From: Sarah Hancock <sehancock1@yahoo.com>
Sent: Tuesday, May 21, 2019 10:09 PM
To: RPS, DOER (ENE)
Subject: Proposed updates to the Department of Energy Resources
(DOER) RPS Class I and RPS Class II regulations
Dear Mr. Wassam,
My name is Sarah Hancock and I am
from Boston, MA. 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,
Sarah Hancock