Knoxville, Tenn. – Yesterday, April 8, 2019, the Southern Alliance for Clean Energy (SACE) submitted comments (link) to the Tennessee Valley Authority (TVA) on ways to improve the Draft 2019 Integrated Resource Plan (IRP). TVA is expected to finalize the plan later this year. SACE has a long history of participating in utility integrated resource planning, both with TVA and utilities across the southeast, and yet this year’s process stood out for some unfortunate reasons, namely a lack of transparency and the manipulation of data. Upon review of the draft plan, it is clear that TVA has manipulated data to reach their desired outcome: a continuation of the 20th century utility business model where utilities continue to ignore customer demands for distributed generation and energy efficiency and blindly build new large-scale fossil and nuclear. The comments submitted by SACE call on TVA to rebuild this IRP in a transparent and objective manner. If that request is not honored, SACE calls on the TVA Board of Directors to reject the IRP in its current form.
In past IRP processes TVA has worked with stakeholders and industry experts to provide TVA with current data on renewable and energy efficiency resources. The Draft 2019 IRP lacked meaningful details and data. Multiple stakeholders, including SACE, filed a request for additional documents and data under statutes from the National Environmental Policy Act (NEPA) and the Freedom of Information Act (FOIA). TVA delivered what can only be described as a “partial disclosure” with a little over three business days left in the comment period.
Despite the limited time given to review these documents and data, it is clear that TVA failed to objectively evaluate resource options in its Draft 2019 IRP. SACE outlines the most egregious errors in the comments we submitted to TVA on April 8, available at: https://cleanenergy.org/news-and-resources/sace-submitted-comments-on-tva-draft-2019-irp/. At a high-level, TVA assumed unrealistically high costs for potential new wind, solar, and energy efficiency and unrealistically low costs for potential new gas and nuclear resources. When these costs would not create the outcome they were looking for, TVA imposed arbitrary constraints on the model to limit solar and energy efficiency.
IRP processes should be transparent and involve stakeholders throughout the process. A successful IRP minimizes a utility’s total costs without limiting customer choice, leading to the lowest possible customer bills, not a myopic focus on rates or a patronizing focus on spending choices by private customers. A successful IRP evaluates the entire life-cycle cost of all resources, both supply and demand and both existing and potential. A successful IRP should be overseen by an engaged oversight body.
TVA states that its mission is “to improve the quality of life in the Valley through the integrated management of the region’s resources.” This IRP misses that mark. As a result, TVA appears poised to further downsize its investment in helping customers manage their energy bills and burdens, slow-walk or halt renewable additions, and continue to invest in old, expensive, inflexible resources.