Certifying Hydropower as Low Impact

Certifying Hydropower as Low Impact

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Waterpower Week

With today’s focus on clean energy, the need to quantify the environmental impact of electricity generation is taking on new importance.

Electric power generators, including owners of hydroelectric assets, are seeing a growing demand from the public as well as from buyers of the electricity (i.e., offtakers) for greater transparency when it comes to environmental impact.

As such, asset owners are embracing ways to demonstrate the importance of environmental sustainability in the day-to-day operations of their projects. Demonstration tools include creating publicly available Environmental, Social, and Governance (ESG) and seeking certifications to demonstrate a project’s environmental stewardship.

According to Shannon Ames, executive director of the Low Impact Hydropower Institute (LIHI), offtakers (i.e., the buyers of the electricity produced by a project) are showing a growing interest in electricity that comes from “low impact” sources and are seeking out hydropower projects that have been certified as such.

Shannon Ames spoke with POWERHOUSE about the institute’s history, the make-up of the institute, the certified facilities, and the process of certification.

Farmers Irrigation District Project located on Hood River in Oregon. Owned by Farmers Irrigation District (LIHI Certified)

POWERHOUSE: What is Low Impact Hydropower Institute (LIHI)?

Shannon Ames: LIHI is a 501(c)(3) non-profit organization. We were founded in 1999. Our mission is to recognize and support hydropower that prioritizes environmental, recreation, historical, and cultural resource protection. We do this by defining and certifying “low impact” hydropower using rigorous science-based criteria and public input; providing education and outreach; and structuring our organization to integrate and evolve with community, conservation, and hydropower interests.

POWERHOUSE: Exactly how does the institute function?

Shannon Ames: We are not associated with a governmental entity of any kind, so we are independent. It’s a voluntary program, and our reviewers are also independent. An important part of the way we’re structured is that conservation groups have the primary voice, so 50% of our board is required to be people who have experience, either currently or in the past, in river or environmental conservation.

Our board is also hydropower oriented. We have several board members from national laboratories — two from Pacific Northwest National Laboratory (PNNL) and one from Oak Ridge National Laboratory (ORNL). They bring deep expertise in fisheries, climate, and water. We have two retired hydropower industry folks, and we also have a very robust industry advisory board.

The industry advisory board is really important to us because what we try to achieve is as aggressive and as strict of a definition of low impact as possible, while also being achievable by the industry. We want to find that line between being something not everybody could get, but also something that’s certainly achievable.

The industry advisory group is incredibly important for making sure that those two things are true. Primarily, people get certified because they want to participate in a renewable energy credit market that either requires or recognizes LIHI certification.

Our criteria and standards are science based, and that extends to resource agency recommendations. The low impact recommendations cannot necessarily just be judgment calls. There needs to be some science behind them.

Our reviews are conducted independently, which is important to us. We have a team of contractors who have experience in hydropower and general fields within the industry. We teach them about the LIHI handbook and walk them through the review process. Basically, we train them ourselves, and then we hire them on an application-by-application basis.

The Willow Island Project located on the Ohio River in Ohio. Owned by American Municipal Power (LIHI Certified)

POWERHOUSE: Are there any states that require LIHI certification?

Shannon Ames: In Massachusetts, for any hydropower project to qualify for the renewable portfolio standard (RPS), it needs LIHI certification. LIHI certification is used as a proxy for meeting the statutory requirements of the state’s RPS, and that’s set out in regulations.

Also, Delaware, Oregon, and Pennsylvania recognize LIHI-certified hydro. Those states don’t require it for all hydro to participate in their RPS programs, but they do recognize it, and that’s often for existing or older facilities. And then, increasingly, we’ve seen community choice aggregators become more interested in LIHI-certified hydro.

About a year or two ago, the city of Ithaca, New York, created its own policy around energy procurement and requires LIHI certification for hydro.

Nationally, the Green-e voluntary Renewable Energy Credit (REC) market recognizes LIHI certification, as does the U.S. Environmental Protection Agency (EPA) Green Power Partnership and the Association for the Advancement of Sustainability in Higher Education (AASHE). This association has a comprehensive program, STARS, that universities and colleges use to rate themselves on how they’re doing sustainably. That program recognizes Green-e for its primary renewable sources.

Gregg’s Fall Project located on the Piscataquog River in New Hampshire. Owned by Gregg’s Falls Hydroelectric Associates Limited Partnership, a subsidiary of Eagle Creek Renewable Energy (LIHI Certified)

POWERHOUSE: What role has LIHI played regarding the needs of offtakers?

Shannon Ames: We’re increasingly seeing that offtakers – including large municipalities, higher education institutions, and corporations who want to directly purchase renewable energy for their operations – are increasingly looking at or are interested in hydropower that has LIHI certification. That’s because LIHI certification provides a certain level of confidence, transparency, and detailed information, so offtakers can understand what the project they’re contracting with is doing about sustainability.

Offtakers say they appreciate that our environmental goals are the priority, that we’re independent, and that we’re very transparent. There’s annual accountability for certified entities which we try to make efficient but comprehensive. We check in annually to ensure that operations in the facilities are still in line with what we reviewed at the time of application, and it provides good incentives for stronger stewardship during the course of the LIHI certification term.

POWERHOUSE: How many hydro facilities have been certified as low impact?

We have 177 active certifications comprising a total of 299 facilities. These are located on over 100 rivers in 24 states. Of the U.S. hydropower that is eligible for certification, 11% is currently certified. There are over 160 fish passage structures and over 1,000 recreational facilities and services at certified facilities. On the one hand, it’s great and an exclusive group. On the other hand, we’d love to see that number increase.

Our certificate holders are strong environmental stewards. They steward over a thousand river miles in the U.S., as well as the associated habitat. Of the certified facilities, 80% have threatened and endangered species present, and those species are being protected.

I also want to note that around 70% of our certificates have conditions, so we do try to be very flexible, where, if a facility is taking actions that put them on a path to meeting the goals of our standards, then we will likely certify with a condition — holding that facility accountable for making progress on that commitment.

Either things have to be achieved in order to get to the point where the facility fully meets the goals, or voluntary changes have been made to the operations or to the facility, in order to meet the goals. We will often put a condition in making sure or just calling out that voluntary action needs to be maintained for the life of the certificate, and then sometimes it’s just a best practice that we would like to call out. In any case, the standards must be met.

The Freedom Falls Hydroelectric Project located on River Mile 10 on Sandy Stream in Maine. Owned by TLK Real Estate Holdings LLC (LIHI Certified)

POWERHOUSE: You mentioned eligibility for certification above; which projects are eligible?

Shannon Ames: In terms of eligibility, we cannot certify a facility whose dam was built after August of 1998. That was when we were founded, and we did not want to be a catalyst for building new dams in the U.S.

You know the statistic – there are over 90,000 dams in the U.S., and only 2,500 of them or so have hydro on them, so there are plenty to work with. The same goes with new diversions and potential changes in reservoirs.

We also don’t certify pumped storage or hydrokinetic facilities at the moment.

POWERHOUSE: Have you certified any facilities at federally owned dams?

Shannon Ames: We have certified facilities that are on both U.S. Army Corps of Engineers’ and Bureau of Reclamation dams. We very recently certified one, owned by American Municipal Power, which is on the Ohio River — Willow Island Lock and Dam. While there’s no difference in the process, we do look at flow regime a little differently.

We take into account that the facility normally does not have too much control over the flow, but we still look at the health of the river system upstream and downstream of the facility. The process is a little bit more complicated because we have to assess where the applicant has control and where they don’t.

The Sherman Island Project on the Hudson River in New York. Owned by Erie Boulevard Hydropower LP, a subsidiary of Brookfield Renewable Energy Group (LIHI Certified)

POWERHOUSE: Can you talk more about the LIHI process as it relates to yet-to-be constructed projects that may be going through an original Federal Energy Regulatory Commission (FERC) license proceeding? Is that a manageable element of LIHI’s program?

Shannon Ames: There are two parts to that.

We will certify projects that are not yet built as long as they are being built at existing dams. They just need to have their FERC license and all their permits.

Once it’s fully licensed and permitted, then we can certify. The certification term for a pre-constructed facility starts once it commences operation and generation.

The Ice House Project on the Nashua River in Ayer, Massachusetts. Owned by Ice House Partners (LIHI Certified)

POWERHOUSE: How about projects going through the FERC relicensing process?

Shannon Ames: On the relicensing side, we prefer that a facility or an applicant comes in either well in advance or after a new license is issued. In some circumstances, the relicensing can be complicated and controversial. There could be a lot of unknown questions and a lot of negotiation happening. It’s very challenging for us to process an application or figure out whether a facility meets our standards when new information is becoming available through relicensing studies, but operational matters have not yet been resolved.

If a facility is involved in a very complicated relicensing, then that’s going to take a while and involve a lot of negotiation. We would both ask and recommend that the owner wait until at least the Environmental Assessment (EA) is issued. If a facility is already certified, and they are entering relicensing, we may extend the current certificate term to give time for the license to be issued. That way, we’re not making judgment calls in the midst of the relicensing process.

If a facility gets certified, and their license is going to come within the certificate term, we’d go through recertification for that facility once the new license comes out.

Afterwards, assuming it was certified or recertified, then that would mark the start of a new ten-year term. We understand the investment it takes to go through a full application with us, and we also appreciate the investment that facility owners must make, especially in terms of implementing a lot of the requirements that come with a new license. That’s one of the reasons we restart the certificate term, so that the facility gets ten years on the certificate and does not have to worry about reapplying while those improvements are being made.

POWERHOUSE: Could you go into more detail about the criteria and process LIHI utilizes before it awards a project with low impact hydropower certification?

Shannon Ames: Our criteria are eightfold, and you will notice that they align with the FERC licensing process resource areas. We wanted to build on that process, not duplicate it, and certainly not create something that is wholly unfamiliar.

We look at whether the river flows are adequate for the habitat. (1)

We look at whether the water quality is adequate for the life that exists in the watershed. (2)

We look at whether there’s upstream fish passage (3) and downstream fish passage. (4) If there are no anadromous or catadromous fish at the facility, then it is often unlikely that upstream fish passage would be required by agencies, so we don’t typically require fish passage where there are no present migratory species. With that said, there are some situations where the circumstances around fish passage have changed during the course of a license.

For example, because of the lack of passage at downstream dams, a facility may not have been required to provide passage. But, by the time they apply for LIHI Certification, the downstream dam does have passage, bringing migratory fish to the applicant’s facility. In this case, if the applicant agreed to put fish passage in, we would likely consider that criterion passed. We would put a condition in, and we would put them on the path to installing fish passage.

We also look at whether the shoreline and watershed is being protected. (5) Erosion is probably the primary thing that we look at, but we also look at and provide PLUS standards (see definition below of PLUS standards) for lands that are owned and protected at the facilities.

We look at recent listings of threatened and endangered species, and we look at recent determinations of where those species are, whether they’re in the project vicinity, and whether they’re being protected. (6)

We also look at cultural and historic resources. Is there a plan? Is the facility following the plan? Does it need to have a plan? Have tribal interests been addressed? (7)

And then, finally, recreation. We want to ensure that recreation is free and accessible at the facility. (8)

A facility must pass all eight criteria to achieve certification.

The Androscoggin Project located on the Androscoggin River in Maine. Owned by Andro Hydro LLC, a subsidiary of Eagle Creek Renewable Energy (LIHI Certified)

POWERHOUSE: Can you speak to the LIHI’s ‘plus standard’ addition to certifications?

Shannon Ames: Through our PLUS standard, which adds three to five years onto a certification term, we recognize hydropower facilities that exceed our regular standards and do something above and beyond our basic requirements.

Almost 30% of the facilities that have been certified have voluntarily gone above and beyond what their license requires them to do. That could relate to flow regimes, fish passage, recreation facilities, and/or land conservation. Sometimes those changes are necessary in order for them to meet our standards to become certified, while other times it’s above and beyond, so we recognize that with a PLUS standard.