From: Rui Coelho <rcoelho@gbtu.org>
Sent: Monday, May 20, 2019 1:47 PM
To: RPS, DOER (ENE)
Categories: Saved as HTML
Dear Mr. Wassam,
My name is Rui Coelho. I am from Belmont MA and the current president of the conservation organization Greater Boston TU, representing approximately 1000 area members.
I am emailing in regards 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.
Being certified by LIHI
means a hydropower facility must pass 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.”
Rui Coelho
President, GBTU
Belmont, MA
617-285-1665