From: Paula Phipps <paula.c.phipps@gmail.com>
Sent: Friday, June 7, 2019 1:09 PM
To: RPS, DOER (ENE); Judge, Michael (ENE)
Subject: Proposed change in hydropower regulation
John Wassam,
DOER
My name is
Paula Phipps and I am writing from Biodiversity or a Livable Climate. We are
emailing in regard to the proposed updates to the Department of Energy
Resources (DOER) RPS Class I and RPS Class II regulations.
We 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,
Paula Phipps
Associate
Director
Biodiversity
for a Livable Climate
Check out Bio4Climate's Compendium of Scientific and Practical Findings Supporting Eco-Restoration to Address Global Warming, Vol 1 No 1 & 2, and Vol 2 No 1 & 2.