In an earlier post, we mentioned that a recent FERC decision had Canadian hydro developers cheering the agency’s characterization of hydro as clean energy. Hydro is an important energy source in New England, but its treatment as a renewable energy source has never been uniform. Each New England state currently allows hydro to count toward its Renewable Portfolio Standard (RPS), but no two state standards (pdf) in the region are alike. To get a sense of the variation of treatment, just look at the variety of hydro plant size requirements for plants to qualify for each state’s RPS: CT limits qualifying hydro to 5 MW or less (2003 or newer); Maine existing plants less than 100 MW; Massachusetts up to 25 MW (1997 or newer) (for Class I; Class II must be 5MW or less); New Hampshire counts incremental production for existing plants of any size (Class I) or new installations of 5 MW or less (Class IV); RI limits capacity to 30 MW; VT limits capacity to 200 MW.
This variety of state RPS standards will no longer be an issue if a national standard is enacted. Which begs the question: how will hydropower count under a national standard? Under the current draft of the Waxman-Markey American Clean Energy and Security Act of 2009 (pdf) (the ACES Act), hydropower that qualifies for renewable certification is limited to:
- Incremental hydropower (improvements to the capacity or efficiency of existing hydro plants);
- Certain hydropower development at existing, non-generating dams; and
- Hydrokinetic technologies, such as ocean, wave and tidal generation.
As with nuclear generation and generation utilizing carbon sequestration technology, non-qualifying hydro power is not certified as “renewable” under the current draft legislation, but is excluded from the calculation of a supplier’s base emissions.
In short, when it comes to certifying renewable energy credits, conventional hydropower often doesn’t qualify, in spite of the fact that hydropower enjoys a substantial (and well-established) emissions advantage over other conventional power sources. (For a discussion of the policy objectives RPSs are used to advance, see this previous post.) We’ll be watching to see whether the certification of conventional hydro is the subject of debate when the ACES Act heads to floor. But whether certification of hydropower is debated or not, hydro also serves as a sort of marker for the political debate that proposed legislation will surely face: regions with significant hydro resources, like New England, have lower per-capita emissions and are more supportive of carbon legislation, while regions without hydro are more dependent on coal and much less likely to support the ACES Act. This problem of regional inequality of carbon impact, has been explored in depth in a recent report (pdf) by the Brattle Group. The report identifies a core of legislators – dubbed The Carbon Nine – who may need to be convinced that their constituents will not bear a greater burden under the ACES Act than those who, like New Englanders, already rely on low-emissions sources like hydro.
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