Southeast Sustainability Directors Network Urges the Tennessee Valley Authority to Strengthen Its Commitment to a Clean, Resilient Energy Future

December 6, 2024 – The Southeast Sustainability Directors Network (SSDN), representing more than 125 local governments dedicated to advancing sustainability across the southeastern United States, submitted comments yesterday to the Tennessee Valley Authority (TVA) regarding its 2025 Draft Integrated Resource Plan (IRP). SSDN’s recommendations focus on driving a stronger commitment to sustainability, transparency, and equity in TVA’s planning process.

“Our members set ambitious sustainability and emissions reductions goals as a way to improve quality of life, spur technology based economic development and save taxpayer dollars,” said Meg Jamison, Executive Director of SSDN. “TVA plays a vitally important role in helping communities across the Southeast reach those goals and our members want to work in close partnership with TVA to bring perspectives of our local governments to the table.”

SSDN sees the 2025 TVA IRP as an essential opportunity for the utility to position itself as a leader in clean energy. In its comments, SSDN emphasized the need for TVA to fully align its strategies with its 2050 net-zero carbon emissions goal, enhance investments in energy efficiency and demand response programs, consider the long-term implications of gas price volatility, and integrate Environmental Justice (EJ) principles into its decision-making process.

Highlights from SSDN comments include:

Energy Efficiency and Demand Response: An Untapped Resource

SSDN voiced concern that energy efficiency (EE) programs are underutilized within the draft IRP. TVA’s analysis suggests a narrow range of options, with energy consumption expected to rise alongside population growth in the Tennessee Valley. According to SSDN, TVA’s economic models undervalue EE compared to other utilities in the Southeast, with investments in EE steadily declining. A recent analysis by the Energy Future Group suggests TVA’s study may not fully capture the potential of EE and demand response (DR) programs to significantly reduce future capacity needs.

“To meet the energy demands of tomorrow, TVA must prioritize investments in energy efficiency and demand response initiatives, which are proven strategies for reducing energy costs and mitigating environmental impacts,” said Jamison. “SSDN calls on TVA to strive for 100% participation from Local Power Companies in offering EnergyRight programs and to provide more transparency in its $1.5 billion allocation for demand management efforts.”

Aligning Strategies with Net-Zero Goals

TVA’s carbon reduction efforts appear limited, with none of the draft IRP strategies aligning closely with TVA’s net-zero by 2050 goal. Although the retirement of coal plants by 2035 is a step forward, SSDN noted that emissions projections remain flat across all strategies after that date. To bridge this gap, SSDN urged TVA to incorporate more ambitious carbon reduction targets within its final recommended strategy.

SSDN also requested TVA provide data in a more accessible format to enable communities and stakeholders to assess the IRP’s impact comprehensively.

Managing Gas Price Volatility and Emphasizing Load Forecasting

TVA’s plan relies heavily on expanding natural gas infrastructure. SSDN emphasized the importance of including gas price volatility in risk modeling and load forecasting to minimize financial risks for TVA ratepayers.

“Reliance on new gas infrastructure without comprehensive risk modeling poses an unnecessary exposure for ratepayers,” added Jamison. “TVA should prioritize robust forecasting and economic modeling that considers the full financial implications of gas price volatility.”

Environmental Justice and Equity in Decision-Making

While TVA’s Environmental Impact Statement (EIS) includes a standard Environmental Justice (EJ) section, SSDN finds that the IRP lacks an evaluation of EJ or equity impacts across its strategies. SSDN stressed the need for TVA to consider site-dependent consequences, such as air and water quality, and to factor in community opposition when siting new facilities.

Increasing Transparency and Strengthening Public Engagement

Finally, SSDN advocates for enhanced transparency and public engagement, recommending independent cost assessments for new projects and clear documentation of public feedback incorporation.

“SSDN remains committed to supporting TVA in its journey toward a sustainable and resilient energy future,” added Jamison. “As TVA’s IRP process continues, SSDN members stand ready to collaborate and share insights on best practices that align with TVA’s vision of affordable clean energy for all.”