r/salmonfishing

I wanted to put this on the radar of the Oregon fishing community because I think it has implications beyond just Eagle Creek National Fish Hatchery.

The Oregon Department of Environmental Quality (DEQ) has opened public comment on Eagle Creek National Fish Hatchery's proposed **National Pollutant Discharge Elimination System (NPDES) permit**. That's essentially the water-quality permit regulating what the hatchery can discharge back into Eagle Creek.

The biggest issue for us is a new set of temperature requirements associated with the **2025 Willamette Subbasin Temperature Total Maximum Daily Load (TMDL)**. A TMDL establishes how much of a pollutant in this case excess heat a waterbody can receive while still meeting Oregon's water-quality standards.

I work at Eagle Creek National Fish Hatchery, so I've been following this closely.

Eagle Creek is a **flow-through hatchery**. We take water directly from Eagle Creek, use it to raise salmon, and return it to the same creek. We have essentially no ability to control the temperature of the water when it reaches our intake.

During warm summer conditions, that incoming water can already be warmer than the applicable temperature criterion. Under one of the final compliance options in the proposed permit, called **Minimum Duties**, the allowable additional thermal load is **0.0 million kilocalories per day** when the incoming water is already warmer than the temperature allowed under the wasteload allocation.

In plain English: under that option, when the creek is already too warm, the hatchery essentially cannot add a positive net thermal load to the water. Otherwise, we have to meet one of the permit's other compliance options.

That's where I see the practical problem:

**We raise salmon. These temperature standards are intended to protect salmon. But we cannot control the temperature of Eagle Creek before the water reaches the hatchery.**

There are technically ways to address this, but cost becomes a major issue. Cooling towers, chillers or groundwater systems might be possible, but Eagle Creek is continuously moving a large volume of water. Cooling that much water even a small amount could require major infrastructure, substantial power use and ongoing maintenance.

**The issue isn't whether engineers can dream up a way to cool the water it's whether anyone has the money to build and operate it at the scale a flow-through hatchery requires.**

Another potential pathway in the draft permit is **thermal-credit water-quality trading**. That could involve funding off-site riparian restoration including planting trees along streams to increase shade and reduce solar heating and then documenting enough temperature benefit to generate thermal credits that offset part of the hatchery's calculated thermal load.

DEQ's draft actually provides a compliance schedule of up to **10 years** if water-quality trading is pursued because of the time required to develop a trading plan, locate land for riparian revegetation and generate the necessary credits.

This also isn't just an Eagle Creek issue.

In 2024, Oregon Department of Fish and Wildlife temporarily closed **Leaburg and McKenzie River hatcheries** for the summer and moved fish off-site specifically to comply with DEQ permit conditions.

[ODFW: Leaburg and McKenzie River hatcheries temporarily closed](https://www.dfw.state.or.us/news/2024/05\_May/052424b.asp)

The temperature requirements affecting Eagle Creek come from the broader Willamette Subbasin temperature framework, so I think anglers should pay attention to how these requirements are incorporated into other flow-through hatchery permits as they are renewed.

I'm fully supportive of protecting cold-water habitat and improving conditions for salmon and steelhead. My concern is whether this permitting approach adequately accounts for the physical limitations of flow-through hatcheries and whether limited hatchery dollars end up going toward cooling equipment, flow-monitoring systems and off-site thermal-credit projects instead of fish production, staffing and aging hatchery infrastructure.

### Want to read the actual permit or comment?

**Public comments are open until 5:00 p.m. Thursday, November 5, 2026.**

**Oregon DEQ Public Notices:**

https://www.oregon.gov/deq/Get-Involved/Pages/Public-Notices.aspx

**Your DEQ Online:**

https://ordeq-edms-public.govonlinesaas.com/pub/login

Once in **Your DEQ Online**:

1. Select **"Public Notices Only"**

2. Search **Submittal #101462**

3. Open **USFW – Eagle Creek National Fish Hatchery**

4. Click the blue information **"i"** on the right

5. Select the **"Comments"** tab

You can submit a comment without creating an account unless you want to attach a file.

DEQ also has instructions here:

https://www.oregon.gov/deq/permits/pages/ydo-public-involvement.aspx

Whether you agree with my concerns or not, I'd encourage people to **read the permit for themselves** and submit their own comments to DEQ if they have something to add.

I'd also really like to hear from anyone working around other Oregon hatcheries: **Are you seeing similar temperature requirements as your NPDES permits are renewed?**