Cheatham County Generation Site EIS Scoping Report
Appendix C Summary of Scoping Comments
Tennessee Valley Authority
● TVA’s modeling should consider increasing transmission transfer capability and resources located outside TVA’s service territory. This could specifically include revisiting whether the Clean Line transmission connection to wind in Oklahoma is still a viable option. If so, the economic benefits of its impact on reliability should be included in the analysis. For instance, analysis by RMI showed that on December 23, 2022, the SPP market (which includes Oklahoma) experienced about 3 GW of wind curtailments.1 That is one of the days TVA had to implement rolling blackouts due to outages at coal and natural gas plants. Analysis by Grid Strategies showed millions of dollars of potential benefits to TVA customers for increased connections to the midcontinent Independent System Operator (MISO) and $1 billion in value for a 1 GW connection between the Electric Reliability COuncil of Texas (ERCOT) and TVA.2 So there are both economic and reliability benefits to TVA customers to increasing transmission capacity between TVA and neighbors. ● TVA has publicly stated that it is forecasting load growth that is much higher than what was studied in the 2019 IRP. The NOI for this EIS states that it is consistent with the 2019 IRP. Therefore, the modeling in this EIS should use load growth forecasts consistent with the 2019 IRP. If load growth has changed considerably since the 2019 IRP, then this is no longer consistent with the 2019 IRP and should not be performed separate from the 2024 IRP. In that case TVA should either wait until the 2024 IRP is completed to start this analysis, or fold this decision into the IRP, as we recommended earlier in these comments. ● TVA should model the EPA’s proposed rule regulating greenhouse gas emissions from new natural gas-fired sources, to ensure it does not make a terribly imprudent investment with TVA ratepayer dollars. On June 22, 2023, TVA’s CEO, Jeff Lyash, testified in Congress that TVA is trying to move its net zero goal forward as fast as possible, and that as it adds carbon-free resources it would use its natural gas-fired power plants, including the Cheatham project, less until they are only capacity resources. It is important that, as TVA evaluates the economic and environmental impacts of the Cheatham gas plant, that it use consistent and reasonable assumptions about how much the plant will actually be used. If TVA expects to use the Cheatham gas plant for only a few years, and operate it at low capacity factors after that, it will significantly impact the cost effectiveness of the project. If TVA expects to continue to use the Cheatham gas plant at levels that make it cost effective, it will likely have too high an environmental impact to be a reasonable investment. TVA cannot have it both ways: either the plant will be used often for a long time or it will not. To conclude our comments on the scoping of this environmental review, we again emphasize that this should not be a separate process at all, but a decision made as part of the larger IRP that TVA simultaneously began at the same time as announcing this project. Only if a project similar to the one proposed at Cheatham is consistent with the 2024 IRP should it move forward. The Southern Alliance for Clean Energy is using this part of the NEPA process to comment on TVA’s proposed generating additions at its Cheatham County site, as outlined in the Notice of Intent (NOI) to prepare an Environmental Impact Statement (EIS) published in the Federal Register May 19, 2023. The National Environmental Protection Act of 1970 remains an important regulation to evaluate the environmental impacts of actions taken by federal agencies. The NEPA process is not, however, a stand-in for a publicly accessible and transparent process that monopoly utilities should go through when making critical resource decisions. On the very same day that TVA published the NOI to start the NEPA process for this specific generator proposal, it also published an NOI that it is starting its 2024 integrated resource plan (IRP). How to replace the retiring second unit of the Cumberland coal plant is a decision best suited for an IRP, not a one-off set of analysis that is being done at the same time that the utility is doing an IRP. This is far from utility best practices, and is not something done in any other jurisdiction in the country. If there is such a need to decide how to replace Cumberland’s second unit in a process separate from the IRP, TVA needs to explain that in detail publicly, including in the scoping report for this NEPA process. Despite our concerns that this should not be a separate EIS, but instead incorporated into the IRP, we are providing the following recommendations if this must move forward as a separate EIS.
SACE Comment Letter_002
6/26/2023
negative
Maggie
Shober
37914
● The EIS should evaluate at least one alternative that does not include any new fossil fuel infrastructure of any kind, including frame and aeroderivative gas-fired and oil-fired combustion turbines (CTs). ● The EIS should use accurate assumptions on the capacity factors for the kinds of CTs evaluated, and that information should be presented in a transparent manner. If the usage of these new units is manually reduced when TVA models its system to produce results for this EIS, it will mask the ultimate environmental impact of the units. ● The EIS should include all incentives available through the Inflation Reduction Act (IRA), including direct pay of clean energy tax credits and the adders available as well as the Energy Infrastructure Reinvestment program (see program overview here: https://www.energy.gov/lpo/energy-infrastructure-reinvestment) ● The EIS should include potential specific transmission upgrades to facilitate any of the alternatives, and any additional benefits these transmission upgrades may provide, such as expanding the ability to interconnect solar and storage resources beyond the amounts considered in a clean energy alternative. ● The EIS should include analysis of how an increase in fuel costs and the variability of fuel costs could potentially impact low-income customers, since TVA passes its fuel costs on to customers. TVA should not ignore this impact because its local power companies (LPCs) are the ones billing customers. ● TVA should use the latest Social Cost of Carbon with proposed updated discount rates of 1.7% from the Office of Information and Regulatory Affairs (OIRA). In addition to these recommendations on the EIS specifically, we have the following recommendations for the modeling that TVA will perform to assess the economic and environmental costs and benefits of each alternative. ● TVA’s modeling should utilize accurate cost assumption forecasts from reputable and public sources that include all incentives, as well as a wide range of fuel cost sensitivities that take into account potential unknowable events like the impact the war in Ukraine has had on natural gas prices. negative Maggie Shober 37914
SACE Comment Letter_001
6/26/2023
Page 3 of 133
Made with FlippingBook - Online Brochure Maker