The Southern Alliance for Clean Energy (SACE) respectfully submits these comments in response to the Tennessee Valley Authority’s (TVA) draft Environmental Impact Statement for replacement of the retiring Cumberland Fossil Plant (hereinafter referred to as the “Cumberland DEIS” or “DEIS”).
In the DEIS, TVA failed to accurately evaluate all options to replace Cumberland and skewed its analysis toward its desired outcome. If TVA moves forward with a new gas plant and pipeline, TVA’s customers will suffer higher electric bills and TVA will not be on track to decarbonize its grid by 2035 without significant stranded costs that must be borne by TVA customers. Replacing Cumberland with diverse, clean energy would lead to a more resilient grid and point TVA on a path that will ensure it fulfills its obligations to provide electricity to its customers at a low cost while safeguarding the environment and bolstering the regional economy.
SACE is a regional organization that promotes responsible and equitable energy choices to ensure clean, safe, and healthy communities throughout the Southeast. SACE’s members are concerned by TVA’s proposal to continue reliance on fossil fuels for decades, refusal to extend the comment period, and refusal to share documents used in compiling the DEIS. The comments submitted here do not cover the full array of shortcomings in the DEIS, but supplement the comments submitted by others by focusing on the following:
- TVA does not need additional gas to integrate renewable energy, and
- TVA failed to account for higher bills and energy burdens that would result from increased gas reliance and increased risk of stranded assets.
SACE calls on TVA to replace the Cumberland fossil plant with a combination of distributed and utility-scale solar, wind, and demand-side measures.SACE Comments to TVA on CUF replacement 06.13.2022