At each site, proposed construction activities and proposed water diversions need to be spelled out in detail.

 

  1. The EIS should discuss the hydrological and biological impacts of the current drawdowns of the lakes, and any proposed changes. The analysis should include a review of scientific literature on the impacts of water removals upon wildlife, vegetation, soil and wilderness values.

 

  1. The EIS should provide a detailed operations, maintenance and environmental monitoring plan for the water infrastructure, and analysis of the wilderness impacts of specific maintenance actions, including helicopter use.

 

  1. The EIS should fully explain the purpose and need for the water these projects would provide.

 

  1. The EIS should fully explain what human activities caused the degraded conditions (such as low instream flows in Icicle Creek) that the projects seek to improve. We should not be repeating the mistakes of the past.

 

  1. The EIS should analyze adequacy of proposed instream flows to support spawning, rearing and migration of steelhead and bull trout.

Link to full comment

The PEIS will evaluate reasonable alternatives.

Compliance with state and federal laws, including the Wilderness Acts, is one of the Guiding Principles. The PEIS will discuss the compatibility of projects proposed to meet the Guiding Principles with applicable state and federal laws. 

The PEIS will describe potential projects and impacts under the proposed program. Additional detail will be provided in any subsequent project level EIS.

The PEIS will consider impacts of lake/reservoir draw-down from proposed projects.

The PEIS will consider monitoring, maintenance, and operation of projects proposed to meet the Guiding Principles.

Existing documents provide background on baseline flows, diversions, and current conditions in the Icicle Creek Subbasin, (see county website). The PEIS will provide additional detail on streamflow, diversions, out-of-stream use, and a need statement relevant to the Guiding Principles and the projects proposed to meet the Guiding Principles.

The PEIS will identify targets for instream flows to support spawning, rearing, and migration of ESA-listed salmon, steelhead, and bull trout in Icicle Creek.

The PEIS will include narrative of the current state of water rights in the basin. For each project designed to meet the Guiding Principles, the PEIS will prescribe what existing and new permits would be necessary for the project.

 

 

Michael J. Painter

Californians for Western Wilderness

P.O. Box 210474

San Francisco, CA 94121-0474

info@caluwild.org

 

Californians for Western Wilderness fully endorses the comments submitted by Alpine Lakes Protection Society and 39 other organizations, dated May 11, 2016.

Link to full comment

Comment noted.

Responses to the endorsed letter are provided under comment 32.

Kayt Hoch

kayt@kaythoch.com

Proposed plan looks like a good approach that seems to have minimal impacts for a great benefit to region.

 

I hope there isn’t going to be negative fall-out from the Puget Sound group

 

Do you have some construction impacts estimations/projections? After the quick recovery of our own property after the impacts form the bridge project I’m not, concerned, just curious.

Link to full comment

General support noted.

The PEIS will describe potential projects and impacts under the proposed program. Additional detail will be provided in any subsequent project level EIS.