By Kent Karriker
Recently a company called FreedomWorks, LLC applied to the Federal Energy Regulatory Commission (FERC) for a preliminary permit to study the feasibility of constructing a pump storage facility on Backbone Mountain, just north of Blackwater Canyon. They are calling it the Big Run Pump Storage Hydroproject due to its proximity to Big Run, a tributary of the Blackwater River. If constructed, the project would impact several parcels of private land, as well as about 1,000 acres of land on the Monongahela National Forest.
You can view the application and other project documents in the FERC Elibrary (https://www.ferc.gov/docs-filing/elibrary.asp). Click “general search,” set the date range to “all,” and enter docket number P-14889. The most recent version of the application is submittal number 20181015-5045.
In accepting the application for processing, FERC stated that “[t]he sole purpose of a preliminary permit, if issued, is to grant the permit holder priority to file a license application during the permit term. A preliminary permit does not authorize the permit holder to perform any land-disturbing activities or otherwise enter upon lands or waters owned by others without the owners’ express permission.”
If FERC issues the preliminary permit, we should expect the company to apply for a license application in short order, which would then kick off the on-site engineering and environmental studies. A subsequent grant of a FERC license would allow construction of the project. Prior to grant of a FERC license, the company would also have to obtain permission from the affected landowners, including a special use permit from the Forest Service to allow use of National Forest land, as well as any other necessary federal, state, and local authorizations.
What is a pump storage facility? Basically it is a giant battery that is used to store excess energy produced by an electric generating facility. Instead of using electrolyte chemicals to store energy the way your laptop battery does, a pump storage facility uses water to store the energy and gravity to release it.
Two reservoirs are constructed, one at a higher elevation than the other. During times when the generating facility is producing excess electricity, the excess is used to pump water from the lower reservoir into the higher reservoir. Later, to withdraw power from the “battery,” the operator releases water from the higher reservoir, letting it flow by gravity back to the lower reservoir. On the way down, it powers a turbine generator, thereby converting the stored energy back into electricity.
In this case the generating facilities producing the excess electricity would appear to be either the existing coal-fired plant at Mt. Storm or the windmill farm at Mount Storm (or both), and possibly other nearby generating facilities.
As proposed, the project would involve a 1,200 acre reservoir on top of Backbone Mountain (the upper reservoir). This reservoir would obliterate most of Tub Run, along with a portion of a tributary to Big Run. The Tub Run drainage lies mostly on previously mined property owned by Western Pocahontas, although it drains through National Forest land on its way down into Blackwater Canyon.
A few years ago, the WV Department of Environmental Protection (DEP) and the Forest Service spent a considerable amount of time, money, and effort restoring the area. This restoration involved taking down old mine highwalls, remediating gob piles, and most importantly, mitigating drainage of heavy metals into Tub Run and the Blackwater River. They achieved this mitigation by capping the area with a thick layer of limestone and topsoil.
It appears that the upper reservoir would be constructed on top of the restored area. One wonders whether construction disturbance could potentially re-expose the capped contaminated material. Also, the area is underlain by old mine tunnels, raising the possibility that the reservoir might leak into the old tunnels and create acid mine drainage problems.
The lower reservoir (a little over 1,000 acres) and an associated pump house would lie mostly on National Forest land near Lead Mine. The reservoir would obliterate most of Mill Run, which is a tributary to the mainstem of Cheat River. This watershed is currently undeveloped mature forest land that lies at the base of the steep western slope of Backbone Mountain.
The two reservoirs would be connected by “penstocks,” which are large tubes through which the water flows. The proposal includes seven penstocks, each 12 feet in diameter. These penstocks would cross National Forest land, and would appear to impact the head of Big Run Bog, which is a designated National Natural Landmark and Botanical Area. Two proposed spillways also appear to have the potential to impact Big Run Bog.
The penstocks and spillways also likely would impact West Virginia northern flying squirrel habitat, and possibly Cheat Mountain salamander habitat. The Cheat Mountain salamander is a federally-listed threatened species. The West Virginia northern flying squirrel was removed from the federal endangered species list several years ago, but it remains on the Forest Service’s Regional Forester’s Sensitive Species list.
The impacts to Big Run Bog, the West Virginia northern flying squirrel, and the Cheat Mountain salamander (if present) would be inconsistent with standards in the Monongahela National Forest Plan. In addition to these inconsistencies with Forest Plan direction, the Forest Service’s special use permitting process would require the project proponent to demonstrate that the project cannot be constructed off of National Forest land. To date, no such demonstration has been provided.
The project also would include construction of a new power line from Backbone Mountain over to the existing substation at Mt. Storm. This line would pass along the north rim of Blackwater Canyon, through the town of Davis, across the Blackwater River, and it appears that it might impact the new state wildlife management area on the former Canaan Valley Institute lands (the rudimentary map in the permit application makes it difficult to determine the exact path in relation to the wildlife management area). The application does not discuss the impacts of this line, but it likely would impact habitat for the West Virginia northern flying squirrel and Cheat Mountain salamander, and probably would have many other adverse environmental impacts.
The Highlands Conservancy board is currently developing a position on this project, and is considering whether to file for intervenor status with FERC. Although we do not have an official position at this time, we wanted to get this information out to members so you can file your own comments with FERC if you wish. Comments are due to FERC no later than December 28, 2018. Because the FERC Elibrary can sometimes be difficult to navigate, we strongly encourage you to get your comments in a few days early. You can find instructions for filing comments in FERC’s “Notice of Preliminary Permit Application Accepted for Filing and Soliciting Comments” (issuance number 20181029-3001 on the project docket). Please follow all instructions carefully so that your comment does not get ignored.