Petition for rulemaking to add dams and reservoirs as a source category under the Greenhouse Gas Reporting Program

The petition argues that dams and reservoirs are significant sources of carbon dioxide, methane, and nitrous oxide, yet are currently excluded from the EPA's Greenhouse Gas Reporting Program (GHGRP). It highlights scientific evidence showing that some U.S. facilities, such as Lake Mead and Kentucky Lake, emit millions of metric tons of CO2e annually, sometimes exceeding emissions from fossil-fuel power plants of similar capacity. The petitioners contend that the current lack of reporting leads federal agencies, states, and utilities to incorrectly assume hydropower is a zero-carbon energy source, which may result in ill-informed climate policies and hinder the U.S. from achieving the Global Methane Pledge. The document identifies seventeen distinct emission sources within reservoir systems and urges the EPA to expand the GHGRP to include these facilities to improve data transparency and inform the transition to a truly clean electric sector.

• Dams and reservoirs emit substantial amounts of greenhouse gases, including carbon dioxide, methane, and nitrous oxide, through reservoir surface emissions and other points such as hydropower turbines, spillways, and downstream water discharges.
• Specific U.S. facilities demonstrate high emission levels: Lake Mead and Hoover Dam emit approximately 12.3 million metric tons of CO2e annually, while Kentucky Lake emits over 1.8 million metric tons of CO2e per year.
• A 2020 study indicated that dams and reservoirs in Ohio are the state fourth largest anthropogenic source of methane emissions.
• Reservoir surface emissions alone in the U.S. are estimated to account for at least 459 teragrams (millions of metric tons) of CO2e per year, a figure comparable to the overall GHG emissions of the U.S. agricultural sector.
• The petition identifies seventeen distinct individual sources and sub-sources of GHG emissions from dams and reservoirs, spanning industrial processes, energy, and land use and forestry sectors.
• Federal agencies, states, and utilities frequently operate under the mistaken assumption that hydropower is a clean, low- or zero-carbon energy resource, leading to incomplete information in climate policy decisions.
• The EPA has not added any new source categories to the Greenhouse Gas Reporting Program since 2010, despite the program's original principle that it should expand and evolve over time.
• Adding dams and reservoirs to the GHGRP is presented as a necessary step for the United States to meet the Global Methane Pledge, which aims to reduce methane emissions by 30% by 2030.

APA

Earthjustice (2022). Petition for rulemaking to add dams and reservoirs as a source category under the Greenhouse Gas Reporting Program. https://earthjustice.org/wp-content/uploads/patagonia_et_al_-_petition_to_add_dams_and_reservoirs_to_the_ghgrp.pdf

Chicago

Earthjustice. Petition for rulemaking to add dams and reservoirs as a source category under the Greenhouse Gas Reporting Program. 2022. https://earthjustice.org/wp-content/uploads/patagonia_et_al_-_petition_to_add_dams_and_reservoirs_to_the_ghgrp.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=Petition for rulemaking to add dams and reservoirs as a source category under the Greenhouse Gas Reporting Program |date=21 March 2022 |url=https://earthjustice.org/wp-content/uploads/patagonia_et_al_-_petition_to_add_dams_and_reservoirs_to_the_ghgrp.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjustice2022petition, author = {{Earthjustice}}, title = {{Petition for rulemaking to add dams and reservoirs as a source category under the Greenhouse Gas Reporting Program}}, publisher = {Earthjustice}, year = {2022}, month = mar, url = {https://earthjustice.org/wp-content/uploads/patagonia_et_al_-_petition_to_add_dams_and_reservoirs_to_the_ghgrp.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }