Comment Log Display

The California Hydropower Reform Coalition (CHRC) supports the
overall objective of increasing Renewable Portfolio Standards
(RPS) requirement to 33 percent by 2020, but we oppose weakening
the definition of small hydro in current RPS statutes.  Doing so
will result in significant adverse environmental impacts.  The key
statute language that should be maintained is a facility that is 30
MW or less ¡§is not an eligible renewable energy resource if it
will cause an adverse impact on instream beneficial uses or cause
a change in the volume or timing of streamflow¡¨.  

If the requirement is increased to 33 percent, purchase of
out-of-state renewables will be important for entities such as
PG&E.  On June 20, 2008, as required, PG&E submitted a letter to
the CPUC explaining why it intends to continue Phase 2 of a study
assessing the physical and regulatory context for developing,
purchasing, transmitting renewable energy from British Columbia
(BC) for California RPS purposes.  Both PG&E¡¦s letter and the
Phase 1 study are attached.  The key conclusions of PG&E¡¦s Phase
1 study include: 
„X	By 2016, BC could develop as much as 6,000 MW of small hydro.
„X	BC small hydro currently would not be RPS eligible in
California, because it would not meet our regulations.  The study
says: "The key obstacle to project success that must be modified
by legislation is the definition of new small hydro generation."
„X	Because current California standards "are the consensus result
of a coalition effort, new efforts to qualify hydro...must be
closely coordinated with those stakeholders."   

CHRC is the leading organization in California addressing river
and watershed restoration through the FERC hydropower relicensing
process.  CHRC was founded in 1997, we are a statewide coalition
of more than 30 conservation, fishing, and recreation
organizations, and have led efforts to secure numerous hydropower
relicensing settlement agreements.  
We are open to discussing efforts to achieve 33 percent, but
oppose weakening the small hydro definition.  We appreciate the
opportunity to comment on this issue.