Dear Mr. Wassam,
My name is Jim Smith and I am from Brookline here in Massachusetts. 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.
I am very interested in knowing the name of the individual who formulated
this new language and how it came to be added the proposed regulations.
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. This is poor policy and a
poor idea. It is not in the best interests of the citizens of our commonwealth.
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 re-certifications 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.
Jim Smith
119 Crafts Road
Chestnut Hill, MA