8 January 2021
Sequoia ForestKeeper and Sierra Club, Western Watershed, and Basin & Range Watch submitted these comments concerning the Isabella Pumped Storage Project, FERC Project No. P-15035 (Isabella Project or proposed project). We strongly oppose the issuance of this preliminary permit. We have a number of concerns about the application by Premium Energy Holdings, LLC, particularly with regard to the potential impact of activities that could be granted under the preliminary permit on sensitive federal lands, which are eligible for inclusion in the National Wilderness Preservation System, and which are currently classified as Inventoried Roadless Areas, Wilderness Study Areas, and eligible Wild and Scenic Rivers. The proposed project would be located on public lands with highly sensitive resources managed by the U.S. Forest Service (Sequoia National Forest) and the Bureau of Land Management (BLM), state lands managed by the California Department of Fish and Wildlife, as well as lands owned by Non-Governmental Organizations and other private lands.
A new boondoggle proposal to build dams above Fay Canyon, Erskine Canyon, or Cane Canyon in Wofford Heights brings a new threat to the Kern River Valley. SFK created maps to show where the proposed dams would be located.

The proposed project would consist of the following:
(1) an upper reservoir created by a new dam at one of three alternative locations in the Southern Sierra Nevada Mountains with a capacity between 19,073 and 34,459 acre-feet.
(2) a tunnel system of steel penstocks and concrete pressurized tunnels to connect the upper and lower reservoirs to the powerhouse;
(3) pump-turbine units in an underground powerhouse with generation capacity of 2,000 megawatts located at one of the three alternative locations;
(4) a cavern of the transformers chamber adjacent to the powerhouse;
(5) the existing Isabella Reservoir, to be used as the lower reservoir, with a storage capacity of 568,000 acre-feet, at an elevation of 2,580 feet above mean sea level;
(6) electrical switchyards and interconnecting transmission lines from the powerhouse to the nearest major transmission interconnection at one of the six alternative locations; and
(7) appurtenant facilities. The estimated average annual generation of the Isabella Project would be 6,900 gigawatt-hours.
This document was published in the Federal Register on 11/16/2020 and available online at federalregister.gov/d/2020-25208, and on govinfo.gov

Comments are due on or before 8 January 2021 for Docket Number: P-15035-000 and Document Number: 2020-25208.
Commenters can submit brief comments up to 6,000 characters, without prior registration, using the eComment system form at:
You must include your name and contact information.
“Should it fail, please contact FERCOnLineSupport@ferc.gov (866-208-3676); we will work to resolve the problem as soon as possible.”
Project Maps and Links to documents
Premium Energy Holdings, LLC [Project No. 15035-000] Notice of Preliminary Permit Application Accepted for Filing and Soliciting Comments, Motions to Intervene, and Competing Applications 9 November 2020

 Fay Canyon Reservoir
Erskine Reservoir
Cane Reservoir