Cheatham County Generation Site EIS Scoping Report
Appendix C Summary of Scoping Comments
Tennessee Valley Authority
The Lazard Levelized cost of Energy Report (2023) estimates that unsubsidized utility scale solar combined with battery storage is always less costly than a gas peaking plant.4 The independent and expert Synapse Report provided the Sierra Club on the switch to gas fuel for Kingston demonstrated the same savings (and emissions reductions). The DEIS should recognize these facts and choose a new, non-fossil fuel path as the agency preferred alternative. The DEIS must also consider the proposed EPA regulations on severely limiting fossil fuel emissions. The added cost of gas fueled infrastructure and the amount of energy that must be used to reduce emissions under these regulations make a shift to natural gas a costly, likely unaffordable choice of fuels. A 13 page EPA fact sheet is available at:
RE: Comments on the proposed Cheatham County Natural Gas Combustion Turbine Electricity Generating Plant and Pipeline NEPA EIS Scope_003
https://www.epa.gov/system/files/documents/2023-05/FS-OVERVIEW-GHG-for%20Po wer%20Plants%20FINAL%20CLEAN.pdf The Federal Register Notice5 is comprehensive and must be carefully considered and addressed in the DEIS before any switch to gas as a fuel can be seriously considered. So called “natural gas” is methane with a stink added to make it dete ctable by the human nose. It is a powerful Greenhouse Gas (GHG). The upstream releases from the extraction and transport of methane6 are well documented and must be acknowledged in the DEIS as a TVA contribution to GHG emissions and climate disruption. Both the proposed new Enbridge pipeline from Nashville to Kingston and the 12 mile long branch pipeline to fuel the combustion turbine in Cheatham County will have ONLY TVA as a customer. TVA is primarily responsible for the impacts of the construction and operation of this pipeline, root and branch. The DEIS must recognize this and justify this huge infrastructure expense, the disruption of installation and the long term impacts on nearby residents. As an attorney, I speak with landowners along the route. Those I talk with are fearful and angry at the idea of a pipeline that runs near their homes sometimes as close as a few feet and destroys their kitchen gardens and landscaping. 4 https://www.lazard.com/research-insights/2023-levelized-cost-of-energyplus/ 5 https://www.federalregister.gov/documents/2023/05/23/2023-10141/new-source-performance-standards-for-greenhouse-gas-emissions-from-new-modified-and-reconstructed 6 Upstream impacts include air pollution, water pollution from fracking waste ponds, and the documented impacts on health. https://www.fractracker.org/resources/oil-and-gas-101/health-environmental-effects-of-fracking/ negative Brian Paddock 38501
6/27/2023
“Assessment Report (AR6), [is] an eight-year long undertaking from the world’s most authoritative scientific body on climate change. Drawing on the findings of 234 scientists on the physical science of climate change, 270 scientists on impacts, adaptation and vulnerability to climate change, and 278 scientists on climate change mitigation, this IPCC synthesis report provides the most comprehensive, best available scientific assessment of climate change. “It also makes for grim reading. Across nearly 8,000 pages, the AR6 details the devastating consequences of rising greenhouse gas (GHG) emissions around the world — the destruction of homes, the loss of livelihoods and the fragmentation of communities, for example — as well as the increasingly dangerous and irreversible risks should we fail to change course.” 3 TVA will not be exempt from the consequences of its shift to gas and its failure to provided leadership which recognizes the necessity of a dramatic change in how we generate electricity will besmirch its reputation for a thousand years. TVA operations will face ever more extreme weather. Tornados and fires, will destroy TVA facilities and customers homes and businesses and the TVA and LPC grids while floods, and drought will challenge its dams. The tiny amount of battery storage suggested ignores the need for long term time shifting and sufficient DEI storage to ride out extended black outs. The very first Integrated Resource Plan stakeholder committee (which I served on) recommend an additional large pumped storage facility which was included in the final IRP. TVA made one feint at proposing some pumped storage in Sequatchie County and gave up when there was resistance. Now TVA would have environmental allies to explain the importance of pumped storage using mountaintops already flattened by “cross-ridge” (mountain top removal) strip mining. As the EPA explained in its letter to TVA addressing the Kingston DEIS, solar plus storage for replacement electricity would cost billions of dollars less. These dollars come from ratepayers. I reviewed the TVA Notice and am quite surprised that the only Alternatives will be “No Action” or build a 900 MW combustion turbine with some battery storage and a “Natural Gas”pipeline with decorations like a pollinator habitat. This an ill informed and clumsy way to approach considering the need, if any, for additional generation to replace coal fueled generation at this location. This narrow binary view ignores several significant factors that must be considered and analyzed to comply with the National Environmental Policy Act (NEPA) and the policies laid out by the Council on Environmental Quality (CEQ). The Citizens Guide to NEPA - Energy1 suggests: “Comments that contribute to developing alternatives that address the purpose and need for the action also are effective.” Accepting this guidance my comments follow. TVA must carefully analyze its demand projections. The touted “nearly” 2½% aggregate increase from “2020 to 2022" is not a predictor of future demand. Once you have scientifically quantified a projected demand and explained this in the Draft Environmental Impact Statement (DEIS) you can fully explain how much of this increased demand might be avoided by energy efficiency programs which TVA appears to have largely abandoned for industrial and commercial end users.2 Certainly choosing to generate by using methane with its associated fuel cost adjustment added to our electric bills will convince consumers to install energy saving appliances and add behind the meter solar with help from the Inflation Reduction Act. (IRA) Hedging on gas prices is not enough. It is time to protect consumers from gas price increases and use fuel cost free renewable energy generation. 1.https://ceq.doe.gov › docs › get-involved › citizens-guide-to-nepa-2021.pdf A Citizen's Guide to NEPA - Energy 2 The TVA program for home energy efficiency is based on modeling which suffers from garbage in - garbage out. I challenge TVA to go out and read the meters at locations which TVA that made over for energy efficiency. I will be glad to put you in contact with an expert who has documented several of these projects which now use more energy than the business or home used previously course, the worst offense of a shift to natural gas rather to renewable energy and storage is the contribution to irreversible climate disruption. I read the warnings from the Intergovernmental Panel on Climate Change (IPCC). I doubt anyone at TVA has - you can find them here: https://www.ipcc.ch/reports/ . The time to STOP all fossil fuels use and emissions is NOW as fast as possible. Shifting to years of further carbon emissions is irresponsible and destructive. TVA is supposed to assure low cost electricity according to the TVA Act and TVA’s boast. 3 https://www.wri.org/insights/2023-ipcc-ar6-synthesis-report-climate-change-findings
RE: Comments on the proposed Cheatham County Natural Gas Combustion Turbine Electricity Generating Plant and Pipeline NEPA EIS Scope_002
6/27/2023
negative
Brian
Paddock
38501
RE: Comments on the proposed Cheatham County Natural Gas Combustion Turbine Electricity Generating Plant and Pipeline NEPA EIS Scope_001
6/27/2023
negative
Brian
Paddock
38501
Hello, I am a resident of Cheatham County and am writing to give my comment on the proposed 12-mile pipeline and combustion plant currenting being planned for your site in Ashland City. I strongly oppose the construction of any fossil fuel related pipelines or activity. We moved to Cheatham County because we love the creeks, the Cumberland, wildlife, and quiet. We especially love to paddle Sycamore Creek. This creek is currently "healthy" by EPA standards, and is actually on the Nationwide Rivers Inventory list, a registry of exemplary scenic and recreational streams. Just yesterday, we saw turles, fish, deer, beaver activity, hop hornbeam, elderflower, sycamores, not to mention the other paddlers and fishermen enjoying the beautiful stream on a hot summer day. A pipeline
Public comment on the Cheatham County pipeline
6/26/2023
negative
Caroline
Hutchins
and combustion plant puts this all in jeopardy. I strongly advocate for solar and wind in lieu of fossil fuel. Fossil fuel use is short sighted, both economically and environmentally. My neighbors and I will be putting up a fight to stop this pipeline. We'd happily welcome solar and wind. Thank you for your consideration
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