Comment Opportunity on Importing BC Hydropower to California

Posted: 11/12/2013
By: Thomas O'Keefe

California is currently accepting comments on whether or not it makes sense to import dirty hydropower from Canada to meet renewable energy standards. Comments are specifically being called for on the draft report entitled "Including British Columbia run-of-river facilities in the California Renewables Portfolio Standards," that included a March 2013 Consultant Report entitled "Analysis of regulatory requirements for including British Columbia run-of-river facilities in the California Renewables Portfolio Standards." The prospects of importing British Columbia's dirtiest hydropower to California are currently very dim, but the state is soliciting public comment on the report with a deadline of November 15th (Notice of Availability and Request for Comments).

Many of our members have expressed concerns with the pace of hydropower development in British Columbia and the devastating impact it is having on rivers enjoyed for whitewater recreation and their natural resource values.
The state's report was completed at the request of the California state legislature who directed the Energy Commission to study the impacts of British Columbia's run-of-river hydropower projects on water quality, recreation, and fisheries. Staff concluded that it would be extremely difficult for these projects to meet the environmental requirements of California's Renewable Portfolio Standard. Staff further concluded that these impacts and the associated transmission costs make it unlikely that hydropower facilities in British Columbia would make a meaningful contribution to California's renewable energy portfolio. 
Staff pointed out that a facility outside the United States must be developed and operated in a manner that is as protective of the environment as a similar facility in California. The report documented what we already knew from the experience of our members who have witnessed these developments first hand: British Columbia requires no Environmental Assessment for projects less than 50MW (which is the majority of projects), agency and public involvement is limited, projects are being increasingly proposed in areas of sensitive wildlife and fish habitat, up to 90% of flow is removed from the river, recreational impacts are largely ignored, and projects are not effectively monitored and compliance with minimal mitigation measures is low.
The findings of this report represent an important victory for the rivers of British Columbia, however the report inaccurately says hydro from British Columbia is "potentially eligible." This is incorrect and it should say hydro from British Columbia is "currently ineligible." With 45 developed run-of-river projects and 36 additional projects under development, the impacts that have already occurred have been devastating. If California were to provide a market for this dirty hydropower, long the dream of many of the developers scrambling to grab a license for every high gradient creek in the province, nearly 2000 sites would be under consideration for hydropower development.
While we have found it challenging to engage in the regulatory process in British Columbia--a challenge when no public process exists--we will continue our advocacy efforts in this country to focus on the demand side of the equation. The power is not needed in British Columbia but with significant profits at stake, we anticipate continued efforts to export the power to the West Coast states of Washington, Oregon, and California.
Commenting on the Report
Public comments are being accepted on the draft report. We recommend that those with an interest in the protection of British Columbia's free-flowing rivers consider filing a comment. Consider these points in developing your comment:
1) Describe your personal interest in the rivers of British Columbia and how the development of these rivers would impact your use and enjoyment of the resources they provide. 
2) State your agreement with the staff conclusion that they do "not find any compelling reason to modify the existing eligibility requirements of the Renewables Portfolio Standard statute" in California to incentivize importing run-of-river hydropower from British Columbia.
3) Request that staff correct the finding that hydropower from British Columbia is "potentially eligible." Hydropower from British Columbia is "currently ineligible," because hydro facilities greater than 30 MW or built after 2005 are ineligible as "renewable" under the California Renewable Portfolio Standard (RPS). Additionally, under California statute "a new hydroelectric facility is not an eligible renewable resource if it will cause an adverse impact on instream beneficial uses or cause a change in the volume or timing of streamflow." Describe in your own words how these facilities have an adverse impact on instream beneficial uses.
4) California statute states that "to be considered eligible for California's Renewables Portfolio Standard, projects located outside the United States must be developed and operated in a manner that is as protective of the environment as a similar facility located in California." California laws are much more protective of the environment than those in British Columbia. Consider personal examples in describing how these facilities are not protective of the environment.
American Whitewater will be working with our colleagues in the California Hydropower Reform Coalition to file more detailed comments.
To File Comments:
Written comments on the Staff Draft Report should be submitted to the Dockets Office by close of business on November 15, 2013. All written comments will become part of the public record of this proceeding and will be posted on the Energy Commission’s website.
The Energy Commission encourages comments by e-mail. Please include your name and/or your organization’s name. Comments should be in a downloadable, searchable format such as Microsoft® Word (.doc) or Adobe® Acrobat® (.pdf). Please include the docket number 11-RPS-01 and indicate “BC Hydro Draft Report” in the subject line. Send comments to and copy Brian McCollough, Project Manager, at
If you prefer, you may send a paper copy of your comments to:
California Energy Commission
Dockets Office, MS-4
Re: Docket No. 11-RPS-01
1516 Ninth Street
Sacramento, CA 95814-5512


Thomas O'Keefe

3537 NE 87th St.

Seattle, WA 98115

Phone: 425-417-9012
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