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Connecticut's United Voice for River Conservation

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River Alliance of CT Priority Topics > Hydropower 

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River Alliance of CT > Priority Topics > Hydropower > 

Sep 25, 2017

Comprehensive Energy Strategy (CES) Comments by Rivers Alliance and Others

In addition to our support of the comments we refer to in our submitted material below, Rivers Alliance of CT commends the extensive efforts reflected in the comments submitted by: CT League of Conservation Voters, Sierra Club, Clean Water ActionConnecticut College ArboretumThe Nature Conservancy in ConnecticutCouncil on Environmental Quality, and many, many individuals too numerous to mention here.  

All submitted comments can be found here.

Here is what we submitted: 

Rivers Alliance  of Connecticut writes in general support of the comments submitted jointly by Acadia Center, et al. [Acadia Center, Citizens Campaign for the Environment (“CCE”), Coalition for Community Solar Access (“CCSA”), Connecticut Fund for the Environment (“CFE”), Northeast Clean Energy Council (“NECEC”), Solar Energy Industries Association (“SEIA”), and Vote Solar].  We also second comments by Joel Gordes

The merger of energy-policy policy entities with the Department of Environmental Protection to for  the Department of Energy and Environmental Protection (DEEP) created the potential for a forceful, integrated state program maximizing the development of high-quality clean energy.   That potential has yet to be realized.  I recently was driving on state roads in Massachusetts, where numerous solar arrays are situated roadside.  I return to Connecticut to hear community complaints about a solar array planned for the middle of a forest.  Why can’t we have more solar arrays in medians and roadsides, and fewer proposals for arrays in farmland and forest?

Community solar is a popular concept with the public (which by and large evinces a strong desire for more clean energy).  Why is progress so slow?  Why does the new strategy limit support for residents who wish to install solar or other clean power infrastructure, when the funding comes from residential customers themselves?   

The comments of the environmental coalition (Acadia et al) and Joel Gordes point to several of problems with state procurement efforts that appear to stem from an unwillingness to downgrade support for megaprojects as opposed to  smaller, decentralized projects.  The economic arguments in favor of this inclination may be at least partially flawed.  The security arguments in favor of decentralization put forward by Joes Gordes also  appear increasingly valid with each new report of national and international cyberattacks, to say nothing of devastating weather events. 

Connecticut has an ambivalent or at least unclear attitude toward monopolies.  A new one is being created today with the proposed merger of Eversource with Aquarion Water.   We ask DEEP to reexamine the incentives in the Comprehensive Energy Strategy and to clarify the structure it believes is best suited to bringing our vital utilities into line with the new and urgent needs of our time. 

We do appreciate the work done by DEEP on energy strategy.  But, yes, we are asking the agency to do more. 

Respectfully,   Margaret Miner, Exec. Dir., Rivers Alliance of Connecticut 

Hydropower: Policy Position of Rivers Alliance


By Margaret Miner

We get many questions about our position on proposals to develop or import more hydropower. This is especially true in a year like 2013, when the governor, DEEP, and legislators were putting forward energy bills that included major roles for hydropower. 

Our basic position is that we support "good," that is, low-impact hydropower. The typical characteristics of good hydropower are that it is run-of-river (water is not impounded and then released only when convenient); that it does not require a new dam; and that it provides passage for fish and eels. The ultimate goal is that a new or enhanced hydropower project should provide overall improvement in the health of the river.

These characteristics are to a considerable extent embodied in Connecticut's definition of Class I hydropower. In Connecticut, all electric utilities are required to have in their energy portfolios a certain percent of Class I energy sources, such as solar and wind. The goal has been 20 percent by 2020. In other words, by 2020, 20 percent of a utility's portfolio should be Class I energy.

Connecticut's definition of Class I hydro includes the good characteristics mentioned above. In particular, this year, with the help of Paul Mounds in the governor's office, Jessie Stratton at DEEP, and Andrew Fisk at the Connecticut River Watershed Council, we achieved a marked improvement in the definition of Class I with respect to fish passage. But unfortunately, in a holdover from the original definition a decade ago, Class I hydropower is supposed to be small and new. Small is under 5 megawatts (mw) and new is post-July 2003. This makes little ecological sense. All things being equal, it is better to have one well-designed hydro plant producing 20 mw, than four dams producing perhaps only 4 mw - or even less. 

The nature of a river is continuity - in biochemistry, physical flow, aquatic life, the birds, amphibians, and mammals that depend on the river for survival. Each natural change flows into another.

Rivers are the arteries of the world. Dams are high-risk tourniquets. Even a small dam can cut off that continuous life and degrade water quality (especially by warming the water and promoting harmful algae blooms and dead zones).

One of the surest ways to compensate for hydropower development by improving overall river health is to trade off removal of one or two existing dams for the hydropower on a third. This is feasible in many locations. There are 5,000 dams on Connecticut waterways. It is difficult to make an argument for building more. Nevertheless, a number of corporations, municipalities, and ordinary people who own riverside property, yearn for their very own new dams and hydropower facilities, and have proposals pending.  

The Rivers Alliance view is that all hydropower in our state should eventually meet Class I standards, and certainly any new hydro should do so. 

For this reason, we strongly opposed legislation this year that allows in some circumstances the sale of destructive Class II hydropower as if it were Class I in order to help utilities fill their Class I requirements. We have not opposed the incredibly massive hydropower facilities in Canada (although we think Canada will eventually regret them). We do not oppose increased importation of Class II hydropower from Canada. But we are extremely concerned about representing massively destructive hydropower as environmentally benign Class I energy.

Why do we care about lawmakers approving an apparently small stretching of the rules on behalf of Hydro Quebec? It is because we are certain that lawmakers and other officials will not be able to resist pleas and pressure to stretch those rules for Connecticut interests on Connecticut rivers. Why should only Canada be allowed to sell Class II hydro in the Class I market? Why shouldn't Connecticut companies be allowed to do so? It's hard to say why not. Therefore, we believe that to protect Connecticut rivers, we need to maintain high standards for what counts as Class I hydropower that can be used to fill the Class I portfolio requirements. 

The bottom line is: We support low-impact hydropower. We oppose any additional destructive hydropower on Connecticut rivers. 

Also, we'd be happy to answer questions and receive comments on the issue.