Even though the Draft 2015 IRP prompts TVA to resume EE program growth, ultimately it falls significantly short of 2011 targets and fails to rely on best industry practices. Two of the biggest departures TVA made from EE industry practices were including growth caps and excessively high program cost assumptions. While it was reasonable for TVA to restrict the annual growth in energy efficiency programs at some level, utilities across the Southeast and the nation have recorded multiyear periods of annual growth rates that substantially exceed the restrictive caps used by TVA. TVA’s recent sensitivity analyses, undertaken concurrently with the public comment period, show that these EE growth caps improperly drive up system costs.
With respect to renewable energy, TVA’s Draft 2015 IRP does not demonstrate a full awareness of, and progress towards, emerging opportunities that would lower power supply costs and risks. While the Draft IRP supports a reasonable growth rate for solar resources (potentially around 2,000 MW), we are dismayed by the skeptical posture that the planning staff has taken towards recent low-cost solar deals, dismissing the broad market for low-cost solar power as an anomaly.
More disappointing is the response to data on the wind power market: TVA’s Draft IRP relies on inflated cost assumptions and outdated technology assumptions, resulting in little to no wind development and suggesting that TVA may soon exit the wind market entirely at the very time when other Southeastern utilities are deepening their investment. In fact, TVA’s sensitivity analyses show that if TVA accepts the availability of cheap, plentiful and reliable wind energy (particularly from wind powered high voltage direct current transmission), then wind resources will drive down customer costs and rates, becoming one of TVA’s leading energy resources as soon as the project can be completed.
TVA staff will now begin reviewing public comments submitted on the Draft IRP as well as comments on the accompanying Draft Supplemental Environmental Impact Statement (click here to view joint comments submitted by SACE and allies on TVA’s Draft SEIS). While this review is underway, the IRP Working Group and other TVA resource planning and advisory groups will continue to meet and work with TVA to address major concerns in the Draft IRP. Once TVA staff completes its tweaks on the Draft IRP, the Final 2015 and SEIS will be presented to the TVA Board of Directors for approval at its August Board meeting in Knoxville, TN. The TVA Board will also meet during the TVA IRP review period, in Huntsville, AL, on May 7th.
We will continue to provide updates on this process throughout the next stage of the TVA IRP process. Stay tuned!