From: Stuart <stuartarm@aol.com>
Sent: Tuesday, May 21, 2019 9:02 PM
To: RPS, DOER (ENE)
Subject: Hydropower generator certification process
Dear
Mr. Wassam,
My name is Stuart Armstrong and
I am from Milton, 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 river systems.
A LIHI certification requires a
hydropower facility to meet rigorous standards for river flows, 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 river systems.
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,
Stuart
Armstrong
38
Ridge Road
Milton, MA 02186