Pumped Storage Project #1 Preliminary Permit Application (FERC Project No. P-14996) Fact Sheet & Key Issues – June 21, 2019

On May 27, 2019, Premium Energy Holdings LLC of Walnut, CA applied for a 24-month preliminary permit for the Owens Valley Pumped Storage Project #1 to “secure and maintain priority of application for a license for the project under Part I of the Federal Power Act while obtaining data and performing the acts required to determine the feasibility of the project and to support an application for a license.”1

The preliminary permit application proposes a project with a lower dam/reservoir in the Gorge upstream of the Dept. of Water and Power (LADWP) Pleasant Valley Reservoir. Three different alternatives consider two upper dams/reservoirs in the White Mountains or an upper dam/reservoir upstream in the Owens River Gorge. Depending on the alternative chosen, dams, reservoirs, powerlines, powerhouses, tunnels, surge tanks, and access roads would be constructed on public lands managed by the Forest Service and Bureau of Land Management (BLM), and lands owned by LADWP. The upper dam/reservoir sites in the White Mountains are located in Inyo County. The Owens River Gorge dam/reservoir common to all alternatives straddles the Inyo/Mono County boundary. The upper Owens River Gorge dam/reservoir site considered in one of the alternatives is in Mono County.2

Premium Energy claims that the project’s main features and facilities will be located underground, will not alter the existing landscape or cause environmental disturbances, and will be out of public sight except for the proposed dams/reservoirs and transmission lines. According to Premium Energy, the project will be operated as a “closed loop” – once enough water is stored for project operation, additional water will not be diverted from the Owens River and operation will “not alter the existing streams flows.”3 However, no estimate is provided concerning how much additional water would have to be diverted from the Owens River Gorge and Wyman Creek to replace water lost through evaporation and seepage.

The OVPS Project #1 would generate 1,200-2,000 MW of power. Project transmission lines would connect with LADWP’s existing transmission system. An additional connection with Southern Edison’s (SCE) Windhub Substation near Mojave would facilitate the exchange of renewable energy with SCE. Upgrades to existing transmission lines and substations may be necessary.4 The project would have a combined total annual energy

1 Premium Energy (PE) Preliminary Permit Application for the Owens Valley Pumped Storage Project (OVPS) #1, pg. 1, May 27, 2019. 2 PE OVPS Application Exhibit 3, Project Map, pg. 24. 3 PE OVPS Application Exhibit 1, pgs. 7-8. 4 Ibid pg. 8.

1 production of 6,900 GWh.5 However, it’s important to keep in mind that the project overall would use more electricity than it produces.

Neither the U.S. Forest Service, Inyo National Forest or the BLM’s Bishop Field Office were originally notified or received a copy of the original application, despite the fact that these agencies manage public lands on which much of the project is located. It is unknown whether the applicant has shared its application or otherwise communicated with LADWP.

Dams/Reservoirs Details:6

RESERVOIR DAM RESERVOIR RESERVOIR TUNNEL LAND HEIGHT/ CAPACITY SURFACE DIAMETER/ MANAGER LENGTH (acre-ft) AREA (acres) LENGTH Wyman Reservoir Height: 12,730 115 Diameter: 21 ft. Inyo National 375 feet Length 19.5 miles Forest, BLM Length: Bishop Field 1,000 feet Office White Mountains Height: 12,057 175 Diameter: 21 feet Inyo National Reservoir 215 feet Length: 20.2 miles Forest, BLM Length: Bishop Field 650 feet Office Upper Owens Gorge Height: 23,419 175 Diameter: 29 ft. LADWP Reservoir 400 feet Length: 6.9 miles Length: 1,365 feet Lower Owens Gorge Height: 23,500 190 Diameter: 21 ft. LADWP Reservoir 375 feet Length 19.5 miles Length: 1,000 feet

If granted, the preliminary permit will allow Premium Energy to conduct project site land surveys; geological and seismic investigations; soil surveys, test pits, core holes, and topographical surveying; hydrological studies including runoff, rain, evaporation, and groundwater flow; evaluation of reservoirs configuration alternative; project water supply plan, including legal matters and water rights; environmental and cultural impact study comprising environmental surveys, impact identification, evaluation, and mitigation measures; engineering studies to optimize the project’s configuration; energy market studies; evaluation of transmission interconnection alternatives; size and specifications of required equipment; cost estimates, economic feasibility, and financing options; development of a preliminary licensing proposal, consultation, and documentation; and preparation, review and filing of the FERC license application.7

Temporary access roads are allowed to fulfill the purposes of the preliminary study permit, although Premium Energy would have to secure special use permits from the Forest Service and

5 Ibid pg. 11. 6 PE Preliminary Permit Application Exhibit 1, Tables 1, 2, & 3, pgs. 7-9 7 PE Preliminary Permit Application Exhibit 2, pgs. 21-22.

2 the BLM to construct temporary roads on public land, and presumably permission from LADWP to do so in the Owens River Gorge. The application confirms that temporary access roads will be needed to conduct studies. These temporary roads will access the Owens River Gorge dam/reservoir sites, subject to approval by the landowner (LADWP). The Wyman Canyon and White Mountains reservoir sites are accessible by the existing White Mountains and Wyman Canyon Roads. Construction of the White Mountains Reservoir would require relocation of at least one mile of the White Mountains Road. Additionally, access roads leading to existing substations or proposed converter stations will be also be required.8

The proposed new dams will also require subsurface investigations in the White Mountains and Owens River Gorge. This includes soil and rock borings and seismic surveys. Remedial actions in response to surface disturbance caused by the studies include an erosion and materials disposal plan, backfilling of core borings and test pits, and replanting any disturbed vegetation.9

The total estimated cost of carrying out and preparing the studies is $5 million. Funding for preliminary permit activities comes from Premium Energy and unspecified investors.10

Key Issues Identified by the California Wilderness Coalition (CalWild) & Others:

Ancient Bristlecone Pine Forest – Both of the potential dams/reservoirs proposed in the White Mountains are located in the Ancient Bristlecone Pine Forest. The Forest was established as a special management area by the Forest Service in 1959 to protect the ancient bristlecone pines and the outstanding visual experience provided by the surrounding landscape.11 The area was expanded and provided legislative protection by Congress in 2009. The legislation directs the Forest Service to protect bristlecone pines for public enjoyment and scientific study; recognize the botanical, scenic, and historical values of the area; and maintain near-natural conditions by ensuring that all activities are subordinate to the needs of protecting and preserving bristlecone pines. All forms of entry, appropriation, or disposal under the public land laws are prohibited.12 Management direction in the Inyo National Forest plan for the Ancient Bristlecone Pine Forest states that soil or watercourses should not be modified except to restore damaged areas to near natural condition or to control or prevent erosion. New above ground utility rights of way and major utility corridors are not suitable in the Forest.13

Recommended Wilderness Addition – The proposed Wyman Canyon dam/reservoir encroaches on the White Mountain West Wilderness addition in sections 6 and 7, T6S, R35E. This addition to the existing White Mountains Wilderness was recommended by the Forest Service because of its ecological integrity, good opportunities for solitude and primitive and unconfined

8 Ibid pg. 21. 9 Ibid pg. 22. 10 Ibid pg. 23. 11 Ancient Bristlecone Pine Botanical Area Management Plan, Inyo National Forest, 1974. 12 Public Law 111-11, 123 STAT. 1061, March 30, 2009. 13 Inyo National Forest Plan, pg. 105-106, August 2018.

3 recreation, and the ecological and scientific research features of the Ancient Bristlecone Pine Forest.14

Protected Inventoried Roadless Areas – The alternative White Mountain Reservoir is located on an unnamed southern tributary of Wyman Creek in the Birch Creek Inventoried Roadless Area (IRA 5060). The Birch Creek IRA is protected under the Forest Service’s Roadless Area Conservation Rule.15 The Wyman Canyon dam/reservoir is located in the White Mountains Inventoried Roadless Area (IRA 5058), which is also protected under the Roadless Area Conservation Rule. Tunnels leading from both reservoirs in the White Mountains run beneath the protected White Mountains IRA as well. The Inyo Forest Plan affirms protection of IRAs under the Roadless Area Conservation Rule.16

Bi-State Greater Sage-Grouse – The Bi-State Greater Sage-Grouse is eligible for protection as a threatened species. Both of the upper reservoirs considered in the project are located in Greater Sage-Grouse critical habitat designated in the White Mountains.17 Renewable energy development and the roads, powerlines and other infrastructure necessary to construct and operate renewable energy facilities have been cited as one of the factors contributing to the decline of the Bi-State Greater Sage-Grouse.

BLM Wilderness Study Areas – The proposed tunnels between the upper and lower reservoirs are located under the Fish Slough Wilderness Study Area (WSA CA-010-080) and Volcanic Tableland WSA (CA-010-081). WSA’s are protected from surface disturbance such as road building and other development.18 Subject to the consent of the BLM, activities allowed under the preliminary permit include the construction of temporary roads, drilling and boring for soil and rock samples, and seismic surveys. This could harm the wilderness character of the WSAs. Tunneling beneath them could adversely impact the flow of groundwater that feeds the Fish Slough wetlands, which contributes to their wilderness quality of the WSAs.

Inyo Forest Plan Compliance – Completed in August 2018, the revised Inyo National Forest Plan includes extensive management direction applicable to the public lands in the White Mountains that would be affected by the upper dams and reservoirs in the proposed project. However, the plan is not considered final until approved by the Forest Service’s Washington office (anticipated by the end of 2019).

In terms of water resources, the plan includes direction to minimize the effects of stream diversions and other flow modification and determine and recommend in-stream flows to

14 Inyo National Forest Land Management Plan Draft Record of Decision pg. 18, Final EIS Vol. 2 Appendix B pgs. 176, 178, August 2018. 15 https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsmrs_072402.pdf 16 Inyo Forest Plan pg. 106, August 2018. 17 Federal Register 78 FR 64327, USFWS, Oct. 28, 2013. 18 https://www.blm.gov/ca/pa/wilderness/wilderness_pdfs/wilderness_study_reports/FishSlough.pdf https://www.blm.gov/ca/pa/wilderness/wilderness_pdfs/wilderness_study_reports/VolcanicTablelands.pdf https://www.blm.gov/ca/pa/wilderness/wilderness_pdfs/wilderness_study_reports/CasaDiablo.pdf

4 maintain and enhance habitat conditions for native aquatic species, maintain and restore riparian resources, channel integrity, and aquatic passage.19

The proposed upper dams/reservoirs in the White Mountains would be located in riparian conservation areas. Forest Service management direction for riparian areas includes the establishment of designated equipment exclusion zones, ensuring that water temperatures are not adversely affected, maintenance and restoration of hydrologic connectivity, and prohibition or mitigation of ground-disturbing activities that adversely affect hydrologic processes.20 The White Mountains dams/reservoir sites are also located within the Cottonwood-Crooked Creeks Conservation Watershed, which provides high-quality habitat and functionally intact ecosystems that contribute to the persistence of species of conservation concern and the recovery of threatened and endangered species. Plan guidelines accept adverse effects from project activities when they are short term, site-specific, and support the long-term functionality of aquatic, riparian, and terrestrial ecosystems.21

In regard to and plant species, the applicable Inyo Forest Plan direction includes (but is not limited to) restoring and maintaining essential habitat for at risk species, collaborate with other agencies to improve conditions for at risk species, minimize disturbance in mule deer holding areas, avoid water developments where there is a high risk of dewatering aquatic and riparian habitats where at risk species occur, avoid fragmentation of sage grouse habitat and bury utility lines to reduce overhead perches for predators.22

In terms of recreation, applicable direction in the Inyo Plan includes (but is not limited to) use of the Recreation Opportunity Spectrum (ROS) for decisions on facilities and infrastructure.23 The public lands potentially impacted by the proposed upper reservoirs in the White Mountains (as well as accompanying access roads, transmission lines, and other development) have ROS allocations of primitive, semi-primitive non-motorized, and semi-primitive motorized recreation.24 Outside the recommended White Mountains West wilderness addition, the remaining area affected by the White Mountains reservoirs is to be managed as a Challenging Backroad Area (CBA).25 CBAs encompass largely undeveloped landscapes and are managed for dispersed summer and winter recreation, with natural landscapes and few amenities.26

The Inyo Forest Plan also includes direction to maintain scenic character for high-quality viewing experiences.27 The public lands where the White Mountains dams/reservoirs are located have very high and high scenic integrity objectives in the plan.28

19 Inyo National Forest Plan pg. 13, August 2018. 20 Ibid pg. 82-84. 21 Ibid pg. 80. 22 Ibid, pgs. 35-39. 23 Ibid pg. 54. 24 Inyo Forest Plan Appendix A, pgs. 125-126, Summer & Winter ROS Maps, August 2018. 25 Ibid pg. 135, Sustainable Recreation Management Areas Map. 26 Inyo Forest Plan, pg. 91. 27 Ibid pg. 55. 28 Inyo Forest Plan Appendix A, pg. 27, Scenic Integrity Objectives Map, August 2018.

5 BLM Lands Management & Resources – Tunnels connecting the upper reservoirs in the White Mountains and one of the lower reservoirs in the Owens River Gorge run underneath BLM lands managed under the 1993 Bishop Resource Management Plan. As previously noted, the tunnels are located beneath the Fish Slough and Volcanic Tablelands WSAs, which are to be managed to protect their wilderness qualities.

These proposed project tunnels are also located beneath the BLM’s Fish Slough Area of Critical Environmental Concern (ACEC). This 36,000 ACEC is managed by the BLM to protect the “rare and irreplaceable” ecosystems represented by Fish Slough and the surrounding Volcanic Tablelands, including the transition between the Mojave Desert and Great Basin biomes, diverse plan communities (wetlands, alkali meadows, and uplands), and one of the riches wetland floras in the Great Basin (with 126 described taxa) and habitat for rare endemic plants such as the Fish Slough milkvetch and Mariposa lily.29 The BLM “will give priority to the management and protection of ACECs.”30 It is unclear from the preliminary permit application the level of study activities, including the construction of temporary roads, boring of soil and rock samples, and seismic studies that would have to occur in the ACEC, should the applicant be able to obtain access from the BLM.

Most of the tunnels on or beneath BLM lands will be drilled through fractured volcanic rock. This could divert or otherwise affect groundwater that feeds the Fish Slough wetlands. The tunnels also run underneath Fish Slough itself, an important wetland that the BLM identified as an eligible wild and scenic river in 1990 due to its free flowing character and outstandingly remarkable fish (Owens pupfish, tui chub), ecological (good quality Great Basin marshland ecosystem, rare Fish Slough milkvetch), and cultural values.31 Tunneling could adversely affect groundwater flows that feed Fish Slough. In addition, the preliminary permit fails to mention the proposed location for the disposal of tunnel debris. BLM direction for the interim management and protection of eligible wild and scenic rivers prohibits hydroelectric development; discourages new transmission lines, natural gas lines, water lines, etc.”; restricts new facilities to existing rights of way; and provides for the selection of alternative locations and construction techniques that minimize adverse effects on river area related values. 32

Tunnels that transport water often require above ground vents or surge chambers. The above- ground portion of the surge chamber for the Castaic pumped storage plant in southern California, which rises 160 feet above the ground and is 120 feet in diameter, is visible for miles.33 LADWP’s tunnel paralleling the Owens River Gorge has no less than three surge tanks. One or more surge tanks required for the OVPS Project #1 may have to be located in and/or will be visible from the BLM Wilderness Study Areas and the Fish Slough ACEC above the tunnel

29 https://www.blm.gov/visit/fish-slough 30 BLM Bishop RMP ROD April 1993, pg. 8,. Federal Land Policy and Management Act, section 202(c)(3). 31 BLM Bishop Draft RMP DEIS 1990, Appendix 2, pgs. 245-253; BLM Bishop RMP ROD April 1993, pgs. 14-15, Special Management Areas Map 2. 32 BLM Bishop RMP ROD April 1993, App. 2 Interim Management Guidelines for Study Rivers, pgs. A2-4, A2-7. 33 https://en.wikipedia.org/wiki/Castaic_Power_Plant

6 routes. Given the expansive viewshed of the northern Owens Valley, the tanks will be quite visible.

The proposed project tunnels are located beneath BLM lands in the Benton Management Area. Ground water impacts from the tunnels and above ground facilities needed to operate the tunnels could conflict with the BLM’s general management direction for the Benton MA. In addition to protecting the Fish Slough ACEC and eligible wild and scenic river, the BLM’s general management direction for the Benton area is to enhance scenic and wildlife resources in this area, enhance semi-primitive dispersed non-motorized recreation and semi-primitive motorized recreation opportunities, protect sage grouse and mule deer habitat, and maintain and enhance habitat for threatened, endangered, or candidate species (Owens speckled dace, Owens Valley vole, Great Basin springsnail, Owens pupfish, and Owens tui-chub).34 These resources could be adversely impacted by tunnels, but also by above ground transmission lines and access roads located on BLM lands south and west of the Owens River Gorge.

Fish Slough Ecological Reserve – The proposed tunnels run just south of this state Reserve, which was established by the California Department of Fish and Wildlife to protect the Fish Slough wetlands and the rare plant, fish, and wildlife species that depend on the wetlands.35 Again, tunneling could affect the flow of groundwater that feeds Fish Slough, which is a major feature of the reserve.

Owens River Gorge – The application includes a lower dam/reservoir site in the Owens River upstream of the existing Pleasant Valley Reservoir and an alternative upper dam/reservoir site (in lieu of the upper sites in the White Mountains) upstream of LADWP’s Middle Gorge Power Plant. The lower dam/reservoir site in the Gorge straddles the Mono/Inyo County line. The upper dam/reservoir in the Gorge is located entirely in Mono County. These sites are primarily located on LADWP lands. The dams/reservoirs are accompanied by underground powerhouses and above ground switchyards and transmission lines that parallel the Owens River Gorge to the west on BLM lands.36

Temporary roads leading east from the existing Owens Gorge Road to the two dam/reservoir sites in the Gorge may be required to conduct preliminary permit studies, including soil and rock borings and seismic surveys.37 Although not mentioned in the amended application narrative, the project map shows a new transmission line linking the three lower power plants/switching yards paralleling the Owens River Gorge to the east on National Forest and BLM lands. Preliminary permit studies for these proposed facilities may require temporary access roads and subsurface investigations as well, subject to access approval by the BLM and LADWP.

34 BLM Bishop RMP ROD April 1993, pgs. 40-43. 35 https://www.wildlife.ca.gov/Lands/Places-to-Visit/Fish-Slough-ER 36 Exhibit 3, Project Map, pg. 23. 37 Exhibit 2, pgs. 20-21.

7 It appears that as much as half or more of the Gorge between Long Valley Dam and Pleasant Valley Reservoir could be inundated by the two new reservoirs. The lower dam/reservoir site in the Gorge and perhaps the upper site would adversely impact a legal settlement between LADWP, Mono County, and the California Dept. of Fish and Wildlife that has restored flows for fish and riparian habitat in a 10 mile segment of the Gorge between LADWP’s Upper Gorge Power Plant and the Control Gorge Power Plant just upstream of the Pleasant Valley Reservoir.38 The upper dam/reservoir site will infringe on critical habitat for the Owens tui chub.39 The Owens River Gorge is one of only three known populations of this endangered species.40

The Owens River Gorge attract smore than 30,000 climbers annually.41 The applicant notes that the proposed dam/reservoir sites in the Gorge would avoid the primary rock climbing routes located between the LADWP powerhouses. The Gorge between the LADWP powerhouses is a popular climbing area because LADWP’s Owens Gorge Road provides relatively easy access.42 As the popularity of this climbing area increases, more climbers are likely to migrate downstream and upstream of the powerhouses (despite the lack of road access) to find less used and more challenging routes. It is recommended that the applicant consult with the rock climbing community to determine the extent of climbing opportunities upstream and downstream of the LADWP powerhouses that could be impacted by the Gorge reservoirs.

County Zoning & Land Use – Project development on LADWP lands and other private lands must comply with county general plans and zoning. It’s important to note that a federal license to construct and operate a hydroelectric project confers on the project owner the right to condemn private land for project development.

Public lands owned by LADWP along the Owens River Gorge, Fish Slough, and scattered throughout the potential foot print of the proposed project are zoned by Mono County for Conservation/Open Space.43 Direction in the Mono County General Plan for land zoned as Conservation/Open Space is to preserve large expanses of open space permanently for wildlife habitat, viewshed values, recreational uses, and other resource protection purposes. Additional direction includes avoiding potential significant impacts to animal and plant habitats, protecting and restoring threatened and endangered plant and animal species and their habitats, avoiding potential significant impacts to local surface and groundwater from the development of water resource projects, conserving Mono County’s water resources while maintaining ecosystem health, protecting public trust values of the county’s water resources, avoiding potential significant water quality impacts, etc.44

38 https://www.wonews.com/Blog.aspx?id=2985 39https://apps.wildlife.ca.gov/bios/?al=ds531 40 https://www.wildlife.ca.gov/Regions/6/Desert-Fishes/Owens-tui-chub 41 https://www.accessfund.org/news-and-events/news/new-access-challenges-at-owens-river-gorge 42 https://www.mountainproject.com/map/105843226/owens-river-gorge 43 http://monomammoth.maps.arcgis.com/apps/Viewer/index.html?appid=8670c63cda0540b39c3ae388cdd7db78 44 https://monocounty.ca.gov/sites/default/files/fileattachments/planning_division/page/9617/conservation-os_final_12.08.15.pdf

8 Public lands owned by LADWP along the Owens River Gorge, Fish Slough, and scattered throughout the potential foot print of the proposed project are zoned by Inyo County for Natural Resources.45 The Conservation/Open Space element to the Inyo County General Plan has direction to protect open space, natural resources, wildlife and habitat, etc., similar to the Mono County General Plan.46

Earthquake Safety – The proposed project penstocks/tunnels run beneath the White Mountains and Fish Slough faults, which are capable of producing up to magnitude 6.7 earthquakes.47 Dams and other project facilities would have to be engineered to withstand earthquakes of this magnitude, which will increase the cost of the project. Movement of these faults could also result in the failure of steep slopes, particularly in the Owens River Gorge.

Rare, Sensitive, Threatened, Endangered, and Special Status Species – The California Natural Diversity Data Base48 lists the following rare, sensitive, threatened, endangered, and special status species in the area affected by the proposed project:

BIRDS MAMMALS FISH REPTILES/AMPHIBIANS MOLLUSKS/INSECTS PLANTS American North American porcupine Owens tui Western pond turtle Wong’s springsnail Nevada wormwood peregrine falcon Townsend’s big-eared bat chub Northern leopard frog Fish Slough Pinyon rockcress Golden eagle Spotted bat Owens sucker Northern sagebrush springsnail Foxtail thelypodium Yellow warbler Pallid bat Owens lizard California floater Torrey’s blazing star Loggerhead shrike Silver-haired bat speckled dace Panamint alligator Morrison bumble Bailey’s wooly Swainson’s hawk Hoary bat Owens pupfish lizard bee buckwheat Great blue heron Western small-footed White Mountains Wine-colored tufa Prairie falcon myotis skipper moss Yellow-breasted Long-legged myotis White Mountains Fiddleleaf chat Owens Valley vole sandhill skipper hawksbeard Olive-sided Sierra Marten White Mountains Inyo County star tulip flycatcher red fox icarioidas blue Owens Valley Southwestern Western white-tailed butterfly checkerbloom willow flycatcher jackrabbit White Mountains Alkali ivesia Willow flycatcher American badger saepiolus blue Wheeler’s dune- Cooper’s hawk Desert bighorn sheep butterfly broom Northern harrier California wolverine White-flowered Redhead Gray-headed pika rabbitbrush Great egret Parish’s Snowy ergret popcornflower American bittern Short-pedicelled Blacked-crowned cleomella night heron Hot springs Bank swallow fimbristylis Yellow-headed Silver-leaved blackbird milkvetch LeConte’s thrasher Fish Slough milkvetch Brewer’s sparrow Inyo phacelia Double-crested Marsh willowherb cormorant Salina Pass wildrye Black-tailed Alkali cord grass gnatcatcher Depressed standing- Long-billed curlew cypress Least Bell’s vireo Golden goodmania Burrowing owl Beautiful shootingstar

45 http://inyoplanning.org/general_plan/graphics/landuse/Diag01.pdf 46 http://inyoplanning.org/general_plan/goals/ch8.pdf 47 https://pubs.usgs.gov/of/2014/1045/pdf/ofr20141045_v2.0.pdf 48 https://www.wildlife.ca.gov/Data/CNDDB/Maps-and-Data#43018410-cnddb-quickview-tool

9 Greater sage- Nevada oryctes grouse Crowned muilla Naked-stemmed daisy Prickle leaf Beautiful cholla Pine Creek evening- primrose Booth’s hairy evening-primrose Limestone monkey flower Scribner’s wheat grass Prairie wedge-grass Coyote gilia July gold Shockley’s buckwheat Compact daisy Little cutleaf Akali hymenoxys Horned dandelion Clustered-flower cryptantha Gray cryptantha Poison Canyon stickseed Rabbit-ear rockcress California draba Virgate halimolobos Idaho sedge Spiny-leaved milk- vetch Egg milk-vetch Broad-keeled milk- vetch Shockley’s milk-vetch Inyo blazing star Coville’s dwarf abronia Scalloped moonwort Bristlecone pine Pinyon beardtongue Small-flowered rice grass White Mountains horkelia Nevada ninebark 49Early cinquefoil Beautiful cinquefoil Many-flowered thelypodium Bailey’s greasewood

Non-Native Species – There are non-native brown trout and possibly other non-native aquatic species in the Owens River Gorge. Pumping water uphill to the proposed reservoirs in the White Mountains could introduce these non-native species to the Wyman Creek drainage.

10 Cultural Resources – The proposed reservoirs and other project facilities are located in areas of high cultural and archeological sensitivity for resources associated with prehistoric big horn sheep hunting, historical period ranching and grazing, and possibly mining. Impacts associated with the tunnels (haul routes, tunnel debris storage locations, lay down areas, etc.) are likely to be extensive. The construction and ultimate physical foot print of the project needs to be thoroughly surveyed to avoid significant impacts on cultural values.

Additional Projects – The applicant originally applied for a preliminary permit for multiple dams and reservoirs. The revised application is for the Owens Valley Pumped Storage Project #1, which implies that more projects may be proposed in the future, along with potential cumulative impacts.

Other Pumped Storage Hydroelectric Projects In California – There are at least two pumped storage hydroelectric projects operating in California. These are PG&E’s Helms Project in Fresno County in the Sierra Nevada and the Castaic power plant in northern Los Angeles County operated by LADWP in cooperation with the California Dept. of Water Resources.

The Helms Project was specifically built as a pumped storage project and includes the 123,000 acre-foot Courtright Reservoir and the 129,000 acre-foot Wishon Reservoir, with an installed capacity of 1,212 MW.50

With a nominal installed capacity of more than 1,500 MW, the Castaic project uses the State Water Project’s Pyramid Reservoir and Castaic Reservoir to generate hydroelectricity via pumped storage, but the primary purpose of the reservoirs is to store water from the State Water Project for export to southern California cities.51

Both the Helms and Castaic projects were designed primarily to generate electricity during periods of high demand (summer afternoons in particularly) and to pump water back into the upper reservoirs at night when electricity demand and costs were low. During California’s energy crisis of 2000-2001, the Helms project was unable to operate because of the round-the- clock demand and high electricity costs caused by the crisis.52

The cost of construction of the Helms project ballooned from an initial estimate of $200 million to $600 million.53 More recently, the increase in electric demand in Central California has consumed transmission capacity prompting PG&E to plan to construct a new 150 mile-long 500 kV transmission line to restore the flexibility of Helms operations.54

50 https://en.wikipedia.org/wiki/Helms_Pumped_Storage_Plant 51 https://en.wikipedia.org/wiki/Castaic_Power_Plant 52 https://www.latimes.com/archives/la-xpm-2001-jan-24-mn-16302-story.html 53 http://large.stanford.edu/courses/2014/ph240/galvan-lopez2/ 54 https://www.nwcouncil.org/sites/default/files/ManhoYeung_1.pdf

11 FERC has issued a license for the proposed 1,300 MW Eagle Mountain Pumped Storage Project adjacent to Joshua Tree National Park. That project proposes to use groundwater as its water source and a former mine site for its reservoirs.55

Currently in California, GreenGenStorage has an active preliminary permit to study a pumped storage project using existing reservoirs on the Mokelumne and Bear Rivers in Amador County owned and operated by PG&E.56 The project was originally considered but dropped by PG&E. Conservationists are concerned that the Mokelumne-Bear project could adversely impact hard won restoration flows in the Mokelumne, cause potentially harmful changes in water temperature, and require raising the Lower Bear River dam, which would inundate a popular public recreation area.57

There are two other active preliminary permits for pumped storage projects in California. FERC has issued a preliminary permit for the existing San Vincente Reservoir and a proposed new upper reservoir in San Diego County.58 FERC has also issued a preliminary permit for the Bison Peak pumped storage project in the Tehachapi Mountains, using groundwater as its water source. FERC has confirmed that since the closed loop project uses groundwater, a federal license will not be necessary, leaving permitting and regulation of the project to local and state authorities.59

FERC issued a license in 2014 for the Sacramento Municipal Utility District’s (SMUD) Upper American River Project that included a proposed 400 MW pumped storage component. After reviewing the high costs and the potential for other more cost-effective electricity storage options that might better match its system, SMUD received permission to remove the pumped storage component from its license.60

The fact that both SMUD and PG&E have tabled pumped storage projects recently should be considered a warning about the physical, regulatory, and economic feasibility of such projects.

For more information or if you have questions about this fact sheet, please contact Steve Evans, CalWild Rivers Director, email: [email protected]; phone: (916) 708-3155.

55 https://www.geiconsultants.com/projects/eagle-mountain-pumped-storage 56 https://www.ferc.gov/whats-new/comm-meet/2017/122117/H-3.pdf 57 http://www.foothillconservancy.org/pages/focus1.cgi?magicatid=&magi_detail=521&magid=36 58 https://www.sdcwa.org/sites/default/files/2018%20Preliminary%20Permit.pdf 59 https://www.utilitydive.com/press-release/20180808-california-pumped-storage-project-will-likely-not-require-a-federal-license/ 60 https://www.tdworld.com/renewables/smud-cancels-pumped-storage-project

12