Owens Valley 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 Owens River Gorge upstream of the Los Angeles 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 California 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