EARTHJUSTICE PATAGONIA SAVE THE WORLD’S RIVERS
Michael Regan
Administrator
United States Environmental Protection Agency Office of the Administrator, Mail Code 1101A 1200 Pennsylvania Ave. NW
Washington DC 20460
Re: Patagonia et al. Petition for Rulemaking to add dams and reservoirs as a source category under the Greenhouse Gas Reporting Program
Dear Administrator Regan:
On March 21, 2022, Patagonia, Save the World’s Rivers (formerly Save the Colorado), and over 130 other organizations and businesses submitted a Petition for Rulemaking requesting that the U.S. Environmental Protection Agency add dams and reservoirs as a source category that must report emissions under the Greenhouse Gas (GHG) Reporting Program. Patagonia and Save the World’s Rivers respectfully submit the following comments regarding recent updates that are relevant to the Petition and GHG emissions from dams and reservoirs.
First, Patagonia and Save the World’s Rivers appreciate your recent comments at COP28 regarding the importance of addressing methane as a planet-warming greenhouse gas. We strongly agree with your statement that “[s]harp cuts in methane emissions are among the most critical actions the United States can take in the short term to slow the rate of climate change.” Your team at EPA, and the Biden Administration in general, deserve significant credit for launching the effort to “tackle super-polluting methane emissions,” and for extending that work with the new regulatory announcement at COP28.
Second, EPA’s focus on reducing methane emissions underscores why the agency should grant Patagonia’s Petition for Rulemaking and add dam and reservoir systems to the GHG Reporting Program. As the Petition explains, methane emissions from dam and reservoir systems across the planet have been estimated to be between 20%–80% of that of fossil fuels, as depicted in the graph below. Further, U.S. dam and reservoirs systems similarly emit large amounts of methane, both individually and collectively.
Moreover, as Patagonia and Save the World’s Rivers previously highlighted in supplemental comments submitted to EPA on December 12, 2022, EPA has taken additional actions since the Petition was filed regarding GHG emissions from dams and reservoirs. For example, in April 2022, EPA included methane emissions from reservoirs for the first time in its Inventory of U.S. Greenhouse Gas Emissions and Sinks. In addition, EPA announced last year that it was in the process of completing a four-year study of GHG emissions from reservoirs, which the agency was planning to complete in 2023. Granting the Petition for Rulemaking would complement these efforts and provide important additional data regarding GHG emissions from individual dam and reservoir systems.
Third, Patagonia and Save the World’s Rivers wish to provide EPA the following new supplemental information regarding the pending Petition for Rulemaking:
Over the last year, with financial support from Patagonia, an internal team of scientists created a new modeling tool named the “All-Res Modeling Tool,” which is the first of its kind to estimate the full lifecycle emissions of dam and reservoir systems. All-Res uses models created by government and university scientists (including those in the EPA and USGS), and published in peer-reviewed journals, for each emissions source category. All-Res then combines those models into a full lifecycle tool. The first application of the All-Res Tool was on the proposed Sites Reservoir in California, which estimated that the reservoir would produce the equivalent GHG emissions of over 80,000 gas-powered automobiles per year. The All-Res report regarding Sites Reservoir received a significant media hit in the Los Angeles Times.
All-Res’ lead scientist, Mark Easter, spoke at a side event at COP28 on December 11, 2023, and he discussed the Tool and the methane emissions caused by dam and reservoir systems. This side event was titled: “Hydropower as a false climate solution & Indigenous efforts to protect and restore rivers.”
If EPA accepts the Patagonia Petition for Rulemaking, we now have a methodology—the All-Res Modeling Tool—that can facilitate implementation for dam and reservoir operators in the United States. Further, this methodology would even be applicable in the states with the most stringent climate regulations, such as California, where the California Air Resources Board standards require a “full lifecycle assessment.”
Again, Patagonia and Save the World’s Rivers greatly appreciate your comments at COP28, as well as EPA’s actions addressing methane-caused climate change. This is why the Patagonia Petition for Rulemaking is so important—with dam and reservoir methane emissions potentially significant in comparison to those of fossil fuels, it represents a large blind spot in the Biden Administration’s policies addressing methane pollution. Without knowing where and how much methane is being emitted in the United States, it is impossible to accurately implement a strategy and policies that effectively reduce methane-caused climate change.
Thank you for considering the Petition for Rulemaking requesting that EPA add dams and reservoirs to the GHG Reporting Program. In addition, we request a meeting with EPA staff in the first quarter of 2024 to further discuss the necessity of adding dam and reservoir emissions to the GHG Reporting Program. A representative from Patagonia will be reaching out to you soon to schedule that meeting.
Sincerely,
Michael Hiatt
Deputy Managing Attorney Earthjustice, Counsel for Patagonia and Save the World’s Rivers
Gary Wockner
Executive Director
Save the World’s Rivers
Hans Cole
Vice President of Environmental Campaigns and Advocacy
Patagonia