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Cheatham County Generation Site EIS Scoping Report

Appendix C Summary of Scoping Comments

Tennessee Valley Authority

TVA must extend the comment periods by an additional thirty days to allow the public the opportunity to engage in the least-cost inquiry TVA has refused to do. Third, the public also needs additional time to consider EPA’s proposed greenhouse gas regulations. During the comment period EPA proposed a lengthy, technical rule to reduce greenhouse gas emissions from new coal- and gas-fired power plants.14 Those regulations appear likely to apply to the Kingston and Cheatham gas plants, substantially altering the costs of new gas plants relative to emission-free alternatives. TVA has not included detailed discussion of the carbon mitigation technologies—hydrogen blending and carbon capture and sequestration—in the Kingston Draft EIS, Cheatham County Generation Site Notice of Intent, or any other public document. Commenters need additional time to evaluate the implications of the new EPA rule on the Kingston and Cheatham proposals. Fourth, the public needs additional time to study pumped hydro storage. TVA has only one pumped hydro storage facility, constructed by 1978. While framed as a programmatic EIS, TVA’s scoping notice identifies particular locations of likely pumped hydro storage projects. New pumped hydro storage was not modeled in the 2019 IRP, and it may have significant site-specific impacts on the local ecology, including to wildlife, land use, and water resources. The public needs more time to understand and comment on these and other potential impacts. For all these reasons, we respectfully request that TVA extend the deadlines by 30 days for Cheatham EIS, Kingston Draft EIS, and Pumped Hydro Storage Programmatic EIS comments. TVA Proposal Current Deadline Deadline Requested Cheatham County Generation Site June 27, 2023; July 27, 2023; Kingston Draft EIS July 3, 2023; August 2, 2023; Pumped Hydro Storage July 5, 2023; August 4, 2023 A 30-day comment period extension will help to ensure that interested parties have a meaningful opportunity to express their concerns. We appreciate your consideration and ask for a response not later than June 16, 2023. 14 EPA, New Source Performance Standards for Greenhouse Gas Emissions from New, Modified, and Reconstructed Fossil Fuel-Fired Electric Generating Units; Emission Guidelines for Greenhouse Gas Emissions from Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule, 88 Fed. Reg. 33240 (May 23, 2023), https://www.federalregister.gov/documents/2023/05/23/2023-10141/newsource-performance-standards-for-greenhouse-gas-emissions-from-new-modified-andreconstructed.

CONSERVATION GROUPS’ REQUEST FOR EXTENSION OF COMMENT PERIOD FOR THE CHEATHAM COUNTY GENERATION SITE ENVIRONMENTAL IMPACT STATEMENT (EIS), KINGSTON FOSSIL PLANT RETIREMENT DRAFT EIS, AND PUMPED HYDRO PROGRAMMATIC EIS___004

6/21/2023

negative

Trey

Bussey

Respectfully submitted, /s Trey Bussey Trey Bussey, Amanda Garcia, Chelsea Bowling, Daniel J. Metzger Southern Environmental Law Center

Appalachian Mountain Advocates tbussey@selctn.org, agarcia@selctn.org, cbowling@selctn.org, sbiggs@selctn.org, dmetzger@selctn.org Gaby Sarri-Tobar (Center for Biological Diversity), Amy Kelly (Sierra Club), Brianna Knisley (Appalachian Voices), Axel Ringe (Tn Chapter Sierra Club), Jeff Huter (National Parks Conservation Association)

My comments are also attached. Comments to TVA Regarding the Natural Gas Plant and Battery Storage System, Cheatham County, TN Submitted by Martha Wettemann, Ph.D, Public Policy and Administration Organization: Shine on Cheatham Mailing Address: 714 Darrow Drive, Pleasant View, TN 37146 Email: marthatsea@comcast.net Phone: 615-746-8916

TVA should extend the comment period. I was first notified of the June 21 public in-person open house in Cheatham County in the Ashland City Times on June 14, 2023. I attended this meeting, at which time I learned that any comments we wished to make had to be submitted by June 27, 2023, just 6 days after the Open House. The meeting was crowded and chaotic. There was not a specific presentation by TVA on this particular project; there were information posters all throughout the small room but they pertained to many aspects of TVA’s plans. It was hard to find the information on this specific project. I asked some questions of people who said they were TVA staff but who had nametags with just their name but no TVA insignia so how was I sure they were even answering for TVA? They also could not answer many of my questions. TVA should be working toward eliminating costly, polluting fossil fuel plants, not constructing new ones. We have a climate emergency due to the high levels of greenhouse gases in our atmosphere now! I recently returned from a trip to Hartford, Connecticut on June 8-10, 2023, during the time that fires were raging in Quebec, Canada, creating the worst air pollution in the world in New York City. We could see the smoke in Hartford, Connecticut. TVA must take more steps now to develop alternatives like energy efficiency, solar, and wind power, not produce more carbon emissions. I asked someone I assumed was a TVA representative at the Open House why they were including a battery backup system with the methane plant, since a methane plant could operate 24/7 without a battery backup. They explained that the battery backup was to support solar energy installations somewhere else on the grid. I then asked why they couldn’t install solar energy here at the Cheatham County site, since they were including a battery backup system. They said there was not enough land at this site to install enough solar. He did not answer how much land they would need. TVA needs to study and provide information to the public on the capacity of this site for solar and how much energy could be produced here with solar, and consider the alternative of solar on this site with battery backup. TVA should expand the scope of the study to a broader geographic area and look at other less polluting energy sources that this community needs and wants. NEPA regulations require the considerations of reasonable alternatives. A methane gas plant and pipeline are polluting and dangerous. Why should the residents of Cheatham County be exposed to the pollution and danger of a methane gas plant and pipeline while residents in another area reap the benefits of a clean solar installation backed up by our battery backup system? Where would the other solar be located? Is it environmentally just to locate a polluting methane plant in a lower-income area such as that around this plant may be while the solar installation may be in a more well-off area? TVA must reveal what and where the backup system is designed for. TVA must state whether there would be safety issues with a methane plant on the same site as a lithium battery backup installation. Any steps TVA has made to move ahead, such as agreements with pipeline companies, need to be disclosed at this point to the public. My brother worked for a pipeline company and I am well aware of issues that arise with maintenance. I asked a person at the Open House who said he was with TVA if pipelines were installed, who would be responsible for maintenance of the pipelines, as we know that lack of maintenance has caused pipeline breaches and environmental degradation at various locations in the country. He assured me that TVA would be responsible for their maintenance. TVA needs to specify if they would be responsible for maintenance or if they have already talked to others about handling pipeline maintenance and what qualifications they would require of anyone doing that. What would be the route of a proposed pipeline and would it impact any clean water sources? I request a draft copy of the EIS. Martha Wetteman

Comments Cheatham County Natural Gas Plant and Battery Storage - Shine on Cheatham_001

6/24/2023

negative

Martha

Wettemann

37146

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