TVA is proposing to add 200 MW of dirty fossil gas peakers at the Allen site in Southwest Memphis without acknowledging harm to the surrounding community or the availability of non-combustion alternatives.

On March 13, TVA released a flawed draft environmental impact statement (DEIS) for the proposed Allen Combustion Turbine peaker project in Southwest Memphis. The DEIS is based on an old and flawed Integrated Resource Plan (IRP), and TVA is choosing to prioritize its continuation with an antiquated technology over the fact that this technology will inflict environmental harm on the surrounding community. The National Environmental Policy Act (NEPA) requires federal agencies to “consider” the effects of proposed projects on the human and natural environment prior to final decision-making. A DEIS, which evaluates a proposal against alternatives and doing nothing, is one step in the NEPA process.

In this DEIS, TVA is proposing to drop 200 MW of what are essentially six GE LM2500 jet engines into the Southwest Memphis community, which has shouldered power generation and industrial pollution for decades. On April 28, SACE filed comments opposing these peakers, describing the harms the related emissions will cause, and outlining clean, non-combustion alternatives that TVA should use instead.

TVA is acting as if time has stood still since 2019. TVA either dismissed (based on embarrassingly outdated information) or ignored alternatives such as battery storage, renewables (including a robust number of projects languishing in TVA’s interconnection queue), transmission, and a myriad of demand-side resources. Instead, TVA proposes to meet its stated need with old technology that will spew NOx and deadly small particulate matter directly onto its neighbors. The DEIS reveals that this pollution will be significant whether the peakers are fired a little or a lot.

TVA has an unfortunate history of disregarding the health impacts of its actions on the very people it serves, and by continuing to pursue jet engine-style peakers in the South Memphis community, TVA is demonstrating that nothing has changed.

TVA could easily expand its program offerings to promote self-generation, reduce energy waste, and reduce demand with clean alternatives, but it refuses to do so. TVA clearly did not identify all available options, and instead proposes a project that will increase the pollution burden in the surrounding South Memphis community while committing TVA ratepayers to decades of fossil fuel price increases.

TVA listed a need for 200 MW of dispatchable power to meet load growth, increase flexibility and reliability, integrate renewables, fast dispatchability, voltage support, and black start capability in the event of a system failure. Battery storage can accomplish all of these tasks (and more, better, faster, cheaper), and there are 300 MW of battery storage projects already in the TVA queue in Shelby County. In addition, there are 1,425 MW of solar-with-storage projects waiting in the TVA queue in the counties surrounding Shelby County, including Hardeman, TN, Polk, MS, Marshall, MS, and Mississippi, AR. These are emissions-free dispatchable resources that could help TVA meet the needs identified for the Allen peaker project.

But instead of putting the effort into analyzing how best to meet the stated need, TVA is choosing to increase the pollution burden in Southwest Memphis, the community that continues to bear the burden of industrial polluters, including an oil refinery and TVA’s Allen coal ash and combined cycle plant. The community recently rallied to stop the Byhalia Pipeline and is bearing the brunt of the 35 “temporary” gas turbines powering xAI. Now, they are faced with yet another fossil fuel threat from the company they rely on to supply power to MLGW. By ending coal combustion and switching to gas combustion (starting with the Allen combined cycle plant in 2018), TVA may think that they are polluting the citizens of Southwest Memphis less, but in reality, they are only polluting them differently.

SACE has provided a robust discussion of the significant harm that NOx, PM2.5 and ground-level ozone will cause in the neighborhoods that surround the Allen site if these peakers are built. Those harms can be summarized visually in the following graphic prepared by Clean Energy Group:

In order to meet the stated need without harming Southwest Memphians, TVA should

– Start with energy efficiency and grow their demand-response programs
– Earnestly develop and procure clean renewable energy in the area
– Work to streamline the contracting and interconnection queue processes to bring clean resources on faster
– Consider energy storage technology at the Allen site and nearby with participation from the local community and guarantee of community benefits
– Use non-polluting grid stabilizing technologies such as advanced inverters

TVA does not actually serve very many individual people. It serves the local power companies that serve the individual people. It is insulated from the human-level consequences of its decisions. These consequences include billing arrearages due to rising rates driven by gas generation, high energy burdens, and direct contact with customers who have been physically harmed by power plant pollution. The local power companies bear these consequences. But, TVA ties the hands of local power companies and limits their ability to self-generate using cleaner, cheaper resources.

TVA can start to change its image as a large bureaucracy that is stuck in the past and out of touch with the people it serves by discarding this plan for 200 MW of polluting fossil generation, going back to the drawing board, and looking at the abundance of clean alternatives with fresh eyes. TVA can look at the list of needs it developed for this location on the grid in South Memphis and then assemble the renewable, battery and demand-side resources that can meet these needs. Rather than throwing one new dirty power plant at the myriad of needs, TVA should match the clean, renewable tools to each need. There are 300 MW of battery storage in the TVA interconnection queue in Shelby County. There are citizens who are eager to participate in rooftop solar and demand reduction programs that are appropriately compensated. There are large-scale solar and wind projects just over the Mississippi River in MISO territory and south of Memphis in Mississippi. All of these resources have the added cost savings benefit of sharing capital expenses in addition to eliminating reliance on dirty, increasingly expensive fossil gas.

TVA states in the DEIS that “Communities closest to the project area are most likely to experience adverse effects. Additionally, communities that are predominately (sic) minority or low-income would be more likely to be affected by the proposed action. However, impacts on communities would be minor overall.” (p. x) This last statement is hubris, and we demonstrate in our comments that it is patently untrue. The impact is significant and reason enough for TVA to withdraw this peaker project and replace it with emissions-free alternatives that improve the lives of Southwest Memphians rather than adding another layer of pollution burden.