Bobby L. Rush, Chairman
House Subcommittee on Energy
House Committee on Energy & Commerce
2125 Rayburn House Office Building
Washington, DC 20515
Fred Upton, Ranking Member
House Subcommittee on Energy
House Committee on Energy & Commerce
2322 Rayburn House Office Building
Washington, DC 20515
Re: Hydropower Licensing Reform and Greenhouse Gas Emissions from Hydropower Facilities
Dear Representatives Rush and Upton:
Thank you for hosting the May 12, 2022 hearing on “Modernizing Hydropower: Licensing and Reforms for a Clean Energy Future,” before the Subcommittee on Energy of the Committee on Energy and Commerce. Earthjustice appreciates the Subcommittee’s focus on increasing the role of Tribes and Native groups in hydropower development, and the recognition that hydropower facilities cause significant harms to fish, wildlife, and ecosystems.
Unfortunately, several participants at the hearing incorrectly characterized hydropower as a clean, carbon free resource. This is not the case. A growing body of scientific studies over the past two decades have established that dams and reservoirs produce and emit substantial amounts of carbon dioxide, methane, and nitrous oxide.1 These greenhouse gas (GHG) emissions include reservoir surface emissions, which occur when dams trap organic material and leached synthetic fertilizers that decompose beneath a reservoir’s water. Dam and reservoir operations also emit GHGs from several other emission points, including hydropower turbines, spillways, and downstream discharges.
Some individual facilities emit large amounts of GHGs, at levels equal to or greater than the GHG emissions from equivalent coal- and gas-fired power plants. For example, a scientific study shows that Hoover Dam and Lake Mead emit approximately 12.3 million metric tons of carbon dioxide equivalent (CO2e) annually, while Kentucky Lake annually emits over 1.8 million metrics tons of CO2e.2 Moreover, the collective GHG emissions of dams and reservoirs are significant. Notably, a 2020 scientific study co-authored by a U.S. Environmental Protection Agency (EPA) researcher estimated that reservoirs in Ohio are the state’s fourth largest anthropogenic source of methane emissions.3
On March 21, 2022, Earthjustice submitted a rulemaking petition to the EPA requesting that the agency add dams and reservoirs to its Greenhouse Gas Reporting Program.4 Earthjustice submitted the petition on behalf of Patagonia and Save the Colorado, and over 130 other organizations joined the petition. The petition requests that EPA require dam and reservoir facilities—including hydropower facilities—to report their annual GHG emissions to EPA and the public. This reporting will allow regulators, policymakers, and the public to have access to accurate and timely information on these facilities’ GHG emissions. Requiring dams and reservoirs to report their GHG emissions will also ensure that federal and state agencies and utilities make decisions on the future of the electric sector based on the best available information regarding hydropower’s GHG emissions, and not risk inadvertently pursuing a clean energy future that is not actually clean.
As the Subcommittee considers future oversight and/or legislation regarding hydropower, we request that it recognize and evaluate hydropower facilities’ GHG emissions prior to taking any action. Continuing to disregard this issue would ignore an important factor regarding future hydropower decisions and further exacerbate the climate crisis.
A copy of the rulemaking petition to EPA is attached, and we are happy to provide additional information on this issue.
Sincerely,
Michael Hiatt
Senior Attorney
Earthjustice
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2
Laura Scherer & Stephan Pfister, Hydropower’s Biogenic Carbon Footprint, PLoS ONE (Sept. 14, 2016)
4
Petition from Michael Hiatt, Earthjustice, to Michael Regan, Adm’r, EPA (Mar. 21, 2022)