From: Aileen Torres <aileentorres221@gmail.com>
Sent: Wednesday, June 5, 2019 2:46 AM
To: RPS, DOER (ENE)
Subject: River Enviornmental Protection
Dear Mr. Wassam,
My name is Aileen Torres and I am from Lawrence, 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.
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.”
Why does Mass Rivers support the
Low Impact Hydropower Institute review process?
While Mass Rivers continues to be the lead advocate for dam
removal in the Commonwealth so that rivers and aquatic wildlife can be restored
to their optimal potential, it’s important to make sure that the dams that are
currently in place and may be more challenging to remove (i.e. dams used for
flood control or significant hydropower generation) are meeting the strongest
environmental standards possible. Poorly sited hydropower projects can
block fish passage, displace wildlife, significantly alter temperature and
makeup of the waterbody and create water diversions that can leave rivers
alternating between unnatural drought and flood-like conditions.
The Low Impact Hydropower Institute (LIHI), is a national
non-profit organization formed in 2000 by a coalition led by American Rivers
and Green Mountain Energy Company. The goal was to incentivize hydropower
facilities to reduce the environmental, recreational and historical impacts of
hydropower generation. LIHI offers the nation’s only independent certification
and verification program. Voluntary certification is accessible to any
existing hydropower, as well as new projects constructed on non-powered dams,
capable of meeting eight science-based criteria with specific goals designed to
protect water quality, ecological flows, upstream and downstream fish passage,
watershed systems, endangered species, cultural and historic resources and
recreational access.
Thank you for you time and consideration.