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Rethinking Low Impact Hydropower and Renewable Energy Certificates

Low Impact Hydropower Project

Wind and solar projects along with their related renewable energy certificates RECs) are on the minds of energy generators, consumers and policy makers. This begs the question as to why hydropower and specifically low impact hydropower are not eligible to receive the same attention. A closer look at the issue reveals both the states and consumers have much to say about the technologies that qualify for RECs. In fact, low impact hydropower projects may qualify for RECs under some individual State Renewable Portfolio Standards (RPS) or the US Environ- mental Protection Agency’s (EPA) Green Power Partnership but not all.

This places the burden on a hydropower developer who believes that their project qualifies for a REC to either work with the relevant state agencies to determine the project’s eligibility and then with third-party validation organizations such as the Low Impact Hydropower Institute (LIHI) and the Center for Resource Solutions Green-e Standard (CRS)2 to be eligible to receive a REC. That may be difficult and expensive, because a state’s view of hydropower is based in part on past regulatory practices associated with the construction and operation of hydropower projects. Some states may understand this, but it may be difficult for them to make exceptions to existing rules and regulations even when a project’s operation changes and benefits environmental resources.

The process of obtaining RECs for a hydro- power project is complicated because the definition of “low impact hydropower” is not defined by federal law. In fact, many states and consumers automatically exclude hydropower because of its reputation as being threatening to the environment and aquatic life. In contrast, states and consumers readily embrace wind and solar as projects that would qualify for RECs even though the effects of wind farms on bird and bat populations and the large environmental land requirements of solar projects are well known. This author believes that rethinking the definition of low impact hydropower is long over- due. States and most consumers fail to recognize the significant changes in law and the Federal Energy Regulatory Commission’s (FERC) regulatory program and case law regarding US hydropower that have occurred since the passage of the National Environmental Policy Act (NEPA) of 1969. When these factors are considered, this author believes there are large numbers of hydropower projects that would qualify as “low impact” and ultimately qualify for RECs. If that occurred, hydropower could be recognized for its contribution in various state RPS programs and in the EPAs Green Power Partnership and play a larger role in the nation’s energy transition away from fossil fuel generation. This would benefit hydropower owners and companies wishing to decarbonize their organizations. Read the full article in the Climate and Energy Journal. [node:read-more:link]

Responsibly Sourced Natural Gas: Time to Change the Natural Gas Industry’s Narrative

Benefits of Responsibly Sourced Natural Gas

The majority of companies in the natural gas and liquefied natural gas (LNG) industry seem fixated on promoting natural gas as the clean “bridge fuel” to further deployment of renewable energy technologies. While natural gas emits far less carbon dioxide (CO2) than coal or oil used to generate power and heat, , it still is a “fossil fuel” that contributes to the adverse effects on climate. Fossil-fuel opponents are increasingly skeptical of the climate benefits reported by the US natural gas and LNG industry. These opponents often cite a  study released in April 2020 that showed methane emissions from the Permian basin of West Texas and New Mexico, one of the largest oil-producing regions in the world, are more than two times higher than federal government estimates.  

The time has come for the natural gas and LNG industry to recognize that the “bridge” for natural gas may be much shorter than previously thought.

            This author believes the time has come for the natural gas and LNG industry to recognize that the “bridge” for natural gas may be much shorter than previously thought. It’s time for the industries and individual companies to shelve slogans and take action to distinguish US natural gas from other global sources by embracing a narrative of “Responsibly Sourced Gas (RSG).” To do otherwise, increases the risk that natural gas and LNG will fall victim to the growing movement to decarbonize the heating, power and transportation sectors via an all electrification strategy. Federal and state policy makers, regulators and lawmakers could begin questioning whether US natural gas and LNG industries could even play a role in the clean energy economy envisioned by the incoming Biden Administration and evidenced by the Biden-Sanders Climate Action Plan. Read more by downloading the entire article [PDF] from the Climate & Energy Journal. [node:read-more:link]

Carbon Pricing in Wholesale Electricity Markets—Options for Fossil-Fuel Generators

Sunset and electric transmission lines

This article was co-authored by Jack Gross, a graduating senior of the George Washington University class of December 2020.

On October 15, 2020, the Federal Energy Regulatory Commission (FERC) announced in a proposed policy statement that it had jurisdiction over carbon pricing mechanisms within the wholesale electricity markets. In that same policy statement, FERC also confirmed it had the authority to approve such rules if brought forward by regional transmis- sion organizations (RTOs) and independent system operators (ISOs).

FERC’s announcement ushers in a new era of wholesale electricity market regulation, particularly for fossil-fuel power generators using natural gas, coal, and biomass. These generat- ing resources will no longer be able to rely on

inexpensive fuels to remain competitive. Instead, they will have to navigate carbon pric- ing mechanisms for existing and future power plants if they are to remain competitive in wholesale electricity markets designed to decarbonize the electric power sector. As is the case with any new proposal from FERC, it will take time for RTOs and ISOs to develop carbon pricing proposals with their stakeholders and market participants. This gives companies time to discuss and develop strategies.

Because fossil-fuel power generators consist of regulated electric utilities, electric and gas utilities and independent power producers (IPPs), each of their approaches to dealing with carbon pricing will likely vary. Some companies might take a “business as usual” approach, including operating existing power plants until the end of their existing economic life, even if it’s shortened by carbon pricing. Generation owners may also decide to do one or more of the following to address carbon pricing in wholesale electricity: [node:read-more:link]

New NEPA Reforms could delay Renewables and Clean Electric Transmission

Federal Lands where trigger NEPA

On July 16, 2020, the President’s Council on Environmental Quality (CEQ) finalized an overhaul of the guidelines for implementing the National Environmental Policy Act (NEPA) regulations (rule). Supporters of the new regulations applauded the changes, but the states and numerous national environmental groups vowed to challenge the new rule in the courts. The timing of the final rule just prior to the Presidential election in November will also create a great deal of uncertainty for projects currently undergoing NEPA reviews and possible delays by those planning projects. [node:read-more:link]

Hydrogen: Hype or a Glide Path to Decarbonizing Natural Gas – Part 2

We continue the analysis of hydrogen which began in Part 1. This time we cover the following topics:

  • The status of efforts to blend hydrogen in the U.S. grid,
  • What hydrogen blending means for decarbonizing natural gas,
  • Regional opportunities to increase hydrogen in the U.S. and to serve Fuel-Cell Electric Vehicles (FCEV), and
  • The Disconnect between hydrogen policy and green hydrogen production shortages

Hydrogen: Hype or a Glide Path to Decarbonizing Natural Gas – Part 1

Blue Hydrogen

Existing technologies that produce blue hydrogen with carbon capture, use, and storage (CCUS) could be a bridge to widespread production of green H2, which is produced with renewable energy without carbon dioxide (CO2) emissions. By incentivizing and encouraging higher production of blue H2, which primarily uses natural gas, and green H2, the transportation sector could be decarbonized to combat the adverse effects of climate change. [node:read-more:link]

Regulatory Challenges Facing Renewable Natural Gas

Renewable Natural Gas- where are the regulators?

Why aren't state regulators getting behind renewable natural gas as they have for wind, solar and other renewable energy projects? The answer may be a one-size fits all mindset where electrification is viewed as the only solution to a successful energy transition. I'm not so sure that this is the case. The conventional wisdom is that RNG is the domain of state regulators, but a closer look at the challenges that RNG projects face shows that the FERC could reduce the costs of RNG projects wishing to interconnect to interstate natural gas pipelines. [node:read-more:link]

Is Electric Battery Storage Overrated as a Clean Technology?

The U.S. and the world are undergoing an accelerated energy transition with high stakes regarding energy security. Concerns about climate change and greenhouse gas emissions are dominating the debate about which energy technologies are politically most acceptable to meet energy needs. Renewable energy, energy efficiency, and electric battery storage technologies appear to be the preferred technologies. However, we believe the notion that renewables and electric storage (batteries) are “clean” has been overstated. [node:read-more:link]


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Tom has a diverse and valued history at the Federal Energy Regulatory Commission. His expertise ranges from hydropower development to cyber security issues. Anyone dealing with the complexities of FERC's regulatory regime would be well served to discuss their issues with Tom.

Principal, JMR Energy Infra, LLC

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