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RRFW Riverwire – Two Permits, Four Dams, and Trouble for the LCR

Updated October 1, 2019

A start-up company based out of Phoenix, Arizona, had no idea how contentious things would get when they filed two permits with the Federal Energy Regulatory Commission (FERC) this spring to build four dams in the Little Colorado River Gorge on Navajo Nation land adjacent to Grand Canyon National Park.

The permit applications are part of a nationwide rush of permit filings for what is known as pumped storage hydroelectricity. Only in this case, the permits are not only contentious, but they face serious design challenges as well.

The concept is simple. During a 24-hour day, the price of electricity fluctuates with demand. If a landscape can accommodate two dam sites within a few miles of each other and the dam locations have a large enough elevation difference between them, the location has pumped storage potential and a permit is filed with the FERC.

At the Little Colorado River Gorge, the Phoenix company decided to file two permits for back to back pump storage facilities in a stairstep. The upstream pair of dams, one low and one high, would be located just upstream of the next pair of dams. one low and one high. Two giant reservoirs would be built up on the rim of the gorge and two reservoirs back to back would flood the gorge below.

The result required two permits to build four dams and resulted in a whole mess of trouble.

It turns out the Phoenix based company that filed the permits did not check with anyone at the Cameron Chapter of the Navajo Nation, including the Chapter’s elected officials. No other western Navajo chapters were consulted either. Though the Navajo Nation at Window Rock was notified of the projects, no decision one way or another was forthcoming from Navajo Nation officials.

Another oversight in the dam plans was that the downstream dam in the bottom of the gorge would completely flood a location held most sacred to the Hopi Nation known as the Sipapu. Think of it as the Hopi Nation’s Notre Dame, a place of pilgrimage visited by the Hopi for thousands of years. The Hopi and Navajo nations have a legally binding agreement not to adversely impact each other’s sacred sites.

Besides the sacred, the location itself is fraught with engineering challenges. The two dams on the rim would be located on Kaibab Limestone, a rock known for its ability to leak water. Hence, the two high reservoirs would need to be lined to hold their precious water.

Meanwhile, the two dams down in the gorge would face their own unique problems. One being travertine. The Little Colorado River Gorge is known for its travertine dams, formed by one of the largest natural springs in all of Northern Arizona. Over a thousand gallons of water every minute discharges into the Little Colorado River, water that is high in dissolved minerals. These minerals coat the natural rock, and would coat the proposed dams, headgates, pumps and turbines as well.

Another problem dam-builders would face is faulting. The area chosen for the two high and two low dams is faulted with natural fracturing in the area. Faults are pathways for water to travel. It’s why that large natural spring is where it is.

And then there are the floods. The Little Colorado River drains an area over 26,000 square miles, bigger than the entire state of West Virginia. Dry most of the year just above Blue Springs, the Little Colorado River gorge can experience flooding close to 100,000 cubic feet per second. That water is not clear but contains large quantities of dirt which the two dams in the bottom of the gorge would need to deal with.

The Federal Energy Regulatory Commission permit process has two main steps, the application followed by an in-depth permit review. This part of the permitting process can take up to three years. The preliminary permit review period is where studies of the impacts of the proposed project are made. It is followed by a formal license application, where FERC decides what conditions (based on the studies done during the preliminary permit process) will be imposed on the project's construction and operation.

The good news is the public gets to comment. Twice, once for each of the two permits. The public is encouraged to comment, and additional comments can be filed later in the sixty-day commenting period as new information is learned.

Issues the public might want to mention include adverse impacts to the Navajo, Hopi and other Pueblo nations, siltation issues at the lower dams, porous issues at the high dam locations, faulting at all the dam locations, impacts to downstream resources like Grand Canyon National Park including native fish like the Humpback Chub, and impacts from travertine that would form on the mechanical structures of the two dams.

River Runners For Wilderness will continue to work on talking points and encourages anyone interested in this issue to start commenting. Additional comments may be sent to FERC at any time before the November deadlines. Here are the two links on where to comment. You are encouraged to comment on both permits.

https://www.federalregister.gov/documents/2019/09/23/2019-20503/pumped-hydro-storage-llc-notice-of-preliminary-permit-application-accepted-for-filing-and-soliciting

https://www.federalregister.gov/documents/2019/09/23/2019-20502/pumped-hydro-storage-llc-notice-of-preliminary-permit-application-accepted-for-filing-and-soliciting

Please share this far and wide, and let’s bury this project in comments.

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