From: Patricia Moran-Queenan <pmqueenan@gmail.com>
Sent: Sunday, June 2, 2019 6:24 PM
To: RPS, DOER (ENE)
Subject: Public comment for proposed hydropower regulations
Dear Mr. Wassam,
My
name is Pat Moran-Queenan and I am from Bedford, Massachusetts. I am emailing
in regard to the proposed updates to the Department of Energy Resources (DOER)
RPS Class I and RPS Class II regulations.
I urge DOER to remove the
proposed addition in eligibility criteria for hydropower under Class I in 225
CMR 14.05 (1)(a)(6), new paragraph h, that reads as follows, “A Generation Unit
that has received a certification from LIHI and a Statement of Qualification
from the Department shall not be required to obtain a recertification from LIHI
in order to retain its Statement of Qualification.
Removing
a requirement for recertification from the Low Impact Hydropower Institute
(LIHI) would effectively undermine a hydropower operator’s motivation to
improve their systems and minimize their environmental impact over time on
rivers. A qualified project would effectively receive a lifetime
qualification regardless of any environmental changes or technological advances
that would prompt updated conditions to protect rivers.
A
LIHI certification requires a hydropower facility to meet rigorous standards
for streamflow, water quality, fish passage and protection, watershed
protection, threatened and endangered species protection, cultural resource
protection, and recreation. It’s important to me that we maintain LIHI annual
compliance reviews and recertifications every 5-10 years to allow for updated
assessments of changing environmental conditions as well as stakeholder and
agency. Nearly 65% of projects that recertify contain updated conditions that
are new or different from a previous certification. Upgrades have included
improved fish and eel passage requirements, which are important for the health
of rivers.
Please remove this new paragraph in the proposed regulations and maintain the original language. The recertification requirement has made a big difference in reducing hydropower impacts on rivers - let’s maintain that for the future.
Thank you for your time and consideration.
Sincerely,
Pat Moran-Queenan
Bedford, MA