It is distressing to learn that sometimes not even wilderness designation can protect our beloved wild places from the destructive exploitation of humans. When it was designated, the Alpine Lakes wilderness included compromises allowing for the continued inappropriate use of spectacular alpine lakes as reservoirs that have allowed wasteful water use practices to continue. The dams would be entirely unnecessary if changes were made downstream to curtail water waste. Now they want even more water for towns and irrigation downstream, and have hatched a plan that would devastate wilderness treasures.
Dams have consequences for alpine lakes. If you have ever visited a reservoir when the water level is drawn down the downsides are obvious in their severity: acres of mud and rotting tree stumps, devastated riparian areas. Even a small irrigation dam can completely alter the natural character of a lake. Both terrestrial and aquatic ecosystems are greatly affected.
An additional factor to consider is the negative economic impact of any action affecting the visitor experience at the lakes in question. The Alpine Lakes Wilderness is one of the most popular areas for outdoor recreation in Washington. Outdoor recreation is a
26.2 BILLION dollar industry in Washington, responsible for directly creating 201,000 jobs in the state, and generating $7.6 BILLION in wages and salaries, and $2.3 BILLION in state and local tax revenue. Leavenworth and the surrounding region have built their economy on a foundation of tourism and outdoor recreation, and any damage done to the pristine natural beauty of the area will have repercussions for the local economy.
The Draft Environmental Impact Statement includes proposals such as boring a hole from upper to lower Klonaqua lake, a move that would drastically and adversely affect the currently pristine upper lake. Other proposals would raise the level of the existing small dams on Eight Mile, as well as both upper and lower Snow Lakes. Several other lakes, including the magnificent Colchuck Lake, are also targeted by the proposal.
The Icicle Network webpage has detailed coverage of the issue: https://www.iciclenetwork.com
As does the most recent issue of the A.L.P.S. (Alpine Lakes Protection Society) newsletter: http://www.alpinelakes.org/newsletters/alpine_2018_01.pdf
You can find the full D.E.I.S. on the Chelan County Natural Resources page: http://www.co.chelan.wa.us/natural-resources/pages/environmental-review
Comments can be emailed to nr.iciclesepa@co.chelan.wa.us
Or sent to this address: Mike Kaputa: Director, Chelan County Natural Resource Department. 411 Washington Street., Suite 201, Wenatchee, WA 98801
Comments are due by July 30th 2018, so get your word in soon and help save the Alpine Lakes!
The A.L.P.S. Newsletter has some good suggestions for points to include in your comment:
• Please tell the agencies that the Alpine Lakes Wilderness is a shared natural resource that must be respected and protected. It is one of the nation’s more popular wilderness destinations and attracts people from around the world, particularly to the Enchantments Basin, known for its competitive permit lottery.
• The DPEIS fails to meaningfully consider fundamental legal issues that will determine which proposals can and cannot be built, including federal wilderness law and state water law. The DPEIS assumes IPID’s easements supersede federal wilderness law, which is wrong. The DPEIS also fails to fully analyze limitations on the scope and validity of IPID’s water rights, which would limit several proposals.
• Alternative 4 is the worst. It includes drilling a tunnel between two lakes (Upper and Lower Klonaqua Lakes); building a higher dam at Upper Snow Lake (enlarging that lake); and a higher-than-ever dam at Eightmile Lake (making that lake bigger than it has ever been). All of these lakes are inside the Alpine Lakes Wilderness. These projects are unprecedented in the National Wilderness System. These projects were not part of the proposed action in the SEPA scoping conducted by IWG in 2016, so the public was not provided an opportunity to comment on them during scoping. The DPEIS analysis of these proposals is grossly inadequate. IPID has no right to ALPINE enlarge Eightmile Lake, and has never had any water rights at Upper Klonaqua Lake.
•Alternative 5 is the least harmful alternative. It includes the “Full IPID Pump Station,” which would move IPID’s point of diversion downstream to the Wenatchee River, and greatly improve flows in Icicle Creek, especially in future decades when climate change will reduce flows in the Icicle watershed. However, Alternative 5 also includes the defective Eightmile “Restoration” project to make Eightmile dam higher than it has been since 1990, i.e., to enlarge Eightmile Lake.
• The DPEIS fails to account for IPID’s relinquishment of part of its water rights at Eightmile Lake. Water that IPID has not used now belongs to the federal government under the federal reserved water right doctrine. If the dam is rebuilt it should remain at its current elevation, where it has been since at least 1990. Any dam rebuilding must be approved by the U.S. Forest Service and must comply with the National Environmental Policy Act (NEPA) and other federal and state laws.
• The Eightmile “Restoration” project assumes a new dam will be higher than the current one, and fails to analyze the alternative scenario where IPID is not allowed to build a new dam any higher than the current one. That alternative is missing, and thus the DPEIS fails to present an adequate range of alternatives. The wilderness protection community has repeatedly told the DPEIS authors that there will be litigation to enjoin any effort to make the dam higher. Litigation takes time and money on both sides.
• IPID’s water rights were granted for the designated purpose of irrigation. The DPEIS proposes to use IPID water for other purposes, such as the fish hatchery and domestic use in Leavenworth, but IPID has no right to use water for these additional purposes.
• For new storage, “restoration” storage and “optimization” projects, the timelines and estimated costs stated in the DPEIS are highly suspect, because the DPEIS fails to account for the fact that these lakes are on National Forest lands inside the Alpine Lakes Wilderness. The DPEIS repeatedly ignores protections of the Wilderness Act. It repeatedly ignores the land management role and authority of the U.S. Forest Service on these National Forest lands. It repeatedly ignores the fact that major federal actions require analysis under the National Environmental Policy Act (NEPA). SEPA is not NEPA. The true costs of Alternatives 1, 2 and 4 are likely much higher than the DPEIS estimates, and closer to the cost of Alternative 5.
• Because the projects are in Wilderness, non-motorized access and non-motorized equipment (i.e. hand tools) and traditional skills should be required whenever feasible. Since the dams were originally built that way, the exceptions should be rare.
• The DPEIS repeatedly ignores the negative impacts on the riparian ecosystems in the Alpine Lakes Wilderness from the proposed unnaturally timed releases of water from lakes, which alters stream hydrology. The DPEIS generally fails to recognize that altering the natural flow regime can degrade a stream’s physical and chemical properties, leading to loss of aquatic life and reduced aquatic biodiversity. We are concerned that IWG has not done adequate sampling and monitoring of impacts from past releases into these wilderness streams, including cumulative impacts.
• Conservation components in the DPEIS are simply insufficient. They need to be expanded to significantly reduce demands on Icicle Creek’s water, thereby allowing its watershed to function more naturally. This will better support our region’s livability and economy over the long-term.
• While we appreciate the goal to improve instream flows in Icicle Creek, it is contradictory to exploit one natural area under the guise of enhancing another, particularly when other options are available.
• The DPEIS should be revised to address the above deficiencies. A Revised Draft PEIS should be released for public comment.
I would also add to those suggestions that an alternative should be added to the plan in a Revised Draft PEIS that would include the complete removal of removal of structures at the lakes so that they can be restored to a completely natural state.
At the very least there should be an option where no action whatsoever is taken (something that the current “no action” alternative does not actually provide).
Dams have consequences for alpine lakes. If you have ever visited a reservoir when the water level is drawn down the downsides are obvious in their severity: acres of mud and rotting tree stumps, devastated riparian areas. Even a small irrigation dam can completely alter the natural character of a lake. Both terrestrial and aquatic ecosystems are greatly affected.
An additional factor to consider is the negative economic impact of any action affecting the visitor experience at the lakes in question. The Alpine Lakes Wilderness is one of the most popular areas for outdoor recreation in Washington. Outdoor recreation is a
26.2 BILLION dollar industry in Washington, responsible for directly creating 201,000 jobs in the state, and generating $7.6 BILLION in wages and salaries, and $2.3 BILLION in state and local tax revenue. Leavenworth and the surrounding region have built their economy on a foundation of tourism and outdoor recreation, and any damage done to the pristine natural beauty of the area will have repercussions for the local economy.
The Draft Environmental Impact Statement includes proposals such as boring a hole from upper to lower Klonaqua lake, a move that would drastically and adversely affect the currently pristine upper lake. Other proposals would raise the level of the existing small dams on Eight Mile, as well as both upper and lower Snow Lakes. Several other lakes, including the magnificent Colchuck Lake, are also targeted by the proposal.
The Icicle Network webpage has detailed coverage of the issue: https://www.iciclenetwork.com
As does the most recent issue of the A.L.P.S. (Alpine Lakes Protection Society) newsletter: http://www.alpinelakes.org/newsletters/alpine_2018_01.pdf
You can find the full D.E.I.S. on the Chelan County Natural Resources page: http://www.co.chelan.wa.us/natural-resources/pages/environmental-review
Comments can be emailed to nr.iciclesepa@co.chelan.wa.us
Or sent to this address: Mike Kaputa: Director, Chelan County Natural Resource Department. 411 Washington Street., Suite 201, Wenatchee, WA 98801
Comments are due by July 30th 2018, so get your word in soon and help save the Alpine Lakes!
The A.L.P.S. Newsletter has some good suggestions for points to include in your comment:
• Please tell the agencies that the Alpine Lakes Wilderness is a shared natural resource that must be respected and protected. It is one of the nation’s more popular wilderness destinations and attracts people from around the world, particularly to the Enchantments Basin, known for its competitive permit lottery.
• The DPEIS fails to meaningfully consider fundamental legal issues that will determine which proposals can and cannot be built, including federal wilderness law and state water law. The DPEIS assumes IPID’s easements supersede federal wilderness law, which is wrong. The DPEIS also fails to fully analyze limitations on the scope and validity of IPID’s water rights, which would limit several proposals.
• Alternative 4 is the worst. It includes drilling a tunnel between two lakes (Upper and Lower Klonaqua Lakes); building a higher dam at Upper Snow Lake (enlarging that lake); and a higher-than-ever dam at Eightmile Lake (making that lake bigger than it has ever been). All of these lakes are inside the Alpine Lakes Wilderness. These projects are unprecedented in the National Wilderness System. These projects were not part of the proposed action in the SEPA scoping conducted by IWG in 2016, so the public was not provided an opportunity to comment on them during scoping. The DPEIS analysis of these proposals is grossly inadequate. IPID has no right to ALPINE enlarge Eightmile Lake, and has never had any water rights at Upper Klonaqua Lake.
•Alternative 5 is the least harmful alternative. It includes the “Full IPID Pump Station,” which would move IPID’s point of diversion downstream to the Wenatchee River, and greatly improve flows in Icicle Creek, especially in future decades when climate change will reduce flows in the Icicle watershed. However, Alternative 5 also includes the defective Eightmile “Restoration” project to make Eightmile dam higher than it has been since 1990, i.e., to enlarge Eightmile Lake.
• The DPEIS fails to account for IPID’s relinquishment of part of its water rights at Eightmile Lake. Water that IPID has not used now belongs to the federal government under the federal reserved water right doctrine. If the dam is rebuilt it should remain at its current elevation, where it has been since at least 1990. Any dam rebuilding must be approved by the U.S. Forest Service and must comply with the National Environmental Policy Act (NEPA) and other federal and state laws.
• The Eightmile “Restoration” project assumes a new dam will be higher than the current one, and fails to analyze the alternative scenario where IPID is not allowed to build a new dam any higher than the current one. That alternative is missing, and thus the DPEIS fails to present an adequate range of alternatives. The wilderness protection community has repeatedly told the DPEIS authors that there will be litigation to enjoin any effort to make the dam higher. Litigation takes time and money on both sides.
• IPID’s water rights were granted for the designated purpose of irrigation. The DPEIS proposes to use IPID water for other purposes, such as the fish hatchery and domestic use in Leavenworth, but IPID has no right to use water for these additional purposes.
• For new storage, “restoration” storage and “optimization” projects, the timelines and estimated costs stated in the DPEIS are highly suspect, because the DPEIS fails to account for the fact that these lakes are on National Forest lands inside the Alpine Lakes Wilderness. The DPEIS repeatedly ignores protections of the Wilderness Act. It repeatedly ignores the land management role and authority of the U.S. Forest Service on these National Forest lands. It repeatedly ignores the fact that major federal actions require analysis under the National Environmental Policy Act (NEPA). SEPA is not NEPA. The true costs of Alternatives 1, 2 and 4 are likely much higher than the DPEIS estimates, and closer to the cost of Alternative 5.
• Because the projects are in Wilderness, non-motorized access and non-motorized equipment (i.e. hand tools) and traditional skills should be required whenever feasible. Since the dams were originally built that way, the exceptions should be rare.
• The DPEIS repeatedly ignores the negative impacts on the riparian ecosystems in the Alpine Lakes Wilderness from the proposed unnaturally timed releases of water from lakes, which alters stream hydrology. The DPEIS generally fails to recognize that altering the natural flow regime can degrade a stream’s physical and chemical properties, leading to loss of aquatic life and reduced aquatic biodiversity. We are concerned that IWG has not done adequate sampling and monitoring of impacts from past releases into these wilderness streams, including cumulative impacts.
• Conservation components in the DPEIS are simply insufficient. They need to be expanded to significantly reduce demands on Icicle Creek’s water, thereby allowing its watershed to function more naturally. This will better support our region’s livability and economy over the long-term.
• While we appreciate the goal to improve instream flows in Icicle Creek, it is contradictory to exploit one natural area under the guise of enhancing another, particularly when other options are available.
• The DPEIS should be revised to address the above deficiencies. A Revised Draft PEIS should be released for public comment.
I would also add to those suggestions that an alternative should be added to the plan in a Revised Draft PEIS that would include the complete removal of removal of structures at the lakes so that they can be restored to a completely natural state.
At the very least there should be an option where no action whatsoever is taken (something that the current “no action” alternative does not actually provide).
