FERC Issues Guidance for Hydro Development

FERC Issues Guidance for Hydro Development

The Federal Energy Regulatory Commission (FERC) issued guidance for developing “closed-loop pumped storage projects at abandoned mine sites and a list of existing non-powered federal dams” that FERC along with other agencies has agreed “have the greatest potential for non-federal hydropower development.” These both “fulfill FERC’s requirements under Sections 3003 and 3004 of the America’s Water Infrastructure Act of 2018 (AWIA).”

FERC was directed by AWIA to conduct a workshop in April 2019 that explored the “potential opportunities for the development of closed-loop pumped storage projects at abandoned mine sites.” The new guidance they issued is “based on information provided at the workshop, identifies resources and provides information to assist prospective applicants considering the development of closed-loop pumped storage projects at these sites.”

A closed-loop pumped storage project is “a pumped storage project that uses reservoirs situated at locations other than natural waterways, lakes, wetlands, and other natural surface water features.” The types of reservoirs that are used in closed-loop projects ” include reservoirs located in surface mine pits or underground mines.”

FERC worked “jointly with the Departments of the Army, the Interior, and Agriculture” to develop the list of already existing non-powered federal dams, as they were directed to by the AWIA. In December 2018, FERC “initiated consultation with the Department Secretaries by requesting agency points of contact for the purposes of receiving and providing input on a draft list of non-powered federal dams.” FERC developed their final list with “representatives of the Army Corps of Engineers, the Bureau of Reclamation, the National Park Service, the Forest Service, and the Department of Energy.”

To compile this list, FERC used “the U.S. Department of Energy’s (DOE) April 2012 Assessment of Energy Potential at Non-Powered Dams in the United States Report; the U.S. Army Corps of Engineers’ (Corps) July 2013 Hydropower Resource Assessment at Non-Powered USACE Sites; the U.S. Bureau of Reclamation’s (Reclamation) March 2011 Hydropower Resources Assessment at Existing Reclamation Facilities; and Reclamation’s March 2012 Site Inventory and Hydropower Energy Assessment of Reclamation Owned Conduits.”

From there, FERC “used DOE’s list of top 100 non-powered dams with the most estimated hydropower potential, prioritized by capacity.” After “obtaining the complete list of dams for the report from Oak Ridge National Laboratory” the list was up to 296 potential dams.

They then evaluated the potential of each dam for hydropower using this criterion:

·         “The compatibility of hydropower generation with existing purposes of the dam;

·         “The proximity of the dam to existing transmission resources;

The existence of studies to characterize environmental, cultural, and historic resources relating to the dam; and

·         “The effects of hydropower development on release or flow operations of the dam.”

The final list excludes:

·         “dams that are or will be utilized by a nonfederal hydropower project under an existing Commission-issued hydropower license;

·         “dams identified by the Forest Service as incompatible with the purposes of existing Forest Management Plans or reservation authority;

·         “dams identified by the Corps as incompatible with hydropower generation due to certain circumstances that would hinder hydropower development (e.g., pending dam removal, extenuating construction activities, etc.); and

·         “dams identified by the National Park Service that may have the potential to affect the national park system or the National Wild and Scenic River system.”

There are “230 non-powered federal dams, sorted by potential capacity, that FERC and the Department Secretaries agree have the greatest potential for non-federal hydropower development” on the final list.