From:                                         Matthew Hoagland <mhoagland1397@gmail.com>

Sent:                                           Friday, June 7, 2019 9:59 AM

To:                                               RPS, DOER (ENE)

Subject:                                     Draft Department of Energy Resources regulations to amend 225 CMR 14 and 225 CMR 15

 

June 7, 2019,

Commissioner Judith Judson

Department of Energy Resources

100 Cambridge Street

Boston, MA 02114

Re: Draft Department of Energy Resources regulations to amend 225 CMR 14 and 225 CMR 15

Dear Commissioner Judson,

Citizens of the Commonwealth of Massachusetts depend upon the various state agencies to protect natural resources while allowing for economic growth. The DOER proposal to remove the requirement that generators obtain a recertification from the Low Impact Hydropower Institute (LIHI) in order to retain their status as a Renewable Portfolio Standard (RPS) eligible facility is, at best, misguided.  Now is not the time to relax recertification requirements. Rather, now is the time to pay closer attention to the impacts of hydropower on our rivers and streams.

Climate change is a driver behind both the need for renewable energy and changing conditions of rivers and streams.  Massachusetts, as a national leader with respect to encouraging innovation, should seize the opportunity to understand and regulate technologies to best adapt to these changing conditions.  Instead of unloading the critical government function of recertification, consider streamlining the same periodic process by encouraging the use of innovative monitoring technologies to access streamflows, water quality, habitat quality and recreational uses, etc.

We can’t predict all of the impacts of climate change. It  By abdicating its responsibility to recertify hydropower facilities the Commonwealth risks harming the environment for no economic gain while making itself powerless to correct problems when they arise. And problems will arise as our climate changes... the unintended consequences could be significant.

Respectfully,

 

Matthew R. Hoagland

Vice President, Southeastern Massachusetts Chapter of Trout Unlimited