Cheatham County Generation Site EIS Scoping Report
National Heritage Areas • The project is within the Tennessee Civil War National Heritage Area (NHA). National Scenic and Historic Trails
• In a letter dated June 16, 2023, the NPS noted that the CHG site is located within about 10 miles of the Northern Route of the Trail of Tears National Historic Trail (TRTW) at its closest point and that the NATT is within the NATR. The location of associated infrastructure and resulting impacts to National Scenic and Historic Trails should be disclosed in TVA’s EIS. • Nationwide Rivers Inventory • Sycamore Creek, Jones Creek and the Harpeth River are listed on the Nationwide Rivers Inventory administered by the NPS and they could be crossed by the approximately twelve-mile natural gas pipeline that is provided in the Action Alternative. National Register of Historic Places • The NPS notes that the Cheatham County Courthouse, Sanford Wilson House and St. Michaels Catholic Church are National Register listed historic properties within twelve miles of the CHG site, as well as other historic properties that may be affected by the project. TVA should complete compliance with the National Historic Preservation Act (NHPA), Section 106 in its analysis of the project, including identification of historic properties and the area of potential effects. Air Quality and Greenhouse Gases • The NPS notes that while cleaner than coal, natural gas-fired generation emits criteria air pollutants and just over half the amount of greenhouse gases (GHG) on a pound per megawatt basis as coal. Natural gas drilling, production, and transport also result in GHG emissions. The NPS recommends that these direct and indirect effects are qualified in detail in the EIS. • The NPS encourages TVA to increase the renewable component of their generation fleet mix to the maximum extent feasible when selecting power generation replacement options. • NPS notes that there is an urgent need to reduce GHG emissions and minimize dependence on fossil fuel-fired generation and recommends that TVA address how this action integrates with other related TVA proposals and how power generation replacement options across the entire system are consistent with guidance in E.O. 14008 and 14057.2. 6.1.4 Southern Alliance for Clean Energy (SACE) SACE provided scoping comments to address the potential environmental and economic impacts associated with the proposed project. In those comments, SACE requested TVA insert the following into the EIS: • Provide an additional alternative that does not include any fossil fuel infrastructure. • Utilize accurate assumptions on the capacity factors for the kind of CTs evaluated. • Include all incentives available through the Inflation Reduction Act (IRA). • Include potential specific transmission upgrades to facilitate any of the alternatives and any additional benefits these transmission upgrades may provide.
17
Made with FlippingBook - Online Brochure Maker