The Low Impact Hydropower Institute (LIHI) in the U.S. is recommending a new approach to its Certificate recertifications. The new process will be based on events that would trigger a full or partial review, regardless of the number of years since the original certification.
LIHI would like to hear from stakeholders on this proposal, which, if adopted, would go into effect on Jan. 1, 2022.
The original LIHI Criteria for certification were published in 2000. In 2016, LIHI published a comprehensive update to the Certification Handbook, which included substantial changes to the standards used to meet the criteria. The update also changed “recommended for dam removal” from a criterion to an eligibility requirement and made upstream and downstream fish passage separate criteria. In addition, the update introduced the concept of zones of effect, requiring a comprehensive review of the criteria for each different area of impact.
Because of the handbook changes, each active LIHI Certificate was required to go through a two-stage recertification process. All active LIHI Certificates will be finished with that process by the end of 2023.
In 2019, LIHI began a discussion with a focused number of stakeholders (certificate holders and conservation organizations and agencies) of the benefits and drawbacks of the current approach. After many discussions, review of stakeholder problem statements, financial analysis and board review, LIHI staff developed the proposed approach.
Full recertification reviews would be required under a limited number of circumstances, such as receiving a new Federal Energy Regulatory Commission operating license. Partial reviews would be required only when an event listed on the flow chart was triggered. These include changes to the facility or its operations, a new watershed management plan that is applicable to the facility and the LIHI Criteria, an event considered a non-compliance event by regulatory authorities, or new formal resource agency recommendations. Handbook changes that occurred since the last certification would apply at the time of the review. Significant handbook changes would not in themselves be a triggering event.
The proposal has the following benefits:
Reduces application costs. Application fees would remain consistent with today’s rates, although full reviews would be less frequent and partial review fees would be less than today’s stage 2 recertification review fees. Most partial review fees are estimated to be $2,000, the same as today’s stage 1 recertification review fee. Full review fees would be determined after an independent reviewer provides an estimate.
Allows for longer certificate terms and greater certainty. In the case of a facility that recently received a new FERC license, for example, it would be unlikely that a trigger event would be activated for many years. Instead, annual compliance reviews would track progress toward LIHI Criteria relevant improvements being made as a result of relicensing. Certification terms would be considered indefinite and active so long as annual compliance reports are filed in a timely manner and no violation to the LIHI Criteria has occurred.
Maintains stakeholder involvement. If no trigger event has been activated, LIHI will seek input from stakeholders on the facility’s compliance with the LIHI Criteria after five, eight or 10 years (depending on the achievement of PLUS standards). LIHI will provide information on annual compliance reports, ongoing operations, any changes that have occurred at the facility, etc., in the current certification term. An announcement will be made, soliciting comments. This review will serve to ensure that stakeholders have a formal process by which to provide relevant information to LIHI.
Improves transparency. Because annual compliance reviews will increase in importance under this new proposal, LIHI will begin posting annual compliance status on the LIHI project web page.
Retains LIHI independence and program credibility. LIHI will continue to work with external third-party reviewers for application analysis and reports. Annual reviews will be more in-depth but less burdensome than full recertification reviews. LIHI will be able to ensure that certified facilities continue to meet the LIHI criteria. In cases where LIHI criteria are not being met, or are at risk of not being met, LIHI will be able to take action in a timely manner.
LIHI is a non-profit organization dedicated to reducing the environmental impacts of hydropower generation through the certification of hydropower projects that have avoided or reduced their environmental impacts pursuant to the institute’s criteria. The voluntary LIHI program is designed to help consumers identify environmentally sound, low-impact hydropower facilities. Certification under the program means the owner can market the project as a certified low-impact facility.