TVA’s proposed combustion generators in Mississippi can be a big supply of carbon and excessive social prices. Grid-scale battery storage is definitely positioned to assist grid integration of extra renewables.
Shelley Robbins | September 4, 2024
| Fossil Gasoline, Mississippi, Utilities
Solely July 22, 2024, the Tennessee Valley Authority (TVA) issued a Draft Environmental Affect Assertion (DEIS) for the New Caledonia Pure Gasoline Plant, a challenge to be situated in Lowndes County, Mississippi. This was performed in accordance with the Nationwide Environmental Coverage Act (NEPA), which requires federal companies akin to TVA to “contemplate” the results of proposed initiatives on the human and pure setting previous to ultimate decision-making.
The challenge in query is a peaking dual-fuel (fossil fuel and distillate gasoline oil) plant consisting of six easy cycle body combustion generators totaling roughly 500 MW. The acknowledged objective of the proposed motion is to “assist continued load progress inside the Tennessee Valley in a manner that’s according to the suggestions within the 2019 Built-in Useful resource Plan (IRP)… whereas facilitating the combination of renewables onto the grid, thereby advancing TVA’s decarbonization targets. The 2019 IRP advisable the addition of as much as 5,200 MW of CTs by 2028…. The addition of CT items to the fleet was advisable to reinforce system flexibility to combine renewables and distributed assets.” (DEIS, p. 3)
The DEIS assesses solely two eventualities: constructing the peaker plant (the Most popular Various) and not constructing the peaker plant (the No Motion Various). The DEIS states “The Proposed Motion aligns with the 2019 IRP.”
TVA is counting on a doc that’s greater than 5 years outdated. That is basically inappropriate as a result of the coverage, financial, and technological assumptions are now not even remotely correct and legitimate.
Moreover, TVA is at present within the technique of updating its IRP – presumably to be launched by the top of this month (September, 2024). TVA mustn’t design a challenge to satisfy a useful resource plan want based mostly on a doc that’s now not related.
SACE filed feedback on September 3, 2024 figuring out a number of extra flaws within the DEIS.
1. Battery Storage Is Not Thought of as an Various State of affairs
The DEIS doesn’t talk about battery storage as a substitute, even supposing battery storage would meet the necessity even higher than the Most popular Various, the five hundred MW peaker. If peaking assets are wanted within the area resulting from real-time load progress and the deliberate addition of renewables, then battery storage ought to be evaluated for the positioning. Batteries are much more nimble than easy cycle combustion generators, and so they can carry out stabilizing and supportive features for the grid far past simply peak energy. Batteries are additionally a higher deal for TVA’s ratepayers as a result of 1) they aren’t topic to gasoline worth fluctuations and a pair of) they’re eligible for IRA tax credit and direct funds. Additional, a battery storage challenge at this web site might in all probability be constructed and introduced on-line quicker than combustion generators.
TVA based mostly its characterization of battery storage prices on the 2019 IRP, when grid-scale installations had been uncommon. Rather a lot has modified since that IRP was drafted, as illustrated on this chart of Giant Scale Battery Storage Additions within the US between 2012 and 2021.
The Vitality Info Company (EIA) expects battery storage capability within the US to just about double this yr with 14.3 GW being added to the present 15.5 GW. Our feedback catalog a number of current battery initiatives that can substitute fossil technology.
2. The New Caledonia Gasoline Plant Will Improve CO2 Emissions Considerably
The Federal Vitality and Regulatory Fee (FERC) doesn’t have jurisdiction over TVA, however they’ve developed a metric to judge the influence carbon emissions from pure fuel infrastructure can have on local weather change. FERC has acknowledged that “proposed initiatives with 100,000 metric tons per yr of carbon dioxide equivalents (CO2e) emissions will probably be deemed to have a vital influence on local weather change.” (emphasis added)
The Company states “The operation of the challenge would end in a most direct enhance of 531,728 metric tons of CO2e per yr based mostly on an assumed most capability issue of 20 p.c…. The anticipated precise direct enhance is 344,077 metric tons of CO2e per yr….” (DEIS, p. iv and p. 29)(emphasis added). The proposed challenge, whereas not underneath FERC jurisdiction, would have 3.5 to greater than 5 instances the CO2e emissions than what FERC deems can have a big influence on local weather change.
TVA makes an attempt to counter this horrifying reality by stating, with none documentation in any respect, that the combustion turbine challenge would cut back greenhouse fuel emissions by facilitating the combination of renewable technology. NEPA requires that each one paperwork upon which a DEIS relies be made publicly out there, and no such research accompanies this DEIS. Battery storage can accomplish renewables integration with none emissions in any respect.
3. The New Caledonia Gasoline Plant Will Have a Social Price of Greenhouse Gases of Over $1 Billion
The social value of carbon represents “the financial losses that outcome from emitting one further ton of GHGs into the environment at a particular time limit.” (DEIS, p. 34) The US Environmental Safety Company describes the social value of carbon as “a complete estimate of local weather change damages and consists of adjustments in internet agricultural productiveness, human well being, property damages from elevated flood threat, and adjustments in vitality system prices, akin to decreased prices for heating and elevated prices for air con.” TVA calculated the social value of carbon for the vary of carbon emissions referenced above. For this fuel peaker, with a 30 yr lifespan beginning in 2025 and utilizing a 2.5% low cost price, the Social Price of Greenhouse Gases ranges from $818,988,368 to $1,082,809,601.
A couple of billion {dollars} in financial losses, together with human well being.
Again to the Drawing Board
SACE concludes that TVA didn’t take the DEIS for the New Caledonia Gasoline Plant severely. We suggest that TVA withdraw this DEIS and begin over with one which considers grid-scale batteries because the Most popular Various. At a minimal, TVA ought to withdraw this DEIS and draft a brand new one after the finalization of the upcoming Built-in Useful resource Plan.
