Connecticut River Conservancy Testimony in OPPOSITION to SB 123 An Act Concerning the Public Utilities Regulatory Authority, the Regulation of Electric Rates and State Public Policy Concerning Electricity Generation
To: Honored Co-Chairs, Sen. Needleman and Rep. Steinberg, and distinguished Members of the Energy & Technology Committee
I am writing on behalf of the Connecticut River Conservancy; we are an environmental nonprofit dedicated to protecting the entire Connecticut River valley through initiatives that support clean waters, healthy habitats and thriving communities. We support the intent of SB 123 but are strongly opposed to the change in how hydropower is defined in Section 4.
Hydropower can have substantial impacts on river health by blocking fish passage, dewatering areas where fish and other wildlife raise their young, and eroding habitat along riverbanks causing water levels to fluctuate up and down unnaturally. Our organization routinely advocates for the river in proceedings with hydroelectric facilities in other states in the watershed to push for strong environmental protection. Upstream we deal with facilities that impact access to recreation, dewater rivers, decimate fish and other aquatic species, and erode streambanks all while profiting off of a public trust. While hydropower is less carbon intensive than “non-renewable” sources of energy, it still has measurable and long-lasting negative impacts on rivers and their associated ecosystems. Therefore, we recommend that the changes pertaining to the definition of hydropower for the Class 1 designation located in Section 4 be removed from the bill.
When hydropower as a Class 1 source was proposed for inclusion in 16-1 in 2013, there was significant opposition to allowing hydropower operations that did not comply with common-sense standards for river health. These are the recommendations we submitted (as the Connecticut River Watershed Council) that were in-part incorporated into the definition that is proposed for removal:
- Run-of-river operation needs to be included in any definition of Class 1 hydro and it must be defined so that it is accurately described as a constant flow of water through a facility. Some dams claim to be run-of-river, but actually allow for up to 5-foot fluctuations in water level over a 24-hour period.
- There must be ecologically relevant flow releases from facilities, such that by-pass reaches not otherwise receiving run-of-river flows are guaranteed to have sufficient water to function as habitat as determined by state fisheries biologists.
- Upstream and downstream passage for all migrating species must be present and functional. Species such as shad, river herring, or eels needs to be allowed to move up and downstream from those dams that are determined by state fisheries biologists to block passage.
- All facilities must be in compliance with their FERC licenses and state water quality certificates issued under Section 401 of the Clean Water Act.
These standards must not only apply to hydropower generated in the state of Connecticut but must also apply to any hydropower that is imported into the state.
We understand the need to make energy more affordable. But we must not do so by removing ecological standards and giving preference to hydropower generation projects that are not environmentally sound. We appreciate that Connecticut currently has basic environmental protection for our waterways in our statutes – we should not remove those and move backwards. We oppose the proposed change in definition of hydropower facilities recognized as a Class 1 source.
Thank you for your consideration. I may be reached at email@example.com or 860-929-8021.
Rhea Drozdenko (she/her/hers)