Cheatham County Generation Site EIS Scoping Report
Appendix C Summary of Scoping Comments
Tennessee Valley Authority
The proposed action alternative includes the creation of a 13-acre pollinator habitat site along Sycamore Creek. I would respectfully point out that the 13 acres referenced is probably already good pollinator habitat. However, if TVA believes it can substantially improve the existing pollinator habitats on this site, it should consider doing so as part of a solar park. The science of combining solar with pollinator habitat is now well developed and an entire service industry has grown up that provides this management service to solar facilities at costs like traditional solar site vegetation management. Assuming TVA will incorporate the criticisms and suggestions provided by commentators in this scoping process, it will publish a greatly improved DEIS for this project that offers a range of action alternatives. Among this range of action alternatives should be a 400MW battery storage facility with 900 MW of capacity provided by any combination of new renewable energy generation, energy efficiency, and Virtual Power Plant (VPP). Failure to do so would be both invalid and fiscally irresponsible. The May 2023 Lazard’s Levelized Cost of Energy Report estimates that unsubsidized utility scale solar combined with battery storage is always less costly than a gas peaking plant, and subsidized with the provisions of the Inflation Reduction Act may be 5X less expensive than the lowest cost gas peaking plant. Given that TVA has repeatedly expressed concerns that it must have flexible gas generation to “backstop” renewable generation it should undertake a study to specify how many MW of this backstop is required per MW of solar and publish its methodology and the results in a publicly available venue for peer review. Then TVA can formulate an action alternative that moves the TVA generation portfolio toward this scientifically determined ratio of flexible gas backstop and renewable generation. However, it is worth noting that many large utility grids across the USA have much higher percentages of solar and/or wind generation on their grid and have not experienced grid instability. (3) It is likely that TVA’s flexible gas generation assets already exceed whatever this scientifically determined ratio may be given the tiny fraction of solar and wind generation currently in the TVA generation portfolio. TVA has the entire concept backwards--the goal is not to build fossil generation to enable renewables installation, but rather, to install renewable generation to enable fossil retirement! At the open house Scoping session in Ashland City on June 21, 2023 I overheard a TVA employees told numerous citizens who asked why TVA is not pursuing more solar that they must install more gas to do so to maintain system reliability. This is contradicted by the 2023 Solar in the Southeast Report (4) that shows TVA is behind most of its peer utilities that have not experienced reliability challenges. Those employees also told citizens that supply chain disruptions prevented it from doing more solar. Yet this same report shows that solar installations were barely affected by the widely discussed supply chain challenges. As a result, TVA is forecast to fall even further behind most of its peers as they accelerate their solar installations at a much faster pace than TVA. When a farmer asked about Agrisolar options he was told that TVA would like to do more of that, but there is a shortage of sheep. While this is true, this is not the only possible Agrisolar option and a solar option which is not included in this scoping process would take years to implement during which one can be certain the supply of sheep will increase. Especially since a solar facility will have an expected operating life of 25-30 years duration. negative Joseph schiller
Cheatham County Generation Site_#164-003
7/6/2023
In this Cheatham County CT plant DEIS TVA again makes the claim it is building the “energy system of the future,” but instead it seems to be mired in the past. The DEIS cites the TVA “strategic plan document” which states emphatically that TVA is committed to applying the best science and technology to formulating its power planning, yet it ignores the international scientific consensus that inspired secretary general Antonio Guterres statements quoted above. I feel obliged to point out that the cited strategic plan document is redundant given that TVA is mandated in its charter to be an innovator in the application of the best science and technology in implementing its policies. The scoping document satisfies neither the letter nor the intent of the National Environmental Policy Act (NEPA) which requires all projects involving federal funds to explore all reasonable alternatives and to afford the public reasonable opportunity for comment on them. The current scoping document includes no action alternatives beyond the proposed natural gas combustion turbine (i.e., peaking) generating plant and 12-mile natural gas pipeline with a modest 100MW (400MWhr) battery storage. A no action and a single preferred action alternative do not constitute a set of reasonable alternatives! It appears that TVA is withholding other obvious action alternatives from consideration because it knows an objective socioeconomic and environmental analysis will find they are superior to the single preferred action alternative proposed. While TVA tries to distract the public by drawing attention to all the various environmental, social, and economic topics that are part of the EIS process, while failing to reveal they are obliged to look at all these factors across a range of reasonable alternatives. What does it matter if TVA analyses all these factors for only one action alternative? There is no possibility of arriving at a better solution than the single proposed action alternative. Other reasonable alternatives that could be considered include a combination of energy efficiency, solar and battery storage, purchased wind energy, and distributed solar and storage from virtual power plants (VPP). While TVA does include a 100MW (400 MWhr) battery storage system in the scoping proposal, and this is a step in the right direction, this battery would be more appropriately sited on the retiring Cumberland coal generating plant reservation, or in the nearby industrial park on the south side of Ashland City. There is no need to destroy a large block of forested and agricultural green space in a cynical effort to justify the construction of a new fossil generating plant and associated natural gas pipeline that will contribute to worsening climate disruption and disrupt the lives and environment of all the private landowners along its path. Further, as stated above, this storage component could be part of a second mixed resource alternative instead of part of this single preferred action alternative. Battery storage not coupled to renewable energy generation is counterproductive. The mixed resource alternative should include sufficient renewable generation to assure this battery storage is charged by pollution free generation. Given TVA’s limited renewable generation capacity, it is highly likely TVA will charge this battery with fossil and nuclear generation during off-peak hours instead of from renewables, thus actually causing even higher carbon emissions!
Cheatham County Generation Site_#164-002
7/6/2023
negative
Joseph
schiller
My name is Dr. Joe Schiller. I live in Montgomery County, on a commercial fruit and vegetable organic farm. I believe the proposed natural gas electricity generating plant to be built in Cheatham County, TN to replace lost generating capacity at the retired Cumberland Coal Electricity GenerationPlant in Montgomery is a violation of the public trust and common decency. I also believe theproposed scoping document is a clear violation of both the letter and the intent of NEPA. Beyond that, the scoping document is financially foolish because it does not include far more economical options. The planet, including the TVA region of the USA is already experiencing dramatically altered and destabilized climate impacts from the carbon emissions to date. Adding more sources of these emissions as proposed in this scoping document will accelerate and exacerbate this problem. This year has been one of the most financially challenging for our farm in the past couple decades. We had damage from winter storm Elliot, the late April frost, and excessive dry April winds this year. Our berry and fruit harvests are reduced, some of our spring vegetable and herb crops were stressed and we lost valuable timber, damage to buildings and significant landscaping damage. Many other people in the region experienced similar losses. Extreme weather events are a threat to everyone, but the financial risks are especially great for us farmers. Adding another major emission carbon emissions source given the current understanding of the precarious state of our planet’s climate system is reckless and unconscionable. The most recent report of the International Panel on Climate Change (IPCC) has stated unequivocally that no additional fossil fuel infrastructure should be built if we are to avoid unmanageable climate disaster.Recent public communications by UN chief Antonio Guterres emphasized the urgent actions needed to avoid climate disaster and that further fossil fuel development is “incompatible with human survival.” He went on to state “Current policies are taking the world to a 2.8 degree temperature rise by the end of the century. That spells catastrophe, yet the collective response remains pitiful. We are hurtling towards disaster, eyes wide open — with far too many willing to bet it all on wishful thinking, unproven technologies and silver bullet solutions.” TVA continues to ignore this message. TVA seems to think it can set the timeline for when it will transition to a carbon free energy system, but it is tragically mistaken in that belief—the earth’s climate system is what determines that timeline. negative Joseph schiller I frequently enjoy recreation in the area in question. The beauty and peacefulness found in the Sycamore Creek area is increasingly hard to come by. The established wildlife and woodlands are important to the area and to the state in general. I would ask that the agency please reevaluate the location of the proposed facility negative William Batchelor
Cheatham County Generation Site_#164-001
7/6/2023
Cheatham County Generation Site_#163
7/6/2023
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