The Miracle Mile and Trout: Let’s not experiment on a blue-ribbon trout fishery

Below you may find some helpful recommendations or issues we have discovered as we have studied rPlus permit with FERC

Big Picture

● This renewable energy storage project is being fast-tracked for

development by a Utah-based developer at the expense of Wyoming’s

world-class wildlife and fisheries.

○ Responsible energy development is worth supporting- this project is far from responsible. rPlus’ project trades away our blue-ribbon fishery, a distinctive bighorn herd, and sage grouse country for an out-of-state, private developer’s grid stability project.

● The DEIS admits there are unavoidable harms and incorrectly claims

that the economic and energy infrastructure benefits are worth it.

○ FERC’s own analysis admits this project would cause serious, potentially permanent harm to our water, fisheries, wildlife, and hunting and fishing opportunities. Then the project moves forward anyways, deciding those impacts are a fair trade-off, relying on a flawed cost-benefit analysis that puts the developer’s profits ahead of our community, environment, and local economies.

● Wyoming’s unparalleled natural resources deserve a more responsibly developed project.

○ rPlus has selected an open-looped system that utilizes the North Platte river system as its lower reservoir. This is a high-impact design. The majority of rPlus’ projects in other states are closed-loop systems, which is a lower-impact design. Closed-loop systems have fewer effects on waterways and fish. A private developer’s financial viability should not be driving the decision to place the North Platte river system and surrounding wildlife habitat at risk, especially when there are alternatives.

The Miracle Mile and Trout

Let’s not experiment on a blue-ribbon trout fishery - The Miracle Mile is recognized as a high-value, “Class 1,” Blue Ribbon Tailwater.

○ State and federal agencies agree this is one of Wyoming’s signature

coldwater fisheries. It is a cherished stretch of river for the communities of

Casper, Rawlins, and beyond. This should be the last place we gamble on

new mixing, warming, and sediment dynamics.

● The DEIS and Adaptive Management Plan admit the project can push

temperatures into the stress zone.

○ rPlus’ own modeling shows that under low reservoir levels and/or maximum operations, the project will cause temperatures in the Miracle

Mile to exceed the state’s thermal stress threshold for coldwater fish

multiple days per year. With warmer temperatures and drought expected to increase in frequency in the future, operating in the stress zone will become more frequent.

● “Not lethal” is the wrong standard.

○ The DEIS leans on the phrase, “not expected to cause fish death.” Anglers and biologists know that repeated sub-lethal stress, warmer water, and more days near 68°F, means poorer growth, lower reproductive success, more disease, and higher angling mortality. You don’t need a fish kill to lose a fishery.

● The modeling window is too narrow to understand the impacts of low water, drought, and a warming climate.

○ The core hydrologic modeling is based on just a few recent years (2013-

2016). It does not include the lowest reservoir levels that Reclamation has

observed, and doesn’t model the far warmer, drier conditions the DEIS itself projects for this region’s future (water temperatures follow air

temperatures). It also doesn’t extend down the full length of the Miracle Mile.

● rPlus is building the project first, and promising to “adjust later”

○ The water quality Adaptive Management Plan is essentially: “We’ll monitor,

and if the river gets too warm and it can be absolutely proven to be directly

related to operations, we’ll consider curtailing operations by 10-20%.” That’s backwards. In a Class 1, Blue Ribbon fishery, it is paramount to design and test hard protections before the concrete is poured. Furthermore, their mitigation and management plan is self-regulating, as opposed to having an independent third party call for a decrease in operations or full shutdown.

Recommendations to be made to FERC

● Demand independent, enforceable temperature triggers that force curtailment and/or full shutdown of the pumps when Miracle Mile temperatures approach 68°F.

● The adaptive management plan should be monitored by an independent

agency or 3rd party, not the project developer, as currently proposed.

Furthermore, water temperature should be reported daily, should activate operational changes immediately, and all data should be publicly accessible in real time.

● Push for more monitoring sites. There is currently only one monitoring gauge planned below Kortes. This one gauge does not cover the full geographic scope that FERC defined during the scoping period – the approximately 27-mile stretch of the North Platte from the upstream reach of Seminoe to Pathfinder Dam.

● Call for updated modeling that includes all observed lower reservoir levels

and modelled future climate scenarios before any license is granted.

Bighorn Sheep

Population-level impacts on a critical Wyoming herd.

● This project will have population-level impacts on the Ferris-Seminoe

Bighorn Sheep Herd, which is currently the healthiest herd in Wyoming.

○ This is the only herd in Wyoming that has not tested positive for the

devastating respiratory pathogen, Mycoplasma Ovipneumoniae (M.Ovi), making it the only viable population. The health of this herd affects the health of all bighorn sheep in the state.

● The project sits squarely in crucial bighorn sheep winter range and parturition habitat.

○ The DEIS acknowledges that “project construction effects on bighorn crucial winter range could be significant, reducing winter survival, recruitment, and population sizes.”

● The Rawlins Resource Management Plan (RMP) was written to protect exactly this kind of habitat.

○ BLM’s plan restricts surface-disturbing activities during winter and lambing periods. rPlus is asking for multi-year exceptions because following those protections would make the project financially “infeasible.”

● They are literally asking to rewrite the rules around a sensitive herd to make the project pencil out

○ The BLM has already said the project is inconsistent with the Rawlins RMP and would require an amendment. That’s not a small tweak, that’s changing the rulebook in favor of rPlus. This also sets the precedent for large developers for years to come- if the rules do not work in their favor, developers can simply change them. The public is being asked to accept long-term impacts to an at-risk bighorn herd so rPlus can maintain their construction schedule and profit margin. That tradeoff should be unacceptable. Recommendations to be made to FERC

● Insist that Rawlins RMP bighorn timing stipulations stay in place—no

exceptions. The developer must follow the rules just like everyone else

● Point out that there are no mitigation measures that could fix the issues

this project would create for this herd if the timing stipulations are not adhered

to. The Wyoming Game and Fish Director is quoted as stating on 11/05/25, “There will be impacts to sage-grouse, and mule deer- I believe we can mitigate for those. However, there will also be impacts to the local bighorn sheep population, which I don’t believe we can sufficiently mitigate impacts for those sheep as well as the fisheries in the Miracle Mile. I don’t think we can come up with a mitigation proposal that would be sufficient in that case.”

Sage-Grouse and Other Wildlife

Stacking Impacts in an already-stressed landscape

● The upper reservoir and transmission lines cut through critical sage-

grouse and big game habitat.

○ The DEIS acknowledges sage grouse lek and seasonal habitat overlap with crucial winter range for mule deer and pronghorn. This overlap triggers protections in the Rawlins RMP that the project cannot meet without significant waivers, underscoring the incompatibility of the chosen site. Again, the solution in the DEIS is to bend the Rawlins RMP to fit the project, not the other way around. Full adherence to sage-grouse and big game seasonal protections and executive orders is described as making the project “infeasible,” so the agency leans towards weakening protections instead of reconsidering siting.

● Additional traffic, dust, noise, lighting, and the effects are a permanent

industrial footprint in what’s now a relatively intact wildlife habitat and

will create cumulative impacts.

○ Layered on top of existing stressors, drought, invasive species pressure,

warming temperatures, and regional development, these disturbances push a once-stable habitat complex toward a tipping point that the DEIS does not highlight within its cumulative effects analysis.

Recommendations to be made to FERC

● Require all stipulations of the Wyoming Sage Grouse Executive Order

2019-03 are followed without exception.

● Insist that Rawlins RMP Sage-Grouse stipulations stay in place—no

exceptions. The developer must follow the rules just like everyone else.

● Demand strict lek buffers and seasonal timing limits for construction and line work, even if that slows the project.

Recreation and Local Economies

117,134 Lost Visits Is Not a Rounding Error

● The DEIS estimates 117,134 lost recreation visits during the 5-year construction period.

○ That includes anglers, hunters, campers, and boaters at Seminoe, Kortes,

and the Miracle Mile. Those aren’t abstract numbers; that’s five years of

ruined trips, blown hunting seasons, lost guide days, and hundreds of

thousands of dollars in lost revenue to the State of Wyoming.

● Permanent industrial footprint impacts recreation long after construction ends.

○ The new bridge, roads, upper reservoir, spoil areas, and transmission

corridors will leave lasting structures and increased traffic that reduce

access and diminish the quiet, high-quality hunting and fishing experiences that have defined the Seminoe–Miracle Mile area.

● The DEIS admits the Miracle Mile fishery will take a hit.

● The DEIS only models economic loss in Carbon County, but the fishing economy for the Miracle Mile spreads across Natrona, Carbon, Albany, Fremont, Sweetwater, the Colorado Front Range, and beyond.

○ Guides, lodging, gas, restaurants – many of these are small businesses and locally owned. How the 5-year construction period will affect these businesses is not captured in the developer’s socioeconomic report.

● The DEIS makes clear that hunting in the Seminoe–Miracle Mile area will

take a major hit during construction.

○ Key access routes near the upper reservoir and Kortes Reservoir will face restrictions, and the DEIS notes heavy truck traffic - around 79 trips a day on one stretch alone - plus noise and dust that will push big game out of the area. For hunters, this means fewer animals on the landscape and lower-quality seasons for years.

● The DEIS overlooks serious safety risks for ice anglers.

○ Rapid water-level changes can create hidden voids beneath the ice, and simply noting that winter use is lower doesn’t make those risks go away. Ice fishing safety needs real analysis, not dismissal.

● Walleye mortality will exceed the annual catch rate by 4 times.

○ Walleye deaths associated with impingement and entrainment in the inflow/outflow structure were modelled in rPlus’ fisheries report leading to

staggering conclusions. Hydro study estimates 24,000 walleye will be killed every year.

● The DEIS does not model potential long-term economic loss from

degradation of the Miracle Mile and Seminoe Reservoir fisheries and

fragmentation of critical big game habitats

Recommendations to be made to FERC

● This project provides temporary construction jobs, and poses a long-term risk to a permanent recreation economy. Once the fishery or the hunting quality is degraded, those dollars don’t come back.

● FERC should adopt enforceable measures that prevent long-term losses

to hunting and fishing opportunities. This includes maintaining wildlife

timing stipulations, protecting access during construction, and establishing binding operational limits that prevent temperature-driven declines in the Miracle Mile fishery. Without these requirements, the agency cannot ensure the project preserves the public’s long-standing hunting and angling use of the area.

Alternatives & Precedent

If We Accept This Here, We Accept It Anywhere

● Wyoming’s wildlife and citizens deserve to know the whole picture.

○ rPlus and FERC have repeatedly denied the requests of the Wyoming Game and FIsh Department as well other other agencies and affected parties for additional studies, modeling, and mitigation planning. Our waters, wildlife, and communities deserve this due diligence.

● The Rawlins Resource Management Plan includes seasonal protections

for wildlife that were put in place specifically to keep sensitive herds

and habitats healthy.

○ rPlus’ proposal to waive those protections would erode the very standards meant to safeguard bighorn sheep, sage-grouse, mule deer, and pronghorn and the habitat they depend on.

● Allowing this project to move forward by rewriting or weakening the RMP would set a dangerous precedent.

○ If renewable energy developers can bypass long-standing wildlife protections and reshape a land-use plan to fit an open-loop hydropower project in the heart of an iconic fishery and big-game stronghold, it opens the door for similar high-impact proposals across Wyoming’s most valued public lands. We will feel this for generations to come.