LIHI Fee Structure
Below is the current LIHI Fee Structure. These rates are effective January 1, 2023 through December 31, 2023.
|Intake Review Fee||$1,200|
|Application Review Fee||Reviewer Fee as estimated in intake + administrative overhead. Subject to supplemental fee to complete review if necessary.|
Rate ($/MWh) * AAG (Average Annual Generation)
Base Rate: $0.02
Market Participant Rates: Only applied to the portion of generation qualified for RPS, Green-e, or other market.
All Others: $0.035
Remainder of generation is charged at the Base Rate.
Minimum Fee if capacity is less than 250 kW: $250
Minimum Fee if capacity is 250 kW - 499 kW: $500
Minimum Fee if capacity is 500 kW - 999 kW: $750
Minimum Fee if capacity is 1.0 - 4.999 MW: $1,000
Minimum Fee if capacity is 5 MW or greater: $1,500
Maximum Fee: $34,333
|Active Condition Fee||$0-$1,000 per condition. Paid annually until condition is satisfied.|
|Recertification or Mid-term Review Fee|
Stage 1 or Initial Mid-Term Review: $2,000
Stage 2 or Full Mid-Term Review if needed: $0-$10,000 +.
Note: Effective January 1, 2022, minimum fees were reduced for facilities up to 1 MW capacity. Calculated annual fees (base rate and market rates) and the maximum fee increased by the annual 2% escalation factor set in 2018.
LIHI Fee Structure Overview
The fees that LIHI charges to applicants and Certificate holders include fees associated with application review as well as annual fees to maintain an active LIHI Certificate. There are three parts of the LIHI Application Process, each involving a separate fee component.
- The initial intake review, which allows the applicant to submit a questionnaire and receive a preliminary confidential review of the facility as well as a cost estimate to proceed with a formal LIHI application.
- The formal LIHI application review, which is published for a 60-day public comment period. The date that a full application (complete application and fee) is received becomes the Certificate Effective date if the Certificate is issued. Applications are posted for public comment as soon as possible after receipt of the full application.
- The Recertification review. Typically, the term of a LIHI certificate is ten years, although there are opportunities for longer terms under certain conditions. Approximately six months prior to the expiration of the current term, the facility owner is invited to apply for recertification.
Intake Review Fees
Intake Review fees are a flat rate as published above.
Full Application Review Fees
The fee charged for review of the full application for LIHI Certification will be calculated during the intake review process. The review fee is a combination of the Reviewer cost estimate plus LIHI overhead.
Recertification or Mid-Term Review Fees
All facilities seeking to renew their Low Impact Certification are subject to a Recertification review fee. Facilities requiring a Mid-Term Review are also subject to a Mid-Term review fee. The review fee includes an initial flat fee of $2,000 to cover the first stage of the Recertification application review (Stage I) or initial Mid-Term review. The result of the Stage I or initial Mid-Term review will be a report on the recertification application or Mid-Term summary, accompanied by an estimate of the incremental cost for completing a Stage II recertification or full Mid-Term review, if required. The incremental cost will be facility-specific, ranging from zero to several times the Stage I or Mid-Term fee.
Annual fees are based on the average annual generation (AAG) of the certified facility multiplied by a $/MWh rate. LIHI will bill all certified facilities an annual fee for each year of the certificate term, including the year in which a facility applies for recertification. Annual fees are retroactive. For example, if a Certificate’s effective date is July 1, 2020, the first annual fee will be invoiced in June of 2021 covering the year from July 2020 to June 2021.
The annual fee rate for each certified facility will vary according to the facility market-participation category. LIHI has created two market participation categories: Verified-Market Participants (VMP) and Base Fee. VMP facilities are those that are publicly listed as a supplier of eligible generation for a state Renewable Portfolio Standard (RPS) program, a Renewable Energy Standard (RES) program, or other similar policy which utilizes the LIHI Certification standard as part of compliance. In addition, LIHI certified facilities generating Green-e certified products will be included in the VMP category.
Verified-Market Participants will be charged according to the market rate schedule published above for the portion of annual generation that qualified for the RPS or similar program at the VMP rates above.
The Base Fee category rate applies to all other certified facilities and to the portion of generation not eligible for participation in a market for VMP facilities.
There are minimum and maximum fees as posted above.
Active Condition Fee
LIHI Certificates may be issued with facility-specific conditions, with which the facility must demonstrate compliance. An Active Condition Fee may be charged for each of these facility-specific conditions for each year the condition remains active. Condition fees are also retroactive and billed with the annual fee. The purpose of condition fees is to recover the cost to LIHI associated with monitoring compliance with active conditions. The fee will range from $0 and $1,000 per condition per year and will be determined by LIHI based on the complexity of the condition and necessary monitoring and follow up.
History of the Fee Structure
Until 2014, LIHI had not significantly altered the Certification Program fee structure since its inception in 1999, even though the program had expanded significantly. At that time, LIHI had issued 116 certificates, totaling close to 5.8 GW of installed capacity. From 2012 to 2014, the Governing Board studied the effectiveness of the fee structure and determined that it did not adequately recover the costs of operating our certification program. This problem related in part to the large number of small facilities that applied for certification. Managing the program and providing services that enhance the value of the LIHI Certificate requires a consistent and predictable revenue stream that can attract and maintain qualified professional staff and consistently return value to all stakeholders. Adequate revenue is necessary to improve value to LIHI certificate holders by allowing staff necessary resources to work to expand the visibility and recognition of the LIHI brand and expanding the markets where LIHI Certificates are recognized.
The changes to the LIHI Certification Program fee structure were designed to allow LIHI to better serve our certification partners, to recover the costs of certifying hydropower facilities of all sizes and create more transparency between costs and fees, to engage in public discussion of the role of hydropower in renewable markets, and to move the Institute into a stronger, more sustainable financial position. The new fee structure was also designed to better align fees with the value that LIHI Certified<sup® facilities realize when they participate in the renewable markets of today. The fee changes were also sensitive to the challenges some certified facilities face in attempting to monetize the benefits of the LIHI Certificate.
The process of revising the fee structure included outreach to a representative sampling of current LIHI Certificate holders, as well as expertise and guidance provided by our Renewable Market and Hydropower Industry advisory panels. The outreach process began in the spring of 2014, and the revision underwent a series of modifications that were responsive to the suggestions offered from stakeholders.
In 2020, the annual fee base rate, market rates, and maximum fee were increased by 10%. Thereafter, these fees increase by 2% per year. Application fees, condition fees and minimum fees were not changed in 2020.
In 2022, minimum annual fees were reduced for facilities less than 1 MW capacity.
In 2023, the application intake review fee was increased for the first time since 2013.