Environmental Impacts of Closed-Loop Pumped Storage Hydropower

Abstract

The goal of this report is to help license applicants, resource agencies, and other members of the hydropower community involved in closed-loop pumped storage hydropower permitting and licensing process, focus the scope of environmental reviews, and more quickly identify impacts with project nexus and potential mitigation measures for these impacts. Pumped storage hydropower (PSH) is an energy storage technology that uses energy to pump water up from a lower reservoir to an upper reservoir where water is stored until electricity is needed and the water is released to a lower reservoir passing through turbines. Closed-loop PSH—PSH that is not continuously connected to a naturally flowing water feature—is one of the lowest greenhouse gas emitting energy storage technologies and is therefore a critical part of the transition to renewable energy (Simon et al. 2023). Proposals for closed-loop PSH facilities in the United States currently account for more than 40% of original licenses and 99% of potential generation capacity in the Federal Energy Regulatory Commission (FERC) hydropower licensing pipeline (Johnson et al. 2023). While closed-loop PSH facilities can have lower environmental impacts than open-loop PSH facilities, no closed-loop facilities have been constructed in the United States to enable direct accounting of project impacts and efficacy of mitigations. Many proposals for closed-loop PSH submitted to FERC are abandoned early in the permitting and licensing process prior to license applications and environmental assessments, so there is little documentation describing potential project impacts and proposed mitigations. The newness of closed-loop PSH proposals in the United States may mean that tribal, federal, and state agencies with authorities for cultural and natural resources protection and management involved in the FERC licensing process may not have experience with closed-loop PSH regulation. Moreover, many proposed closed-loop PSH facilities are in areas that do not have high concentrations of conventional hydropower, so these agencies may also be unfamiliar with the FERC hydropower licensing process. The goal of this report is to help license applicants, resource agencies, and other members of the hydropower community focus the scope of environmental review for the closed-loop PSH development, licensing, and federal authorization process enabling quicker identification of potential impacts, mitigations, and situations where mitigation may not be possible. We found that environmental impacts of closed-loop PSH are highly site-specific, and generalizations about the types of environmental impacts across closed-loop PSH projects are difficult to make. Environmental impacts of closed-loop PSH are like those for open-loop PSH with a few exceptions including water sourcing, which can lead to delays and contention due to potential complexities with water rights, impacts to aquatic resources, and greenhouse gas emission potential. Cultural resource impacts were commonly reported in National Environmental Policy Act (NEPA) documents reviewed and discussed in interviews, but in many cases such impacts cannot be mitigated.