Pumped Storage Hydroelectric Facilities

The current inclusion of "hydroelectric generating facilities with a production capacity of 200 MW or more" in the Project List is too broad, in terms of encompassing pumped storage hydroelectric (PSH) projects that may have a production capacity of greater than 200 MW, but not have potential to cause adverse environmental effects in areas of federal jurisdiction.

For example, closed-loop PSH projects that involve the development of new "dryland" reservoirs (constructed on lands where no existing watercourse is present) do not have the potential for non-negligible adverse changes to fish and fish habitat, or aquatic species as defined in the Species at Risk Act, as might traditional hydroelectric generating facilities.

Accordingly, it is suggested that PSH projects be excepted from the "hydroelectric generation facilities..." provision in the Project List. An alternative approach would be to qualify the definition of "hydroelectric generating facilities" here by stipulating that such hydroelectric generating facilities must include works/scope that have the potential to have adverse environmental effects on areas of federal jurisdiction.