SACE | Southern Alliance for Clean Energy

July 2014



1. TVA Considers Retirement of Allen Fossil Plant in Memphis

2. Mississippi Approves New Energy Efficiency Plans

3. What the Clean Power Plan Means for the Southeast

4. Atlanta Bikes for Solar Energy

5. A Fond Farewell to Our Coal Ash Intern

1.TVA Considers Retirement of Allen Fossil Plant in Memphis
Proposes replacement with a new natural gas plant in its stead

TVA’s Allen Plant

On July 2, the Tennessee Valley Authority (TVA) released a draft Environmental Assessment (EA) outlining its plans to retire the Allen Fossil Plant in Memphis and to replace it with a new natural gas-fired plant. We at SACE applaud TVA’s continued commitment to reduce its reliance on coal-fired energy and its efforts to reduce its overall contribution to carbon pollution. A 30-day public comment period for the Draft EA is now open and will close August 5. The ultimate decision will be voted on by the TVA Board at its upcoming August 21 Board meeting. Please stay tuned as we continue to dig into the draft EA and explore opportunities to work with TVA to ensure that replacement options utilizing renewable energy and energy efficiency resources are also considered.

The Allen plant is 55 years old and does not have sufficient air pollution controls needed to comply with upcoming air regulations for sulfur dioxide and hazardous air pollutants. Instead of moving forward with a plan to spend almost half a billion dollars to retrofit Allen, TVA has made the wise decision to retire the old and inefficient plant.

We were aware that the Allen decision was pending and SACE believes that TVA has a number of options available to it for replacement power. We see a tremendous energy efficiency resource that is currently underutilized in the Memphis market and believe that the Clean Line wind proposal and the continued availability of a strong solar resource all need to be factored into TVA’s replacement power decision.

Retiring Allen is great news for Memphians, who continue to struggle with the negative effects of poor air quality. Each year, the Allen plant emits thousands of tons of toxic air pollutants into the atmosphere that contribute to negative air quality across the region. In 2012, Memphis was number one on the Asthma and Allergy Foundation of America’s list of the “most challenging places to live with asthma.” Moving away from coal is the right decision for both public health and the environment and we are happy to see TVA embrace this choice.

SACE will be working on formal comments and developing talking points as we continue to learn more about TVA’s plans – so stay tuned!

2. Mississippi Approves New Energy Efficiency Plans
Mighty Mississippi takes a big step towards a cleaner energy future

On June 20, SACE submitted comments to the Mississippi Public Service Commission (MPSC) on its recent approval (Order Numbers 2014-0006-330141 and 2014-0010-330143) of two proposed Quick Start Energy Efficiency Plans (Docket Numbers 2014-UA-006 and 2014-UN-10).

The state’s investor-owned electric utilities, Entergy Mississippi and Mississippi Power Co., filed the proposed plans in January 2014 to meet the requirements of the MPSC’s Rule 29, which as we discussed in 2013, calls for the establishment of initial portfolios of three-year energy efficiency programs by the state’s utilities. The plans will be in place from mid-2014 through 2016, and the MPSC will review the resulting energy savings in its consideration of subsequent Comprehensive Portfolio Plans. SACE looks forward to actively engaging in that process and in future MPSC reviews of the programs.

The companies’ efficiency plans will help residential, commercial and industrial customers to reduce their electricity consumption through programs that provide incentives for efficiency investments such as heating and air-conditioning upgrades, improved insulation and air sealing, and the use of efficient compact-fluorescent and LED lighting.

We commend the companies and the MPSC for their efforts to quickly establish initial portfolios of energy efficiency programs, but it is worth noting that there are several areas for improvement in the specific plans that were approved. First, the energy efficiency impacts projected by the companies are very modest, and we recommend that the MPSC establish savings targets that, at a minimum, would put Mississippi on track to meet the energy efficiency goals recommended by the Environmental Protection Agency as part of its proposed Clean Power Plan for reducing the emission of carbon dioxide. We are particularly concerned that the approved programs’ energy efficiency impacts are expected to decline or remain flat in the final year of the Quick Start Plans.

We also provided information on several other topics, including: (1) best practices regarding the recovery of lost revenues, or lost contributions to fixed costs; (2) Quick Start program modifications and additional program offerings for the companies to consider in their Comprehensive Portfolio Plans; (3) sources of clear guidelines for evaluation, measurement and verification; (4) program flexibility guidance for the MPSC to consider as an alternative to the companies’ approaches to addressing over-subscription; and, (5) the importance of establishing a stakeholder working group to discuss the companies’ energy efficiency programs in a non-regulatory proceeding setting.

We are optimistic that Mississippi is building a robust framework for successful energy efficiency programs, and we will be enthusiastically monitoring future developments and providing input as the recently approved plans are implemented and reviewed. With a new path toward energy efficiency, Mississippi may have one less reason to be singing the blues.

3. What the Clean Power Plan Means for the Southeast
How EPA’s new carbon rules might affect our region’s energy

Released on June 2, the Clean Power Plan is EPA’s first regulation aimed at reducing carbon dioxide (CO2) emissions from existing coal-fired power plants. In recent blogs, we’ve provided a brief introduction to the Clean Power Plan, explained the energy efficiency implications of the proposed rule and told you about our meeting with EPA Region 4 and regional allies to discuss the rules impacts in the Southeast. This article offers a deeper dive into the Clean Power Plan and explains how it could affect our Southeastern states.

In 2012, over 366 million tons of CO2 were emitted from roughly 270 coal units at 82 coal-fired power plants across our 8 Southeast states. Overall, our Southeastern states contribute around 22% of our nation’s total annual carbon dioxide emissions – a disproportionate amount. Some Southeastern utilities, such as the Tennessee Valley Authority, Duke Energy and Georgia Power, have recently taken important steps to decrease their reliance on coal-fired power. The Clean Power Plan will help ensure that these utilities do not back-peddle on plans to retire coal-fired power plants and should help drive additional investments in renewable energy and energy efficiency measures across the Southeast.

The Clean Power Plan is built around Section 111 of the Clean Air Act, which uses Best System of Emission Reduction (BSER) to control a particular pollutant – in this case, CO2. (Learn more here about the history behind carbon regulation). When determining the BSER, EPA considers, among other things, the costs associated with reducing those particular emissions and technical feasibility for emission reduction.

Using this BSER methodology, EPA has determined four building blocks for how states can reduce their emissions system wide:

1) Increase efficiency of existing coal-fired plants

2) Increase utilization of natural gas

3) Increase utilization of renewables and nuclear

4) Increase the amount of energy efficiency

To be clear, states do not need to use each of these building blocks to comply with the Clean Power Plan. Instead, these four building blocks can be mixed and matched in different ways – giving states maximum flexibility in deciding how best to comply with the rule. EPA determined each state’s unique 2030 CO2 emission rate by calculating the amount of emission reductions each state could achieve through each one of these four building blocks. (Find out more about the EPA determination process here.)

Below are EPA’s proposed 2030 emission rates for our Southeastern states as well as their 2012 emission rates.

These state goals reflect the realities of how each state produced energy in 2012. For example, Kentucky’s percentage reduction of CO2 seems rather low, at 18%,, but still represents a measurable reduction in emissions for Kentucky as it currently relies on coal-fired power for 90% of its electricity.

In order to comply with the Clean Power Plan, states must develop a State Implementation Plan (SIP) that outlines a method to reduce emissions to the appropriate state CO2 emission rates, as well as how the state will measure and verify emission reductions. If a state fails to submit a SIP or submits an inadequate SIP to EPA for approval, EPA may develop a Federal Implementation Plan (FIP) for that state. Assuming the schedule goes according to plan, and not held up by litigation, states must submit SIPs to EPA in June 2016. EPA has allowed flexibility with this timeline, if states choose to submit regional compliance plans.

It remains to be seen how each state will craft its SIP. While much of the rhetoric in our region has been about the pain (in the form of higher bills) that this new rule will bring to the average customer, EPA actually estimates that if a state chooses to rely heavily on increased energy efficiency as a compliance method, customers will see a decrease in utility bills over time. We are hopeful that implementation of the Clean Power Plan will result in increased clean energy resources in the Southeast. Stay tuned for additional SACE insights as we continue to analyze the Clean Power Plan and work with our states to comply with the rule in a way that helps build a clean energy economy in the Southeast.

4. Atlanta Bikes for Solar Energy
Atlantans take a Tour Du Soleil during the city’s first bicycle festival

Riders discuss the Sunshot research panels at Georgia Tech. Photo: Cameron Adams

This piece was submitted by Alex Solomon, a new SACE member from the event.

What better way to see clean energy in action than by bike? On June 9th, I joined 63 helmet-clad Atlantans to learn about solar energy in Georgia. One of several events in the first annual Atlanta Cycling Festival, SACE’s Bike for Solar, also known as Tour de Soleil, took cyclists 7 miles through urban Atlanta neighborhoods to see 4 unique solar array installations.

The event kicked off at the headquarters of sustainable building non-profit Southface Energy Institute, just north of downtown Atlanta. Ride organizer Amelia Shenstone of SACE welcomed the assembled crowd alongside Georgia Public Service Commissioner Tim Echols and State Representative Scott Holcomb. All three voiced their strong support for making Georgia a leader in solar power.

Before mounting our bikes, we climbed up to the roof, led by Southface Commercial Fellow Christina Parkhurst. The headquarters feature high-efficiency recycled building materials, passive heating and cooling, 75% water conservation, and a green rooftop which offers both increased insulation as well as a tranquil setting for its employees to take breaks outside. In addition to being a LEED platinum facility, the roof features a solar array that is not only offsetting part of the facility’s energy consumption, but is in fact made of recycled materials itself, as the array was salvaged from a BP gas station under deconstruction.

Hopping on our bikes, we crossed the I-75/85 corridor to the west side of Atlanta. On the southwest corner of the Georgia Tech campus, adjacent to a Norfolk Southern rail line stands the Georgia Tech Carbon Neutral Energy Solutions (CNES) Laboratory. Over the din of the neighboring rail cars – carrying, among other things, coal – Brion Fitzpatrick of Inman Park-based firm Inman Solar provided an overview of the 296.4 kW array. The panels, made by Norcross’s Suniva (a company born out of Georgia Tech solar developments), provide enough energy to run all primary power at the lab. They are spread across the roof, the front face of the building and in parking lot canopies, which also provide shade. Before we departed, Joseph Goodman, Senior Research Engineer at CNES, displayed a prototype racking system for solar panels that is material-lean, and thus reduces capital costs, making solar even more competitive with other energy sources.

Next, along Atlanta’s new Beltline trail, we stopped by the Fourth Ward Skate Park to check out a unique solar installation by Atlanta based Hannah Solar. Affectionately named “The Stegosaurus,” due to the angled orientation of the panels in series, Hannah’s CEO Pete Marte noted the array powers 50% of the park and its efficient LED lighting system.

Our final stop on the tour took us to the Ashley Auburn Pointe Apartment Complex, where, as Dakin Spain of West Midtown-based Radiance Solar explained, the 140 kW array that sits atop the angled roofs of the mid-rise complex use half of their power to offset costs of common space power needs, while the other half is sold back to the grid through Georgia Power’s buyback program. The array features solar modules from SunPower that are some of the most efficient available.

The Tour de Soleil was sponsored by the Southern Alliance for Clean Energy, a regional non-profit advocating for energy choices that address climate change and create safe, healthy communities across the Southeast. The Atlanta Cycling Festival ran through June 14th and featured several events daily – all centered around biking. To learn more, visit You can see more pictures from the ride on Facebook here and here.

5. A Fond Farewell to Our Coal Ash Intern

EmilyCedzoSACE’s coal ash team is saying a fond farewell to our intern Emily Cedzo, who is moving on to continue her education at Duke University’s Nicholas School of the Environment, seeking a Masters in Environmental Management concentrating in Environmental Economics and Policy. When she came on board in May 2013, Emily dove head-first into our coal ash work; helping to plan and staff the first ever Southeast Coal Ash Summit, conducting research into census and demographics data around North Carolina’s coal ash sites, and helping to maintain our interactive website, Most recently, she’s been traveling across North Carolina to compile a photo library of communities and waterways impacted by coal ash dumpsites. Thanks for all your hard work, Emily, and best of luck in your graduate studies!