TAKE ACTION FOR THE MIRACLE MILE

For questions, please contact Patrick Harrington

Patrick.Harrington@tu.org

1. Sign the Petition

Visit https://www.votervoice.net/TU/Petitions/5738/Respond to sign the petition.

2. Comment to FERC

How to Submit Official Public Comments to FERC:
Your voice matters. Submit your public comments to the Federal Energy Regulatory Commission (FERC) by March 14th to help protect the Miracle Mile and North Platte River ecosystem. 

1. Go to https://ferconline.ferc.gov/QuickComment.aspx. Please fill out the form, keep an eye out on your email inbox for a verification email, then submit your comment.   

1. Reference Docket # P-14787 in your comment submission 

1. Add a paragraph that personalizes your comment (where do you live, why are you concerned about this project, how might it impact you?) to our sample letter below, cut and paste, and submit. 

Template Message – please customize as you would like.  

Dear Federal Energy Regulatory Commission,

[Insert personalize paragraph: where do you live, why are you concerned about this project, how might it impact you?] 

I am writing to urge that a full and science-based Environmental Impact Statement (EIS) be prepared for the proposed Seminoe Pumped Storage Project in order to protect the irreplaceable fish and wildlife habitat, water quality, and recreation opportunities in and around the North Platte’s Miracle Mile and Seminoe Reservoir. The Miracle Mile section of the North Platte River is a Wyoming Game and Fish Department designated blue-ribbon fishery that attracts anglers regionally and nationally each year, generating millions of dollars of fishing and other recreation-based economic benefits each year for local communities. In addition, I urge FERC to work with federal, state, and local agencies, particularly the Wyoming Game and Fish Department, per the Federal Power Act, section 10(j), to develop and apply permit conditions to protect this unique resource.  

The proposed project’s use of Seminoe Reservoir in an open-loop system could alter water temperatures, degrade water quality, and increase sediment resuspension, harming trout populations and the broader North Platte River ecosystem. Construction and operation impacts could also damage habitat critical to populations of bighorn sheep, mule deer, sage grouse, and other terrestrial species. These impacts must be adequately understood and addressed before impacts occur, rather than relying primarily on adaptive management and mitigation to address them after the damage has been done.  

I urge FERC to complete a full Environmental Impact Statement (EIS) and apply stringent permit conditions to ensure that decision-makers proactively assess and mitigate any potential environmental impacts. If FERC or other agencies determine that more time is needed for this part of the permitting process, I ask that you extend the timeline as needed. It is critical to prioritize the long-term health of Wyoming’s fish, wildlife and outdoor economy by requiring a full environmental review of the Seminoe Pumped Storage Project to ensure that this regional renewable energy storage project is not hastily advanced at the expense of Wyoming’s irreplaceable natural resources and the communities and economies that depend on them.  

Sincerely,
[Your Name]
[Your Address]
[Your Email] 

Background

General Background: 

• The Seminoe Pumped Storage project is a proposed “reservoir-based energy storage project” that is being touted as a “modern energy hub for Wyoming wind energy”, with an upper reservoir proposed to be built on Bureau of Land Management lands, and Seminoe Reservoir (Bureau of Reclamation facility) to be used as the system’s lower reservoir.  

• Pumped storage is essentially a “water battery” for renewable energy, in which water is pumped into an upper reservoir during times of low energy demand, then released through power-generating turbines during times of high energy demand. Pumped storage does not result in any net new energy generation, but contributes to the stability and consistency of the energy grid.  

• The project is being proposed by the project developer, rPlus Hydro (a Utah LLC), as an open-loop system. Open-loop systems such as the one proposed for Seminoe are capable of releasing significant quantities of water between reservoirs multiple times a day, altering the temperature stratification of the lower reservoir and increasing turbidity. Closed-loop systems have been studied by the Pacific Northwest National Laboratory to generally have lower environmental impacts than open-loop projects. 

• This is a large, 900+ megawatt project that according to the project developer, rPlus Hydro, is poised to support the export Wyoming wind energy to regional out-of-state markets such as Colorado, California, etc. It proposes to cycle approximately 10,800 acre-feet of water between its upper reservoir site (to be built) and lower reservoir site (Seminoe Reservoir) multiple times per day. 

• The project is sited in Carbon County at the lower end of Seminoe Reservoir, right above Kortes Reservoir and the Miracle Mile. Therefore, TU and agency partners have concerns about the potential impact to the world-class, blue-ribbon fishery in the North Platte that generates millions of dollars of fishing and other recreation-based economic impact each year.  

• Other concerns brought forward by federal, state, and local agencies, nonprofit organizations, and the public during the Federal Energy Regulatory Commission (FERC) scoping process include: long-term effects on water quality; entrainment of fish in Seminoe Reservoir; sport and ice fishing impacts in Seminoe Reservoir; premature dam failure; emergency spillway design inadequacies; North Platte system water rights; wetland loss; impacts to mule deer, bighorn sheep and sage grouse habitat; long-term impacts to recreation including fishing and hunting; construction-related impacts; and socioeconomic impacts to surrounding communities. Please see TU’s Seminoe Pumped Storage Public Information Meeting slides for a summary list of scoping comments, and see FERC’s Scoping Document 2 for a detailed list of scoping comments and FERC’s responses. 
  • Seminoe Pumped Storage Public Informational Meeting
  • FERC response to comments – Scoping Doc 2 (1)

• The project is undergoing a complex permitting process involving review by multiple state, federal, and local agencies. Some elements of the permitting process are being fast-tracked. FERC is the lead agency for the National Environmental Policy Act (NEPA) process. There is an upcoming deadline this Friday, March 14th, 2025 for public comment to FERC as well as for federal and state agencies to provide recommendations, terms, and conditions. Recent requests to extend the comment period by several local and federal agencies have been denied by FERC. FERC will be considering whether to evaluate the project using an Environmental Assessment (EA, abbreviated review and opportunity for public participation) or Environmental Impact Statement (EIS, more review, analysis, and opportunity for public participation), as well as evaluating agency recommendations to attach conditions to their permit, based on these comments. 

• A full Environmental Impact Statement analyzing potential alternatives, associated natural resource concerns, and economic impacts would potentially allow for informed decisions to be made about the project by land and resource managers. It is also important that agency concerns are adequately addressed through the FERC permitting process, including requests for more studies based on data collected specifically for the project rather than a reliance on modeling alone.  

Key Concerns and Findings 

Fisheries & Water Quality 

• The project developer has sponsored several water quality modeling studies. These studies, based on a 4-year period (2013-2016) claim that there will be relatively minimal impacts to water quality, including temperature, dissolved oxygen, and other parameters, even though the continuous flow of large quantities of water in and out of Seminoe Reservoir is likely to alter the thermal stratification of the reservoir, impacting the tailwater fishery of the Miracle Mile. The Wyoming Department of Environmental Quality appears to be satisfied with the results of these studies. However, the Wyoming Game and Fish Department interprets these studies to show temperatures beyond the allowable threshold for Class 1 waters with coldwater fisheries are possible under multiple scenarios at the Kortes Reservoir outflow.   

• The Wyoming Game & Fish Department (WGFD) has therefore raised concerns over the water quality and fisheries studies, flagging temperature increases over the allowable amount, reliance on modeling rather than actual habitat distribution data for fish, and results that only address the very upstream part of the Miracle Mile at the outflow of Kortes Dam (rather than down the entire Miracle Mile to Pathfinder Reservoir). Increased turbidity and sediment resuspension could also degrade critical fish habitat in the Miracle Mile, and entrainment of walleye in Seminoe Reservoir at high levels is possible. Lower wintertime temperatures in the Miracle Mile are also possible. Requests for additional fisheries studies have been dismissed by the project developer and the permitting agency (FERC). 

• According to the project developer’s water quality studies, water quality concerns are heightened in drought years. Coupled with lower water availability during July and August and corresponding high air temperatures, this could amplify negative effects on fisheries and aquatic habitats, particularly in the Miracle Mile.  

Wildlife, Recreation, and Local Economy 

• The proposed project threatens the Ferris-Seminoe bighorn sheep herd, Wyoming’s only viable source for future bighorn reintroductions, by disrupting crucial habitat, increasing disease risk from dust exposure during construction, and impacting hunting in this highly coveted area. Bighorn sheep have been identified as a Species of Greatest Conservation Need (SGCN) by the Wyoming Game and Fish Department (WGFD) 

• Habitat for the Shirley Mountain and Ferris Mountain mule deer herds and Medicine Bow pronghorn herd may also be impacted by project construction.  

• The project’s proposed upper reservoir site as well as a transmission line crosses designated sage-grouse management areas, raising concerns about habitat fragmentation. 

• Wyoming State Parks has raised recreational impact concerns, including: 

• Five years of construction-related traffic disruptions and closures. 

• Fluctuating water levels affecting boating access and safety, as well as ice formation important to ice fishing. 

• Potential long-term impacts on visual resources and permanent recreational infrastructure. 

• The economic impact study only models construction-related impacts to Carbon County, WY where the project is located and touts the benefits of 300-500 full-time construction jobs and associated indirect spending during the 5-year construction period. After construction, limited job creation (18-24 jobs) for the project is expected. Long-term economic impacts resulting from the impairment of the Miracle Mile fishery including guiding and outfitting jobs, associated indirect spending, and tourism and recreation-based spending from the general public, including from Natrona, Albany, Fremont and Sweetwater Counties, and the Front Range of Colorado, have not been modeled.  

• =Safety concerns have been raised, including the potential for premature dam failure at Seminoe Reservoir as well as questions about the design of and impacts from the overflow spillway from the upper reservoir into Kortes Reservoir. 

Regulatory & Environmental Review 

• FERC is the lead agency, with the Bureau of Land Management (BLM)and the Bureau of Reclamation (BOR) serving as key commenting agencies. 

• The Clean Water Act’s US Army Corps of Engineer’s Section 404 permit process is being fast-tracked under an Emergency Energy Executive Order, raising concerns about whether environmental safeguards will be fully considered. 

• A full Environmental Impact Statement (EIS) would help to ensure a transparent review process and that all public and agency concerns are adequately addressed. 

• Under the Federal Power Act, section 10(j), each FERC license needs to include conditions for fish and wildlife protection based on recommendations from State fish and wildlife agencies, in this case the Wyoming Game and Fish Department, as well as the US Fish and Wildlife Service.  

• The project developer has recently submitted an accompanying Wyoming Department of Environmental Quality (DEQ) 401 Water Quality Certification Request Form. In its request, even though the project discharges into the lower end of Seminoe Reservoir, directly in Kortes Reservoir, then directly into the Miracle Mile, a Class 1 water, the developer states that the project “does not discharge into a Class 1 water, therefore a demonstration of how the proposed discharge will maintain existing water quality is not required.”  The developer also proposes a water quality adaptive management plan with 3 tiers that reviews temperature exceedances at the end of the season, after potentially negative impacts have already occurred, and considers other factors for elevated temperatures that could be interpreted to allow the project developer to not take responsibility for these impacts. Proposed “appropriate mitigation measures” are not explained in detail, but “may include stream restoration or aquatic habitat enhancement” identified in consultation with DEQ. The timeline between identifying and proving that there is an issue, then seeking to address them through mitigation projects, is therefore likely to take several years, and it is unclear if mitigation projects will be able to satisfactorily address these issues. Other parameters such as dissolved oxygen and sediment have not been included in the adaptive management plan.