The Massachusetts Department of Energy Resources (DOER) has proposed new regulations for hydropower dams that would harm our rivers.
DOER is proposing that generators would have to undergo under just one review to receive a lifetime certification as a river-friendly facility. This certification would entitle them to a lifetime of benefits from the state as providers of environmentally sustainable energy. You can read more about why this is a bad idea in the sample email, below.
Please take a moment to send an email to DOER before June 7th to tell them that we need to maintain strong environmental standards for hydropower dams! Sample text can be copied and pasted below (text is between starred lines). Please submit your emails to John Wassam at DOER.RPS@mass.gov.
“Dear Mr. Wassam,
My name is _____________________ and I am from _________________. 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. Thank you for your time and consideration.”
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.