From: John Goodman <goodmaj@gmail.com>
Sent: Wednesday, May 22, 2019 1:42 PM
To: RPS, DOER (ENE)
Subject: Update to RPS Class I and RPS Class II regulations.
Dear Mr. Wassam,
My name is John Goodman and I am from Belmont. 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.
Regards,
John Goodman