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TVA Draft IRP – Exceedingly Broad Planning is Meaningless – SACE | Southern Alliance for Clear EnergySACE


TVA’s draft doesn’t current a single technique or plan for TVA to prioritize shifting ahead. As an alternative it presents 30 potential paths ahead primarily based on 6 eventualities and 5 methods.


Maggie Shober | September 23, 2024

| Fossil Gasoline, Transmission, Utilities

The Tennessee Valley Authority (TVA), the nation’s largest public energy utility, launched its long-awaited built-in useful resource plan (IRP) as we speak, September 23, 2024. Whereas the plan and its related draft Environmental Affect Assertion (EIS) are prolonged, 631 pages to be precise, there’s nonetheless fairly a bit lacking. Right here is our preliminary evaluation, with extra particulars to return as we dive into the paperwork.

What’s most notable from a primary look by the doc is that there isn’t any proposed near-term motion plan that particulars what precisely TVA plans to do within the subsequent 5-8 years. There isn’t even a most popular portfolio. Only a very big selection of potential paths ahead. If the TVA Board approves a doc this broad, it might be handing over full management of the utility to unappointed executives to make any selections they need. Do executives wish to construct solely photo voltaic? Technically they might do this. Do executives wish to solely proceed with their fossil gas bonanza? They might do this too, beneath this similar supposed plan. TVA executives simply pushed by a huge fee hike with zero public course of, so why would we belief them to do something totally different with useful resource planning?

Vary of Attainable Useful resource Additions to TVA Energy Grid by 2035 as offered within the 2024 Draft IRP Govt Abstract. Chart supply: SACE.

What’s There

That is TVA’s first IRP since 2019, and it has noticeably extra photo voltaic, storage, and demand-side measures like power effectivity. That’s definitely a step in the correct course!

Half of the eventualities TVA modeled included some kind of regulation on carbon dioxide (CO2) emissions. One other step in the correct course, although because the last EPA regulation on CO2 from present coal and new gasoline energy crops is the legislation of the land, the state of affairs that fashions that regulation needs to be renamed the “Reference Case” state of affairs (the principle state of affairs used to match all others to). The three eventualities with a CO2 regulation are inclined to have decrease general CO2 emissions. Although notably, the state of affairs with the ultimate rule has increased emissions than the 2 that assumed the draft rule, which regulated each present and new fossil gasoline powerplants (the ultimate rule solely regulates new fossil gasoline energy crops, with an extra rule on present fossil gasoline to be anticipated subsequent).

The draft IRP exhibits that TVA’s system-wide CO2 emissions differ extra between eventualities than methods. Which means that both TVA’s methods usually are not very totally different, that there are a number of methods that align with decarbonization, and/or that a lot of the drivers that decide whether or not TVA’s system reduces carbon emissions is past its management. Not one of the methods obtain TVA’s acknowledged aim of attending to net-zero carbon emissions by 2050.

The place TVA does obtain some stage of decarbonization, it does so with further renewables and storage, but in addition by switching uncontrolled fossil gasoline assets to both burn some hydrogen with the fossil gasoline or set up carbon seize and sequestration (CCS).

What’s shocking is the way in which these carbon reductions are achieved. Whereas these eventualities have some accelerated renewables and storage by the early 2030s, most notable is that each one the fossil gasoline TVA plans to construct in its business-as-usual case is as an alternative a “hydrogen” energy plant or a fossil gasoline energy plant with carbon seize and sequestration (CCS) put in.

What isn’t

Photo voltaic plus storage was not modeled as a single useful resource. Standalone photo voltaic and standalone storage have been modeled individually, however when the 2 are mixed they’ll present advantages to the grid that useful resource fashions can not acknowledge when they’re modeled as separate assets.

Moreover, lengthy period storage doesn’t seem anyplace in TVA’s draft IRP regardless of a concerted effort by the Division of Vitality to mobilize lengthy period storage over the subsequent 5 years. TVA assumes 10 hour storage turns into obtainable beginning in 2029 however limits it to 500 MW or 650 MW per yr.

Additionally lacking is a state of affairs that achieves, or comes shut, to Biden administration’s aim to decarbonize electrical energy by 2035. All eventualities see a discount in annual CO2 emissions till annual emissions flatten out within the late 2030s and early 2040s.

Moreover, transmission evaluation doesn’t look like included on this IRP. The truth is, TVA says it is going to begin a separate course of for built-in transmission planning, which is not going to be built-in with this built-in useful resource planning. I assume calling these planning processes built-in is sufficient, we don’t have to really do the work to combine them?

Lastly, and maybe most significantly, regardless of a longer-than-usual remark interval and some extra public open homes, TVA continues to be counting on its NEPA course of for public feedback on the draft IRP. No listening to, no course of overseen by an impartial regulator, and no written testimony. We now have known as on TVA to do greater than NEPA, and people calls nonetheless stand.

What comes subsequent

This draft doesn’t current a single technique or plan for TVA to prioritize shifting ahead. As an alternative it presents 30 potential paths ahead primarily based on 6 eventualities and 5 methods. As a part of the remark interval, TVA asks that stakeholders assessment the 30 portfolios and supply suggestions on what TVA ought to prioritize. Theoretically, meaning TVA ought to choose one portfolio or a slim vary as its last IRP.

Prior to now, TVA has simply lumped the outcomes of over 30 portfolios collectively into large ranges that make the entire planning course of utterly meaningless. Who’s to say whether or not TVA shall be allowed to do this once more? The TVA Board of Administrators, that’s who.

SACE shall be diving into all 631 pages of the draft IRP to deliver additional updates on matters like how TVA assessed totally different classes of threat, how TVA decided what is required to maintain the system dependable, and extra.

TVA will host a number of in-person open homes and two digital webinars in October and November. Discover one close to you right here, or use TVA’s on-line portal to submit a touch upon the draft IRP by November 26.



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