Rivers Alliance Comments on the draft RFP from Private Developers for Zero Carbon Energy
In May, CT DEEP solicited public comments on what should be in the next request for proposals for the zero carbon energy procurement. Our comments focused on ensuring that projects on brownfields and previously disturbed lands be given weight in order to be competitive. While there are definitely some improvements and we appreciated the enhanced public outreach component in the draft, we expressed concern comments submitted on the draft RFP that the process has not changed in order to favor siting that would not be detrimental for forests, farmland soils and water quality.
Read our full comments on the Draft RFP for Zero Carbon Procurement – Comments of Rivers Alliance
River Alliance submits comments on DEEP’s RFP for grid-scale clean energy procurement
Promoting and procuring carbon-free, renewable energy is essential to slowing down the impacts of climate change. However, if not sited and implemented thoughtfully, renewable energy can be harmful to resources necessary to adapt and be more resilient to the impacts of climate change that our region is already experiencing. We need to go beyond only looking at carbon offsets as the measure of balance between losing forest and reducing carbon. Loss of ecosystem services must be considered as well. When it comes to our inland water resources, large-scale solar and hydropower can be particularly damaging if not priced and sited properly.
Kinneytown Dam: Working for Better Passage for Migratory Fish
Over the past several decades, the Naugatuck River has made a remarkable comeback, with the return of fish, birds, and other wildlife, and an increase in human use. From 1999-2004 five dams were removed from the river. However, currently, there is an ineffective fish ladder at Kinneytown Dam that is preventing migratory fish from accessing miles of restored habitat upstream. Rivers Alliance of Connecticut is proud to be a part of the Naugatuck River Restoration Coalition, a coalition of concerned organizations formed to ensure that safe, timely, and effective fish passage returns to the Naugatuck River.
Providing safe, timely, and effective fish passage is a condition of the exemption from licensing the Kinneytown Dam was granted in 1983. While the fish ladder was built to meet this requirement, even when it was operating as designed, fish passage was modest, at best. Since 2013, the ladder has been rendered almost completely ineffective.
For more information on this hugely important issue, check out this interactive story-map.
Moratorium Needed on Large Scale Solar Permitting
Moratorium Needed on Large Scale Solar Permitting Impacting Natural or Working Lands
The Rivers Alliance Board of Directors has asked the Commissioner of Connecticut’s Department of Energy and Environmental Protection (DEEP) Katie S. Dykes to issue a moratorium on permitting for large scale solar installations impacting natural or working lands.
Given the number of applications before the Siting Council, the Rivers Alliance board voted unanimously to support a moratorium until the Siting Council reviews the recommendations from the Governor’s Council on Climate Change (GC3) and, in coordination with DEEP, adopts new standards for review. We understand that PA 17-218 was enacted to protect prime farmland and core forests. It is evident, however, that we are still losing farm and forestland to solar development at an alarming rate. The GC3 working groups have identified critical ecosystem services provided by our natural and working lands that are not addressed by the legislation and are not being considered by DEEP or the Siting Council.”
Energy Projects And Water Protection
For several years, the siting of clean energy projects has been highly problematic with respect to protecting water resources, core forests, and farmland. Recently Rivers Alliance joined in a petition to improve the stormwater discharge plans for a large solar project in core forest above Candlewood Lake. See below a Hartford Courant article on the project, detailed comments on the science and process by Weantinoge Heritage Land Trust, and comments from Rivers Alliance.
Link to Hartford Courant article
Links to Rivers Alliance comments in support of Weantinoge Heritage Land Trust opposing Candlewood Solar LLC.
New Hampshire Nixes Controversial Hydropower Project
On February 1, New Hampshire regulators unanimously rejected the controversial Northern Pass Transmission project, which is supposed to deliver hydropower from New Hampshire to southern New England. The Northern Pass route, which would run through the White Mountains, has been vigorously opposed by environmentalists, especially since other routes are available. The bad news stunned Eversource and the state of Massachusetts. For some reason environmental opposition was not taken seriously. But New Hampshire values its natural resources and the tourism they inspire. The vote in the state Site Evaluation Committee (SEC) was 7 to 0. Eversource can appeal. But how about honoring the importance of open space and wildlife (here in Connecticut, too)?
Here’s a link to one of the many press reports: https://www.usnews.com/news/best-states/new-hampshire/articles/2018-02-01/state-regulators-vote-to-kill-northern-pass-project
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 Action, Connecticut College Arboretum, The Nature Conservancy in Connecticut, Council on Environmental Quality, and many, many individuals too numerous to mention 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
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.