Cheatham County Generation Site EIS Scoping Report
6.1.8 U.S. Environmental Protection Agency NEPA
• In light of the Inflation Reduction Act (IRA), the USEPA recommends more than one action alternative be identified and considered. Reasonable alternatives could include a combination of peak shaving, increased generation from other production units to include renewable energy sources, energy efficiency, and demand management to meet capacity requirements. Under these requirements, the USEPA recommends: o TVA consider and incorporate new and emerging technologies that are more economically advantageous as the result of the IRA since the price of natural gas is projected by the Energy Information Administration to be higher than the estimate in the 2019 IRP. o That the EIS identify the timeline in which renewable buildouts will occur and the direct connections between that buildout and planned natural gas generation that TVA identifies as enabling of future renewable energy sources as the gas generation plants have been proposed without comparable renewable energy generation investment. o TVA should use the best available Social Costs of Greenhouse Gases (SC-GHG) estimates in the EIS and include a discussion of whether and to what extent the estimated GHG emissions from the alternatives are consistent with TVA taking action to help achieve science-based national GHG reduction targets. Air Quality & GHG Emissions • The USEPA recommends that the EIS alternatives analysis reflect alternatives consistent with meeting net-zero emissions goals laid out by the Administration, TVA’s own commitments, and the U.S. 2030 national reduction target in the Paris Agreement. The analysis should also: o Address Executive Order 14057, that establishes policy for the federal government to lead by example to achieve a carbon-pollution free electricity sector by 2035 and net- zero emissions by 2050. o Align with GHG reduction goals and policies, and o Disclose and discuss any inconsistency of the proposed action with State, Tribal or local plans or laws. Environmental Justice • Consistent with EO 14096, Revitalizing Our Nation’s Commitment to Environmental Justice for All, the USEPA encourages TVA to ensure protected populations are not disproportionately or adversely impacted by the project. • The USEPA also encourages compliance with EO 12898, by identifying and mitigating disproportionate impacts on minority and low-income populations. • The USEPA encourages the use of the EJSCREEN tool. Mitigation • Efforts should be made to consider plant designs with increased Carbon Capture and Storage (CCS) and hydrogen fuel blending technology to mitigate emissions.
20
Made with FlippingBook - Online Brochure Maker