hydropower relicensing and climate change

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HYDROPOWER RELICENSING AND CLIMATE CHANGE 1 Joshua H. Viers 2 ABSTRACT: Hydropower represents approximately 20% of the world’s energy supply, is viewed as both vulnera- ble to global climate warming and an asset to reduce climate-altering emissions, and is increasingly the target of improved regulation to meet multiple ecosystem service benefits. It is within this context that the recent deci- sion by the United States Federal Energy Regulatory Commission to reject studies of climate change in its con- sideration of reoperation of the Yuba-Bear Drum-Spaulding hydroelectric facilities in northern California is shown to be poorly reasoned and risky. Given the rapidity of climate warming, and its anticipated impacts to natural and human communities, future long-term fixed licenses of hydropower operation will be ill prepared to adapt if science-based approaches to incorporating reasonable and foreseeable hydrologic changes into study plans are not included. The licensing of hydroelectricity generation can no longer be issued in isolation due to downstream contingencies such as domestic water use, irrigated agricultural production, ecosystem mainte- nance, and general socioeconomic well-being. At minimum, if the Federal Energy Regulatory Commission is to establish conditions of operation for 30-50 years, licensees should be required to anticipate changing climatic and hydrologic conditions for a similar period of time. (KEY TERMS: climate change; environmental regulations; hydropower; relicensing; water law; water policy.) Viers, Joshua H., 2011. Hydropower Relicensing and Climate Change. Journal of the American Water Resources Association (JAWRA) 1-7. DOI: 10.1111/j.1752-1688.2011.00531.x INTRODUCTION Hydropower represents approximately 20% of the world’s energy supply (Sommers, 2004), is viewed as both vulnerable to global climate warming (Lehner et al., 2005; Minville et al., 2009) and an asset to reduce climate-altering emissions (Kosnik, 2008; Resch et al., 2008), and is increasingly the target of improved regulation to meet multiple ecosystem ser- vice benefits (Reno ¨fa ¨lt et al., 2009). It is within this context that the recent decision by the United States (U.S.) Federal Energy Regulatory Commission (FERC) to reject studies of climate change in its con- sideration of reoperation of the Yuba-Bear Drum- Spaulding (YBDS) hydroelectric facilities in northern California will be shown in this article to be poorly reasoned and risky. Through the Federal Power Act (FPA), the U.S. FERC is the sole issuer of licenses for nonfederal hydroelectric operations. Since 2005, licenses often undergo an Integrated Licensing Process (ILP; Energy Policy Act §241), which provides opportunity for affected parties to recommend issues for consulta- tive investigation and possible mitigation, such as impacts to downstream fisheries. In light of global 1 Paper No. JAWRA-10-0028-P of the Journal of the American Water Resources Association (JAWRA). Received March 2, 2010; accepted January 21, 2011. ª 2011 American Water Resources Association. Discussions are open until six months from print publication. 2 Assistant Research Scientist, Department of Environmental Science & Policy, University of California, Davis, One Shields Avenue, Davis, California 95616 (E-mail / Viers: [email protected]). Joshua H. Viers holds a research faculty affiliate position with the Center for Watershed Sciences. JOURNAL OF THE AMERICAN WATER RESOURCES ASSOCIATION 1 JAWRA JOURNAL OF THE AMERICAN WATER RESOURCES ASSOCIATION AMERICAN WATER RESOURCES ASSOCIATION

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  • HYDROPOWER RELICENSING AND CLIMATE CHANGE1

    Joshua H. Viers2

    ABSTRACT: Hydropower represents approximately 20% of the worlds energy supply, is viewed as both vulnera-ble to global climate warming and an asset to reduce climate-altering emissions, and is increasingly the targetof improved regulation to meet multiple ecosystem service benefits. It is within this context that the recent deci-sion by the United States Federal Energy Regulatory Commission to reject studies of climate change in its con-sideration of reoperation of the Yuba-Bear Drum-Spaulding hydroelectric facilities in northern California isshown to be poorly reasoned and risky. Given the rapidity of climate warming, and its anticipated impacts tonatural and human communities, future long-term fixed licenses of hydropower operation will be ill prepared toadapt if science-based approaches to incorporating reasonable and foreseeable hydrologic changes into studyplans are not included. The licensing of hydroelectricity generation can no longer be issued in isolation due todownstream contingencies such as domestic water use, irrigated agricultural production, ecosystem mainte-nance, and general socioeconomic well-being. At minimum, if the Federal Energy Regulatory Commission is toestablish conditions of operation for 30-50 years, licensees should be required to anticipate changing climaticand hydrologic conditions for a similar period of time.

    (KEY TERMS: climate change; environmental regulations; hydropower; relicensing; water law; water policy.)

    Viers, Joshua H., 2011. Hydropower Relicensing and Climate Change. Journal of the American Water ResourcesAssociation (JAWRA) 1-7. DOI: 10.1111/j.1752-1688.2011.00531.x

    INTRODUCTION

    Hydropower represents approximately 20% of theworlds energy supply (Sommers, 2004), is viewed asboth vulnerable to global climate warming (Lehneret al., 2005; Minville et al., 2009) and an asset toreduce climate-altering emissions (Kosnik, 2008;Resch et al., 2008), and is increasingly the target ofimproved regulation to meet multiple ecosystem ser-vice benefits (Renofalt et al., 2009). It is within thiscontext that the recent decision by the United States(U.S.) Federal Energy Regulatory Commission

    (FERC) to reject studies of climate change in its con-sideration of reoperation of the Yuba-Bear Drum-Spaulding (YBDS) hydroelectric facilities in northernCalifornia will be shown in this article to be poorlyreasoned and risky.

    Through the Federal Power Act (FPA), the U.S.FERC is the sole issuer of licenses for nonfederalhydroelectric operations. Since 2005, licenses oftenundergo an Integrated Licensing Process (ILP;Energy Policy Act 241), which provides opportunityfor affected parties to recommend issues for consulta-tive investigation and possible mitigation, such asimpacts to downstream fisheries. In light of global

    1Paper No. JAWRA-10-0028-P of the Journal of the American Water Resources Association (JAWRA). Received March 2, 2010; acceptedJanuary 21, 2011. 2011 American Water Resources Association. Discussions are open until six months from print publication.

    2Assistant Research Scientist, Department of Environmental Science & Policy, University of California, Davis, One Shields Avenue, Davis,California 95616 (E-mail Viers: [email protected]).

    Joshua H. Viers holds a research faculty affiliate position with the Center for Watershed Sciences.

    JOURNAL OF THE AMERICAN WATER RESOURCES ASSOCIATION 1 JAWRA

    JOURNAL OF THE AMERICAN WATER RESOURCES ASSOCIATION

    AMERICAN WATER RESOURCES ASSOCIATION

  • warming (IPCC, 2007) and an overwhelming body ofscientific evidence for changes to the hydrologicregime (Dettinger et al., 2004; Hayhoe et al., 2004;Stewart et al., 2004, 2005; Maurer et al., 2007), a coa-lition of stakeholders recently requested that climatechange and its potential impact to YBDS hydropoweroperations be included as one of several studiesundertaken in the ILP. FERC denied this studyrequest on the grounds that

    Although there is consensus that climate change isoccurring, we are not aware of any climate changemodels that are known to have the accuracy thatwould be needed to predict the degree of specificresource impacts and serve as the basis for inform-ing license conditions. (FERC, 2009)The YBDS hydroelectric generation and water con-

    veyance facilities are a complex mix of infrastructure,operations and jurisdictions between a private utility(Pacific Gas and Electric) and public utility (NevadaIrrigation District). Because of the complexity of oper-ations and geographic proximity, these utilities havefiled joint applications to FERC to renew existinghydropower generation licenses, which if approvedwill ensure a series of operating rules for the life ofthe license, typically 30-50 years in length.

    The potential energy used in hydropower opera-tions is a common pool resource with public discretionas to its end use. Hydropower provides a quick sourceof reliable energy due to its ability to transformpotential energy from stored water into kineticenergy, and ultimately electricity, on very shortnotice, often within seconds, and thus adds signifi-cant flexibility to an energy supply portfolio. Hydro-power is also a renewable source of energy that doesnot emit greenhouse gases through generation, andpresently contributes 15%24% of Californias totalpower system supply (CEC, 2005, 2008). Recent shiftsin policy (e.g., California Assembly Bill 32 (Francoet al., 2008)) have placed an emphasis on developingand maintaining hydropower as part of its efforts tocurb greenhouse gas emissions, and sustain devel-oped energy sources. As such, the public has aninherent interest in the continued maintenance andproduction of energy from its rivers.

    However, hydroelectricity is produced with detri-mental environmental consequences. Hydropower sys-tems adversely impact riverine ecosystems innumerous ways (Ligon et al., 1995; Poff and Hart,2002; Poff et al., 2007), including the disruption of fishmigratory routes; alteration to the flow regime, whichcan disrupt reproduction of aquatic and riparianorganisms alike; alteration of geomorphic processesthat can either deprive sediment from downstreamecosystems or create conditions of scour and incision;and alter the quality of downstream waters, mosttypically temperature. The environmental impacts of

    hydropower vary across time, including hourly peak-ing operations that rapidly change downstream flowconditions and long-term impoundments in largereservoirs that alter the downstream hydrologicregime on inter- and intra-annual bases.

    The impacts of global climate warming to thehydrological regime include changes in the spatialand temporal distribution of precipitation patterns,and its intensity and extremes; widespread melting ofsnow and ice; increased rates of evaporation and tran-spiration; and changes to soil moisture and runofffluxes (IPCC, 2008). Similar observations have beenmade in the regional context of western NorthAmerica, most notably a shift in the seasonality ofsnowmelt runoff (Stewart et al., 2005; Maurer et al.,2007), as well as long-term trends to Californias lar-ger rivers (Dettinger et al., 2004; Vicuna et al., 2007;Anderson et al., 2008). Californias climate is expectedto warm by 2-6!C over the next 50-100 years (Hayhoeet al., 2004), with reduction in snowpack, earlierrunoff, and reduced spring and summer flows (seeHidalgo et al., 2009). Despite the lack of consensus inoverall precipitation changes in California (Dettinger,2004; Vicuna et al., 2007), the Mediterranean seasonalprecipitation regime of wet winters and dry summersis not projected to change (Cayan et al., 2008).

    Recent studies of Sierra Nevada water resourcesunder climate warming suggest that these generalclimatic and hydrologic changes will result in sub-stantial changes in the timing, magnitude, duration,and frequency of flows (Vicuna and Dracup, 2007;Young et al., 2009), posing significant challenges tohydropower generation under a status quo approachto operations. For example, Mehta et al. (2011) useda rainfall-runoff model (WEAP21) and coupled waterdemand prioritization module for the area in questionto simulate hydroclimatic response to uniformincreases of 2, 4, and 6!C to observed air tempera-tures and historical precipitation for the period 1981-2000 in weekly time steps. The period of simulationincluded an extended drought (1987-1992), the wet-test year on record (1983), and the flood year ofrecord (1997), which represent extremes in the histor-ical discharge record. This study shows that withoutchanges to water management operations (i.e., reser-voir storage and release schedules) shifts toward ear-lier timing of hydropower generation and reductionin total annual generation result, with a 5-20% reduc-tion in hydropower generation overall with 2-6!Cwarming, respectively, largely from a reduction inseasonal snowpack and annual streamflow. Summerseasonal hydropower reductions range from 25 to35% with 2!C warming, which is the anticipatedwarming for early to mid-21st Century and more inthe scope of FERC licenses now under consideration.These results are not isolated. Vicuna et al. (2010),

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  • for example, used multiple global climate models(GCMs) to derive rainfall-runoff responses for thenearby Merced River, where averaged results indi-cated progressively decreasing streamflow releasesthrough turbines and corresponding increases inuncontrolled spills over the current century. Theimplication of this projected system behavior is thatto maintain hydropower generation and revenue nearhistorical levels, changes in operations will be madeto compensate for seasonal shifts and overall declinesin water supply.

    There are currently 54 such hydropower projectslicensed by FERC located in the western SierraNevada with 7.1 GW of potential generation capacityannually (see Supporting Information). These projectslicense 47% of the large dams in the western SierraNevada (n = 291) and include 110 powerhouses and826 km of water conveyances (i.e., ditches, canals,penstocks, and tunnels). Notably, there are 1,858 kmof rivers downstream from FERC projects, represent-ing 53% of all regulated rivers in the western SierraNevada. Not only does this hydropower infrastructurerepresent a vast economic investment but also clearlyplaces FERC projects and their regulation at the cen-ter of any adaptive solution to reconciling water andecosystem management, hydropower generation, andclimate warming.

    POOR REASONING

    The stated reasons by FERC for not explicitlyincluding climate change in the YBDS relicensingILP is two-fold: inaccuracy in climate change models,and the lack of a clear nexus between changinghydroclimatic conditions and project operations. Thelatter point refers to regulatory language that speci-fies commissioned ILP studies must be able to showhow licensed operations will impact a specificresource and how the issue will inform the develop-ment of license requirements. The reasoning used todetermine model inaccuracy, however, is less clear.

    As Girvetz et al. (2009) point out, most GCMs areoften too coarse for many scientific and planningquestions, but that is not to say that they are inaccu-rate. In fact, hindcasted hydrology from multipleGCMs has been resolved over decadal time periods tobe used in extensive detection and attribution studies(Hidalgo et al., 2009). However, questions remainregarding which of the GCMs should be used forregional applications, the method of downscaling, andthe distribution and any consensus among modelresults (see Pierce et al., 2009). Recent improvementsin downscaled regionally adjusted climate ensembles,

    when coupled with hydrological models, have repro-duced observed flows at relatively fine scales(!150 km2) (Vicuna et al., 2007), and are now beingused in relative risk assessments to water supply(Vicuna et al., 2010). These models are highly accu-rate, in that they reliably reproduce observed condi-tions over large areas and long time frames usingphysical principles, and thus one can conclude thatother factors, such as uncertainty or imprecision, arebehind FERCs reasoning.

    Although downscaled global climate and hydrologi-cal models both have uncertainty in their respectiveoutcomes (IPCC, 2008), uncertainty by itself is insuf-ficient to discount model findings as inaccurate. Tem-perature-driven impacts to the hydrological systemcan be anticipated with higher certainty than precipi-tation, as GCMs tend to agree on the direction oftemperature change if not the magnitude (IPCC,2007), but the source of uncertainty is complex.Uncertainty in climate change models can be parti-tioned into internal variability, model uncertainty,and scenario (i.e., emissions) uncertainty (Hawkinsand Sutton 2009). Internal variability refers in partto the natural fluctuations of a given climate, whichin the case of California is highly variable on sea-sonal and annual bases. This source of uncertainty isalready integrated into hydropower operations model-ing, presumably. Model uncertainty refers to the dif-ferent responses climate models have to atmosphericforcing and forecasts are often averaged into ensem-bles to reduce such uncertainty. Uncertainty in emis-sions scenarios, the third source, is the largestcomponent of overall uncertainty over longer timeestimates (Hawkins and Sutton 2009) and is com-pounded by the underlying socioeconomics of humanbehavior. For planning purposes, however, Hawkinsand Sutton (2009) found that overall uncertainty inclimate change models is minimized and model sig-nal-to-noise ratio is maximized at the 40- to 50-yeartime horizon, which is concordant with the issuanceof a FERC license.

    Regardless of inherent uncertainty in climatechange modeling and data coarseness, hydrologicalmodels themselves are generally accepted within theFERC relicensing process, and well used by most ifnot all water utilities for planning purposes. In fact,rainfall-runoff simulation modeling is sufficient forstate and federal governments to anticipate changesin operations and delivery in the coming decade(Christensen et al., 2004; Anderson et al., 2008).Thus, it is not the uncertainty or inaccuracy in cli-mate-driven hydrological models that concerns licens-ees. Rather it is the imprecision of these models, andtheir inability to specify a quantitative condition inthe future, that runs counter to FERCs charge underthe FPA, which is to provide surety to licensees.

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  • Thus, in its rejection of incorporating climate changeinto future hydropower operations licensing, FERC isconceding to the licensees lack of operational specific-ity under such conditions.

    A critical interpretation of the FPA and FERCsability to regulate is the project nexus. As describedby FERC (2005), they will consider studies in the ILPthat meet all of several criteria. Most notably, thenexus between project operations and the resource tobe studied must be identified, in addition to howstudy results would inform the development of licenserequirements. The clearest connection between cli-mate warming, hydrology, and subsequent alterationsto operations, and thus potential license conditions, isthe direct effect of extreme climatic events, such asdrought, on downstream receiving waters. In the caseof YBDS, 463 million cubic meters is expropriated perwater year on average, which if fully exercised intimes of prolonged drought, could leave many riversand streams barren. Knowing the likelihood and fre-quency of violating minimum instream flow condi-tions or water delivery contracts given futureclimate conditions would appear to be important andhave a clear nexus to operations. Indirect effectswill also impinge on downstream ecosystems. Withincreasing atmospheric temperatures, stream andreservoir inflow temperatures will also increasetoward equilibrium. Managing cold water releaseswill become more difficult, especially for smaller vol-ume reservoirs with limited cold water pools, or inreservoirs that increasingly fail to stratify in warmermonths due to reduced storage. While exceedancestudies for such conditions, and for potential retrofitsto outlet works to improve likelihood of meetingwater quality objectives, are not current standardILP practice, they do meet the many criteria imposedby FERC for consideration. Furthermore, when thebiological response to an exceeded temperaturethreshold is mortality, it appears misleading to sug-gest that a re-examination of the license condition isa sufficient remedy.

    RISKY DECISIONS

    The ILP focuses in part on the impact of hydro-power operations on downstream aquatic ecosystemsand recent relicensing efforts have resulted in opera-tional rules intended to minimize longer-term ecosys-tem impacts, such as incorporation of environmentalflows intended to maintain ecosystem condition (Kinget al., 2003; Arthington et al., 2006). While the focuson environmental flows in relicensing is worth-while, flow prescriptions are completely within the

    operational framework of licensees (i.e., flow releasesare dependent upon upstream reservoir storage, or inthe case of the Sierra Nevada, snowpack) and whollywith the underlying assumption of hydrological sta-tionarity. In other words, observed variability inhydrological records, however limited, is assumed tobe sufficiently robust to be used as boundary condi-tions for operations modeling into the future, andthus in the determination of downstream environ-mental flows and release schedules. It is an unfortu-nate assumption, and an inherently risky one, giventhat we now know that the future is not likely to looklike the recent past (Milly et al., 2008).

    In order to adapt to a climate warming alteredhydrology, an overall modification of the statewidewater distribution system is anticipated to maintaindeliveries (Tanaka et al., 2006). Further, SierraNevada hydropower systems are likely to alter thetiming of releases to maintain revenues (Madani andLund, 2007). However, it is not well known how spe-cific hydropower projects will need to adapt to chang-ing resource conditions (Madani and Lund, 2010).Therefore, it is risky to not explore the full potentialdimensions of future climate warming and hydrologicresponse. For example, a central component of ILPrelicensing efforts is an analysis of water year typesto define different operational rules for wet and dryyears in California there are very few normalyears based on the cumulative seasonal flow for a givenriver basin, and often indexed against a regional com-posite such as the forecasted Sacramento River Index(DWR, 2010). Dry year operating rules tend to favorhuman uses (e.g., hydropower, withdrawals fordomestic and agricultural consumption), whereas wetyears allow for more environmental flows. Aside fromthe assumption of stationarity in the hydrologicalrecord, it is conceivable that without any investiga-tion into climate change impacts on hydrologicalresponse operational rules would be set forth for thenext 30-50 years based on a wet year-dry year dichot-omy that will inevitably trend toward dry, due inpart to increased surface runoff during periods of sat-uration in snow dominated systems (Barnett et al.2005) limiting infiltration and subsequent subsurfacerunoff.

    POTENTIAL REMEDIES

    Poor reasoning and risky decisions aside, FERC isprobably challenged to meet its regulatory mandatewhile balancing many political and economic inter-ests. The scientific parsing of one given hydropowerproject is insufficient to alter an established process,

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  • such as the ILP; however, there are a few potentialremedies that could improve decision making and itsoutcomes. At minimum, FERC should mandate thatall hydropower licensing efforts include climatechange studies as a standard part of their review,and in fact the State of California requires suchreviews by all natural resource regulatory agencies(Schwarzenegger, 2008). The failure to comply withCalifornia Environmental Quality Act mandates foraddressing future environmental conditions is nowthe basis for Plumas County and Plumas CountyFlood Control and Water Conservation District vs.California Department of Water Resources (SuperiorCourt of California 2008), which points to the failureto address what is known today and exploration ofreasonable climate change-related impacts. Simi-larly, the preparation of National Environmental Pro-tection Act (NEPA) scoping documents, which areintended to represent a reasonably foreseeable rangeof alternatives for future operations, should include aclimate-impacted alternative. Perhaps in anticipationof future consideration, the Department of Interiorhas recently released Order 3289, which states theDepartment must consider and analyze potential cli-mate change impacts when undertaking long-rangeplanning exercises and making major decisionsregarding potential use of resources under theDepartments purview (Salazar, 2009). The fact thatit is not considered presently in NEPA preparationwill probably provide fertile ground for litigation inany relicensing effort going forward (Smith, 2008).

    More importantly, however, changes to the FPA areneeded to allow greater frequency in the review oflicense terms, to increase the aggregation of licenses,and to embrace regionalization of water operations.Through the implementation of ILP, we know thatthere will be negotiated changes to future operations ofYBDS and other such facilities. These changes will beintended to mitigate the adverse ecological effects ofriver regulation with a move toward natural flowregimes (Poff et al., 1997; Richter et al., 2003), andintended to ensure the public trust in sustaining natu-ral resources. We also anticipate that there will beclimate warming induced hydrological change. There-fore, it is reasonable to assert that fixed long-termlicenses are not in the publics best interest and a morefrequent review of license conditions is warranted.This point is further reinforced by several consider-ations reviewed by FERC (2001), including provisionsthat allow licensees to utilize status quo operationsduring periods of dispute that can be perpetuated todelay enactment of or reform to license conditions.Further, we can anticipate that the net benefits ofreoperation will necessarily be localized unless policiescan be adapted to encourage a broader geographicassessment of impacts and greater coordination of

    hydropower operations within basins. This aggre-gation of licenses would not only help minimize cumu-lative downstream effects of serial flow manipulationbut also minimize direct liability by any one licensee toprotect and enhance downstream resources.

    Lastly, changes in FPA should be made to allowlicensees and stakeholders to engage in regionaliza-tion, in which specific projects and water resourcesare assessed for their marginal benefit to the publictrust. For example, nearly all of Californias naturalruns of anadromous salmonids are on the brink ofextinction (Moyle et al., 2008), due in large part todams blocking migratory accesses to spawninggrounds (NMFS, 2009). Regional assessments of cli-mate warming impacts on hydrological response mayreveal that some basins are better suited for hydro-power delivery, while others at sustaining salmonpopulations. Given the recent Biological Opinion bythe National Marine Fisheries Service (NMFS, 2009),it is highly likely that FPA Section 18 prescriptionsfor fish passage will affect most if not all SierraNevada projects impairing reaches of historical sal-mon habitat. Individual licensees will not probablywant to solely bear the burden of fish passage andhabitat maintenance when such impairments arecumulative (Bezerra and West, 2005); thus, regionalor watershed approaches could help licensees propor-tionally share responsibilities.

    It is clear that FPA licensing is one of many con-cerns to hydropower operators, as regulators arebeginning to more rigorously enforce the federalClean Water Act 401(c) (see Pollak, 2007) and willcontinue to engage in the application of the federalEndangered Species Act 7 (see Wood, 2004). Thecurrent comingling of regulatory authorities, coupledwith decentralized decision making on a project-by-project ad hoc basis, makes regionalization difficult,but all the more important. The current situationsuggests that an independent body such as Califor-nias Independent System Operator for the energygrid or the Bonneville Power Authority for ColumbiaRiver operations may be needed to provide opera-tional and regulatory coherence and reliability to asystem of utmost socioeconomic importance. Further,future hydrologic and hydropower operationsresearch needs to focus on optimizing operations formultiple downstream demands and flow requirementswithin a nonstationary hydroclimatic framework.

    CONCLUSION

    Given the rapidity of climate warming, and its anti-cipated impacts to natural and human communities,

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  • it is reasonable to assert that long-term fixed licensesof hydropower operation that do not explicitly incor-porate a mechanism for adaptation are not in theinterest of the public or the environment. Further, itis reasonable to presume that some adaptation will benecessary given the magnitude of anticipated change.The current approach by FERC, however, is likely toresult in reactive adaptation with near-term, singleactor solutions held in the private domain. The publictrust would be better served by anticipatory adapta-tion with mid- to long-term, multiple actor solutionsheld in the public domain. The reason for this is thatthe licensing of hydroelectricity generation cannot beissued in isolation due to downstream contingenciessuch as domestic water use, irrigated agriculturalproduction, ecosystem maintenance, and generalsocioeconomic well-being. The stated policy of FERCis to issue licenses for the full 50-year term absentcompelling reasons to do otherwise (FERC, 2001,p. 99). In practice, FERC establishes conditions ofoperation for
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