TVA is bypassing clean energy alternatives in favor of methane gas projects, violating NEPA and the TVA Act. Advocates demand lawful, transparent environmental reviews and alternative evaluations.

Yesterday, I gave public comments to the TVA Board of Directors at their quarterly listening session in Putnam County, TN. These sessions are one of the few opportunities for the public to speak directly to TVA leadership. Even though the board remains out of quorum until new board members are nominated by the President and confirmed by the Senate, a few dozen members of the public still showed up to speak, listen, and hold TVA accountable. And to their credit, the attending board members did listen.

I used my allotted three minutes to address a serious and ongoing failure in TVA’s environmental review process.

TVA is proposing one of the nation’s largest buildouts of methane gas infrastructure to meet growing energy demands. Instead of evaluating real alternatives to meet demands, like energy efficiency, demand response, or renewables with storage, TVA skips straight to its preferred option: more gas.

That’s not just bad policy – it’s a violation of federal law under the National Environmental Policy Act (NEPA), which requires agencies to rigorously explore a range of reasonable alternatives to major actions affecting the environment. It’s also a failure of leadership under the TVA Act, which tasks this Board with ensuring TVA operates in compliance with the law. With the anticipated Integrated Resource Plan on hold until a full board is present, objectively evaluating alternatives is even more critical.

TVA’s recent draft Environmental Impact Statement for the Allen methane gas expansion is a prime example. The stated goals—more capacity, flexibility, and renewable integration—are reasonable. But TVA didn’t seriously analyze any non-gas solutions to meet them. That’s not planning. That’s rubber-stamping.

It’s time for the Board to course correct. TVA must reevaluate its proposed projects and do what the law, the public, and our future demand: compare the actual environmental and economic trade-offs of real alternatives. Not just the ones that fit a fossil-fueled status quo.

You can read my full public comment below.

Oral Public Comments to the TVA Board

“I’m here today to urge the board to take action on TVA’s ongoing failure to examine alternatives in environmental review processes of proposed projects. Under NEPA, TVA is required to rigorously and objectively evaluate a reasonable range of alternatives to proposed major actions that significantly affect the environment. That’s not optional—it’s federal law. Under Section 831 of the TVA Act, the Board is to ensure that all activities of the TVA are carried out in compliance with applicable law. But in case after case, TVA ignores this duty, treating its preferred option as the only option while dismissing other viable paths despite serious financial and environmental risks.

TVA recently published the draft EIS for the Allen methane gas expansion. TVA says the project is needed to increase energy generation and capacity, improve year-round flexibility, and support renewable energy integration. But instead of evaluating a range of ways to meet those goals, TVA went straight to its preferred solution: More methane gas.

There are multiple ways to achieve these goals. Energy efficiency, demand management, energy storage, distributed renewables, and grid modernization can all help improve flexibility and reliability—often with lower costs and less risk. TVA failed to examine these options. Not seriously. Not at all.

Allen is just the latest example. TVA did the exact same thing with New Caledonia earlier this year, and is poised to do the same with Cheatham County. In each of these instances, TVA only examines the proposed, predetermined project, or in the alternative, nothing at all. This is malpractice, needlessly exposing TVA and its customers to financial and environmental risk. It’s inconceivable that TVA would commit billions of dollars without actually examining alternatives – without modeling, without cost comparisons, and without real transparency.

TVA claims resource planning happens in the IRP, and that site-specific alternatives are analyzed during the EIS process. But that’s not what’s happening. Gas is treated as a foregone conclusion from the start. The public is being told these decisions are data-driven, but what we’re actually seeing is a predetermined outcome wrapped in procedural language.

The board needs to change TVA’s course. TVA should complete a new set of analyses, starting with Allen, extending to Cheatham and beyond. TVA must compare the economic and environmental impacts of the projects with an actual range of alternatives. Our formal comment letter outlines these recommendations further.”