Get the lowdown - certifying hydro11 December 2003
With eight projects certified, and new projects in the process of application, the Low Impact Hydropower Institute is certainly making a big impact on the US hydro community, as Carrieann Davies discovered when she spoke to the organisation’s new executive director, Fred Ayer
WHEN FRED AYER sat down in early 2002 to conduct an interview with Lydia Grimm, executive director of the Low Impact Hydropower Institute (LIHI) at that time, for inclusion in the March 2002 issue of International Water Power and Dam Construction, he probably didn’t realise that a year and a half later he would be in the same position as his interviewee!
On 2 June 2003, Ayer started his tenure as new executive director of the LIHI, after the governing board voted unanimously to hire the Portland, Maine, US-based consultant following the departure of Grimm to the legal office of Bonneville Power Administration. At the time of Ayer’s appointment, Richard Roos-Collins, chair of the LIHI Governing Board said: ‘We are delighted that Fred will be the new executive director…he has extensive knowledge of the hydro power industry as well as the entrepreneurial experience necessary to move our certification programme forward, so that it becomes truly national in scale.’
One of Ayer’s first assignments in his new role saw him involved with the Nisqually hydroelectric scheme on the Nisqually river in western Washington – the eighth scheme to be certified by the LIHI.
The Nisqually project comprises two facilities - the upstream Alder development, which has an installed capacity of 64MW and is operated in a peaking mode, and the downstream LaGrande development with an installed capacity of 50MW, operating in run of river mode. The project creates a bypassed reach of the Nisqually river between the LaGrande dam and the LaGrande power house (water is diverted at the dam into penstocks or pipelines that go directly to the power house, bypassing the natural channel of the river). The bypass reach is about 2.7km long.
The project was relicensed in 1997 based on consultations with state and federal resource agencies and the Nisqually Tribe. These consultations resulted in new operating conditions to provide increased minimum flows in the bypassed reach and modified flows overall to provide for minimum flows in the river below the LaGrande power house. There are anadromous fish (salmon species that spawn in fresh water and migrate to saltwater) in the lower portion of the LaGrande bypassed reach, and historic barriers to fish passage in the LaGrande gorge. The Nisqually Tribe has treaty fishing rights in the Nisqually river, and operates the Clear Creek Hatchery downstream of the project area.
The project, which meets LIHI's eight environmentally rigorous Low Impact criteria, successfully completed the Institute’s application process, with the board voting unanimously to certify the facility.
As Ayer settles into his position dealing with such projects, I decided to catch up with the new director to find out more about this important organisation.
Q. When and why was the Low Impact Hydropower Institute developed? What is the mission of the organisation?
A. The Low Impact Hydropower Institute (LIHI or Institute) was the brainchild of American Rivers, the non-profit river conservation organisation. It came into being in the late 1990s as an independent entity with the support of a broad range of conservation, renewable energy and public interest groups. The Institute’s Governing Board is made up of representatives from organisations such as American Rivers, Trout Unlimited, the Natural Resources Defense Council, Environmental Defense, the Appalachian Mountain Club, and the Northwest Power Planning Council, among others.
The Institute’s mission is to reduce the impacts of hydro power dams through market incentives. We do this through our Low Impact Hydropower Certification Programme, a voluntary programme designed to help identify and reward hydro power dams that are minimising their environmental impacts. Just as an organic label can help consumers choose the foods and farming practices they want to support, the Institute’s certification programme can help energy consumers choose the energy and hydro power practices they want to support.
Q. What criteria must projects meet in order to gain low impact certification?
A. The Institute’s certification criteria are aimed at ensuring that the certified dam adequately protects or mitigates its impacts in eight key resource areas: river flows, water quality, fish passage and protection, watersheds, threatened and endangered species, cultural resources, and public access and recreation opportunities. The eighth criterion requires that the dam must not have been recommended for removal.
The standards under each criteria vary depending on the specific mitigation measures recommended for the hydro power dam by expert state and federal natural resource agencies in licensing or similar regulatory proceedings. The Institute will certify as low impact only those projects that have met the most stringent recommendations for the project in certain key areas - even if the project is legally authorised to operate with less stringent measures.
The standards are designed to be tough but achievable and to reflect the best available analysis about a project’s impacts. The standards are not designed to eliminate all impacts - that would be impossible. Rather, we want to make sure that a certified Low Impact hydro power facility has minimised its impacts in its particular river context in accordance with the best available science applied to that project.
Q. What happens when a project has been certified as low impact? What does this mean for the hydro operator?
A. When a project achieves LIHI certification, the applicant/dam owner may market the power produced from the facility as coming from a certified Low Impact facility. As renewable energy choices become more popular, the expectation is that certification will provide the dam owner with the ability to charge more for the energy produced from a certified facility. These additional revenues will be in recognition of meeting the strict LIHI standards and that consumers will be willing to pay a premium because they can be confident that the project has been carefully evaluated and meets stringent standards. Dam owners may also want to use the certification as independent confirmation or acknowledgement of good stewardship practices or other corporate environmental goals.
In addition, the Green-e Renewable Electricity label considers hydro power from LIHI-certified facilities to be eligible for the Green-e certified power products (www.green-e.org). The Power Scorecard (www.powerscorecard.org) uses LIHI certification to rate electricity service products containing hydropower supplies.
Q. Is the project reinvestigated after a number of years to ensure it can still be certified as low impact? Do the certificates have a time length?
A. Certification is valid for a period of five years. Since we certified our first facility in 2001, we have not yet had a certificate renewal application, but we envision that at the end of the first five years, the certificate holder would submit a renewal application to the Institute. If there have been no material changes at the facility that would affect the certification and if the criteria have not been revised, renewal will be granted. If there have been material changes or the criteria have been revised, the application will be reviewed in a process similar to an initial application.
From a compliance standpoint each certificate holder must submit an annual statement to the Institute and confirm that during the preceding year there has been:
• ï„·No violation of the Institute’s criteria.
• ï„·No violation of the Certification Use Requirements.
• ï„·No change in conditions relevant to the certification.
• ï„·No receipt of notice of violation or non-compliance relevant to the facility’s certification from any government agency.
Q. How do you decide which projects to investigate? Do hydro operators apply for certification for their facilities or do you approach the hydro operators themselves?
A. The LIHI certification programme is entirely voluntary. By and large, applicants come to us. I’ve only been with the Institute since June and I’m amazed at the interest in Low Impact certification. There is no question that we encourage hydro power project owners to consider certifying their facilities and a unique part of our process is an intensive and confidential pre-application screening process that we have historically not charged a fee for. This part of the process takes place prior to a potential applicant submitting an application. During that process we work closely with the project owner going through our detailed criteria questionnaire to identify areas that could make certification difficult.
Q. I know that members of the LIHI have spoken at meetings in both the US and Europe – what has been the general reaction towards the organisation and its certification programme amongst the hydro power community?
A. We often refer to the variety of entities that own and operate hydro power projects in the US as the ‘hydro industry’ and from my perspective this is a very misleading concept. ‘Hydro industry’ sounds very monolithic and nothing could be further from the truth. The entities that own and operate hydro facilities in the US run the gamut: investor-owned utilities, electric cooperatives, irrigation districts, public utility districts, independent power producers, federal agencies, state agencies, Indian tribes, manufacturers, etc. While I’m not suggesting that these entities have nothing in common, it’s fair to say that for each type of entity there are different missions, goals, objectives, and political and regulatory constraints. These differences, at times, are significant and shape the way certain hydro power owners accept change and new ideas. So, the long and short of it is that the reaction to the LIHI certification programme from the hydro industry is mixed. On one hand, there is a general belief among many hydro project owners that all hydro power dams should be considered eligible for green power status, along with solar and wind power. With that viewpoint, an organisation like LIHI that certifies some hydro power dams and not others is objectionable, even if the certification is entirely voluntary. On the other hand, we have certified eight facilities since early 2001 from both small and large hydro power project owners representing both the public and private side of the hydro industry.
I’m hopeful that hydro folks who are not comfortable with LIHI certification will change their views as markets become more active, predictable, and fair. I believe that the same hydro folks who don’t like ‘outsiders’ deciding what is and isn’t green will come to realise and see the value in what we have to offer - a credible, voluntary, impact-based (as opposed to capacity size-based), environmental certification for projects that meet tough, but attainable standards.
Q. Are you considering taking your certification scheme to projects outside the US?
A. This is something that has been discussed at various times, but because our criteria is built around the FERC [Federal Energy Regulatory Commission] regulatory scheme and a reliance on agency recommendations, we don’t think our process is readily transferable outside the US. However, I’m always interested in talking with folks who might think otherwise - I’d like to think we are open to a range of possibilities.
Q. In an interview you conducted last year with Lydia Grimm, former executive director, she suggested the possibility of using the then current standards as a premium certification, but then offering something less rigorous but still environmentally sound to allow for more of the market to develop. Is this a viable option? Is it something you are looking at?
A. Anything is possible, but right now one of the complaints I hear is that our criteria and process are too complex. It seems to me adding levels of ‘greenness’ probably wouldn’t make it simpler. We have had ongoing discussions over the years with industry trade groups aimed at modifying the LIHI criteria and process, but this has not moved beyond the talking stages. A change like that may be viable, but based on the recent interest in low impact certification, I’m not sure changes are in order. However, we are required by our by-laws to periodically review and if necessary, amend the Low Impact Hydropower Certification Programme requirements as needed.
Q. How many people work for the LIHI? What are their backgrounds?
A. Only one employee - me, and I have 25+ years experience in hydro power licensing and permitting, most as a consultant, but six years with a utility. I have no previous NGO or non-profit work experience. Although small, the ability of our organisation to tap a range of knowledgeable and experienced professionals through its Governing Board, Advisory Boards, Technical Advisor, and contractors is impressive. Each month we become more proficient at perfecting our ‘virtual organisation’. I only meet ‘in-person’ with the Governing Board once a year, but we ‘meet’ via teleconference 8-10 times a year, and regularly converse via e-mail. I make regular use of efficient and knowledgeable contractors as adjunct staff and/or technical assistance. Our web site is loaded with information and provides a great resource for potential applicants and green power advocates.
Q. What made you decide to take up the position as executive director?
A. I have spent the last 25+ years working with hydro projects. Mostly I have worked as a consultant, helping dam owners through the FERC licensing and relicensing process. I am an unabashed fan of hydro power, but I believe the days of new dam construction in the US, are, for all practical purposes, over. I think the interests of the Institute are complementary to the interests of many hydro power project owners, and there is much that can and will be done with existing hydro resources from an engineering, social, and environmental perspective to bring these facilities into the twenty-first century. I see LIHI as an important part of that exciting and challenging ‘refurbishment’ process, and, I will apply my many years of hydro experience to ensure that the Institute’s involvement stays credible and flexible.
Q. What is your vision for the LIHI and what will it look like in five years?
A. I’m very optimistic about the future of the Institute. In five years LIHI will:
• ï„·Be recognised as the ‘gold standard’ for certifying low impact hydro power;
• ï„·Have certified dozens of hydro projects as ‘low impact’ and have those projects be recognised and compensated for that status.
• ï„·Be on the brink of finalising certification procedures/criteria for projects outside the US.
• ï„·Be a credible and knowledgeable voice helping the Green Market evolve to the point that state and federal governments go beyond arbitrary, and relatively meaningless size and date of construction criteria (e.g., projects less than 30 MW and built after 1 January 2000) for determining eligibility of existing hydro projects in procurement programmes and RPS eligibility standards.
Let’s get together in five years and see how close I came.For further information about the Low Impact Hydropower Institute, and the projects they have certified so far, please visit www.lowimpact.org
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