April 29, 2009 - LIHI Releases Revised Criteria for Public Review
Public Comment Period Runs Through June 29, 2009
The LIHI Governing Board is pleased to anounce the release of revised criteria for the Low Impact Hydropower Certification Program. This release begins the public review and comment process. The Institute believes these proposed revisions provide important improvements to the Low Impact Hydropower Certification Program. We have provided a link to the revised criteria ( userfiles/file/LIHI%20Revised%20Criteria%20%204-29-09.pdf ) as well as a link to a memo from our consultant, Gabriela Goldfarb, that describes the changes to the criteria ( userfiles/file/Criteria%20Crosswalk%204-29-09.pdf )
Since its creation, the LIHI Governing Board has been committed to regular reviews of the program to ensure it is continuing to meet its goals and objectives. These reviews have all been subject to public comment, and during the period 2001-2007 have resulted in the following adjustments to the LIHI criteria and program:
1. Extend the term of certification from two to five years.
2. Formalize a free, confidential pre-application consultation to help prospective applicants understand the potential for certification of the Facility.
3. Extend the program to “new”hydropower capacity at an existing hydropower structure.
4. Extend the program to “new” hydropower added to non-hydropower dams or other structures so long as the existing dam had not been considered for removal.
5. Revise the Watershed Protection criteria to include three extra years of certification for projects with adequate buffer zones.
6. Allow for pre-operation certification of certain "new" facilities (not new dam construction) if they had at least been authorized if not constructed.
7. Make the certification date for all future certifications retroactive to the date the application was filed (once a certification decision reached) to offer the ability for project owners to obtain payment for the period it takes to get through certification.
8. Introduce an annual fee and simplify the re-certification process and fees.
Certification holders express great satisfaction with the program. Some have reported significantly increased prices for certified power, especially in the contracts with institutions seeking affordable renewable power. Every project where the certification approached expiration has sought and received recertification. The first re-certification occurred in 2006, and as of March 1, 2009 we have re-certified ten projects.
Starting in late 2007, the Governing Board initiated a complete program review. A Criteria Task Force was formed and charged with revising the existing criteria. This group met regularly throughout 2008 and into early 2009 and produced the document described in the first paragraph.
In revising the criteria, the Task Force looked for ways to raise the bar on environmental performance while simultaneously increasing the value of LIHI certification for our current and future certificate holders. We also looked for ways to simplify our current criteria. The Task Force considered a number of policy questions, including recent changes in energy markets, new renewable energy policies, changes in the way that hydropower is regulated, and climate change. We also wrestled with tough fundamental questions about our criteria. Have our goals changed since the 1990s? Does it still make sense to rely on process-based criteria? In the end, the Task Force and the LIHI board felt that the basic framework and assumptions – relying on agency recommendations, for instance – that underpin LIHI’s criteria are strong, and have contributed greatly to the organization’s success over the years. Accordingly, these new draft criteria represent an incremental change rather than a seismic shift.
From the perspective of our Task Force and Board, the most important step in this criteria review is your feedback; it is critical that these criteria have the support of the industry, the environmental community, and the state and Federal resource agencies that participate in the regulation of hydropower. The Institute strongly encourages your comments and suggestions concerning these proposed revisions, and also welcomes any additional thoughts or suggestions you may have about the program. We will accept comments for sixty days, i.e., until close of business on Monday, June 29, 2009. Comments may be submitted by e-mail (preferred) to info@lowimpacthydro.org with “Criteria Comments” in the subject line, or you may submit comments by mail (34 Providence Street, Portland, Maine 04103) or fax at 206-984-3086. Once the public comment closes on June 29, 2009, (when this was posted last week the date for public comment closing was June 9, but should have been June 29, we apologize for this error) the Governing Board will review and evaluate comments, make revisions or edits as necessary, distribute a Final Draft to all commenters, and put the Final Draft on the LIHI website. The Governing Board anticipates that revisions to the criteria will be in place by September 1, 2009.
Finally, this year marks our tenth anniversary! Yes, the Low Impact Hydropower Institute (LIHI) has been in business since 1999. The Institute received its first application for certification in May of 2000. As of January 1, 2009, the Institute has certified 37 projects (103 dams) in 22 states from Maine to Alaska with a combined installed capacity of 2,136 MW. Through its Certification Program, the Institute serves a broad constituency with a variety of stakeholders including river advocates, electricity consumers, renewables advocates and “green” energy labeling groups, power marketers, and the hydropower industry. Looking back, I discovered that the work to create LIHI’s criteria, the backbone of our Low Impact Certification Program, began much earlier:
• In early 1997, Margaret Bowman, then Director of Hydropower Programs for American Rivers, and others, began to develop criteria that would enable hydropower projects to earn an endorsement as green or environmentally preferable power sources.
• After several rounds of criteria proposals, public and industry review, the program was set and in June, 1999, the Low Impact Hydropower Institute (LIHI) was incorporated as a non-profit public benefit corporation in the State of California.
• In 2000, the Island Park, Idaho project was the first project to apply for certification, but it was the Stagecoach Project, Colorado which was the first to gain LIHI certification in 2001.
Thank you for your continued support of the Low Impact Hydropower Institute. We look forward to hearing your thoughts and opinions on these proposed new criteria. If you have any questions, please call me207-773-8190 or John Seebach, the Chair of the Criteria Review Task Force at 202-243-7055.