Cheatham County Generation Site EIS Scoping Report
• Include analysis of how an increase in fuel costs and the variability of fuel costs could potentially impact low-income customers. • Include the latest Social Cost of Carbon with the proposed updated discount rates of 1.7% from the Office of Information and Regulatory Affairs. Economic Modeling The SACE also recommended that TVA incorporate an assessment of the economic and environmental costs and benefits of each alternative by: • Utilizing accurate cost assumption forecasts from reputable and public resources. • Consider increasing transmission transfer capability and resources located outside TVA’s service territory. • Model the 2019 IRP for load growth forecasts. If these forecasts are no longer consistent with the 2019 IRP, TVA should wait until the 2024 IRP is completed. • Model the EPA’s proposed rule regulating greenhouse gas emissions from new natural gas-fired sources. 6.1.5 Southern Environmental Law Center • Through a joint letter representing the SELC, Appalachian Voices, Sierra Club, Tennessee Chapter Sierra Club, National Parks Conservation Association, Appalachian Mountain Advocates and the Center for Biological Diversity (collectively Conservation Groups), TVA was requested to extend the comment period an additional thirty days to allow the public the opportunity to engage. 6.1.6 Conservation Groups (SELC on behalf of Sierra Club, Appalachian Voices, Appalachian Mountain Advocates, and Cumberland River Compact) Conservation groups including Sierra Club, Appalachian Voices, Appalachian Mountain Advocates, and Cumberland River Compact submitted a joint comment letter. The main items raised in the letter are provided below: • TVA must not make a decision to move forward with a major new fossil generation asset without first completing the 2024 IRP. • 2019 IRP does not provide sufficient basis to support the proposed project or that it is the lowest system cost. • TVA must address the cost competitiveness of its preferred alternative relative to more affordable renewable and climate pollution-free options. • TVA must consider in the Draft EIS all reasonable alternatives, not only its preferred action and a no-action alternative. • TVA must not sever its own NEPA review of the gas plant from FERC’s NEPA review of the gas pipeline that the plant requires. • TVA cannot claim that the project is needed to integrate renewable resources without, at the very least, explaining what those resources are, where they would be located, and how they interact with the generation needs connected to this project.
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