From: Robert Kearns <robsterkmc@gmail.com>
Sent: Tuesday, May 28, 2019 3:15 PM
To: RPS, DOER (ENE)
Dear Mr. Wassam,
My name is Robert Kearns and I am from Braintree, 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.
As a resident, I like to fish recreationally as well as observe migratory fish
runs. I recently also purchased a kayak and go paddling recreationally. The
standards of review and recertification are a good thing for residents like
myself and visitors alike to Massachusetts.
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.