TVA's draft does not present a single strategy or plan for TVA to prioritize moving forward. Instead it presents 30 potential paths forward based on 6 scenarios and 5 strategies.

The Tennessee Valley Authority (TVA), the nation’s largest public power utility, released its long-awaited integrated resource plan (IRP) today, September 23, 2024. While the plan and its associated draft Environmental Impact Statement (EIS) are lengthy, 631 pages to be exact, there is still quite a bit missing. Here is our initial assessment, with more details to come as we dive into the documents.

What is most notable from a first glance through the document is that there is no proposed near-term action plan that details what exactly TVA plans to do in the next 5-8 years. There isn’t even a preferred portfolio. Just a very wide range of potential paths forward. If the TVA Board approves a document this broad, it would be handing over full control of the utility to unappointed executives to make any decisions they want. Do executives want to build only solar? Technically they could do that. Do executives want to only continue with their fossil fuel bonanza? They could do that too, under this same supposed plan. TVA executives just pushed through a massive rate hike with zero public process, so why would we trust them to do anything different with resource planning?

What is There

This is TVA’s first IRP since 2019, and it has noticeably more solar, storage, and demand-side measures like energy efficiency. That is certainly a step in the right direction!

Half of the scenarios TVA modeled included some sort of regulation on carbon dioxide (CO2) emissions. Another step in the right direction, though since the final EPA regulation on CO2 from existing coal and new gas power plants is the law of the land, the scenario that models that regulation should be renamed the “Reference Case” scenario (the main scenario used to compare all others to). The three scenarios with a CO2 regulation tend to have lower overall CO2 emissions. Though notably, the scenario with the final rule has higher emissions than the two that assumed the draft rule, which regulated both existing and new fossil gas powerplants (the final rule only regulates new fossil gas power plants, with an additional rule on existing fossil gas to be expected next).

The draft IRP shows that TVA’s system-wide CO2 emissions vary more between scenarios than strategies. This means that either TVA’s strategies are not very different, that there are multiple strategies that align with decarbonization, and/or that most of the drivers that determine whether TVA’s system reduces carbon emissions is beyond its control. None of the strategies achieve TVA’s stated goal of getting to net-zero carbon emissions by 2050.

Where TVA does achieve some level of decarbonization, it does so with additional renewables and storage, but also by switching uncontrolled fossil gas resources to either burn some hydrogen with the fossil gas or install carbon capture and sequestration (CCS).

What is surprising is the way those carbon reductions are achieved. While these scenarios have some accelerated renewables and storage by the early 2030s, most notable is that all the fossil gas TVA plans to build in its business-as-usual case is instead a “hydrogen” power plant or a fossil gas power plant with carbon capture and sequestration (CCS) installed.

What isn’t

Solar plus storage was not modeled as a single resource. Standalone solar and standalone storage were modeled separately, but when the two are combined they can provide benefits to the grid that resource models cannot recognize when they are modeled as separate resources.

Furthermore, long duration storage doesn’t appear anywhere in TVA’s draft IRP despite a concerted effort by the Department of Energy to mobilize long duration storage over the next 5 years. TVA assumes 10 hour storage becomes available starting in 2029 but limits it to 500 MW or 650 MW per year.

Also missing is a scenario that achieves, or comes close, to Biden administration’s goal to decarbonize electricity by 2035. All scenarios see a reduction in annual CO2 emissions until annual emissions flatten out in the late 2030s and early 2040s.

Additionally, transmission analysis does not appear to be included in this IRP. In fact, TVA says it will start a separate process for integrated transmission planning, which will not be integrated with this integrated resource planning. I guess calling these planning processes integrated is enough, we don’t have to actually do the work to integrate them?

Finally, and perhaps most importantly, despite a longer-than-usual comment period and a few more public open houses, TVA is still relying on its NEPA process for public comments on the draft IRP. No hearing, no process overseen by an independent regulator, and no written testimony. We have called on TVA to do more than NEPA, and those calls still stand.

What comes next

This draft does not present a single strategy or plan for TVA to prioritize moving forward. Instead it presents 30 potential paths forward based on 6 scenarios and 5 strategies. As part of the comment period, TVA asks that stakeholders review the 30 portfolios and provide feedback on what TVA should prioritize. Theoretically, that means TVA should pick one portfolio or a narrow range as its final IRP.

In the past, TVA has just lumped the results of over 30 portfolios together into huge ranges that make the whole planning process completely meaningless. Who’s to say whether TVA will be allowed to do that again? The TVA Board of Directors, that’s who.

SACE will be diving into all 631 pages of the draft IRP to bring further updates on topics like how TVA assessed different categories of risk, how TVA determined what is needed to keep the system reliable, and more.

TVA will host several in-person open houses and two virtual webinars in October and November. Find one near you here, or use TVA’s online portal to submit a comment on the draft IRP by November 26.