Kelly Baxter, NEPA Project Manager
400 West Summit Hill Drive
Knoxville, TN 37902

Re: Urgent Need for the Tennessee Valley Authority to Transition Off Fossil Fuels in the 2025 Integrated Resource Plan to Tackle the Climate Emergency and Advance a Safe, Affordable, and Clean Energy Future for Communities

Dear Ms. Baxter,

From rural areas harmed by polluting pipelines and gas plants to urban centers trying to achieve carbon reduction goals, we are united in our demand that the Tennessee Valley Authority (“TVA”) abandon methane gas in favor of clean, affordable, and forward-thinking renewable energy so that we can work for a just and equitable future for all.

As a public utility, TVA has an obligation to protect and serve the interests of people in the region. On top of this, as the country’s largest federal utility, TVA has the responsibility and opportunity to lead the way forward to a just and equitable energy future free of fossil fuels.

Instead of pioneering this urgently needed transformation, TVA’s draft 2025 Integrated Resource Plan (“2025 IRP”) would lock in its reliance on methane gas for several decades, burdening millions of people with more dirty air, asthma attacks, higher cancer rates, power blackouts and rising utility bills. TVA already has one of the largest gas buildouts of any utility this decade. This draft IRP – combined with TVA’s ongoing gas buildout – is unacceptable. TVA’s plans are way out of line with climate science, federal clean energy targets, the demands of Valley communities, and even TVA’s own mission to improve the quality of life of people in the region.

We are in a make-or-break moment for the future of our planet and our communities. This year Tennessee communities, like much of the country, have faced extreme climate disasters, from deadly heat waves and tornadoes to frigid ice storms and devastating hurricanes fueled by increasing climate-warming emissions. Most recently, Hurricane Helene brought unimaginable loss – families have lost loved ones, homes, businesses, and so much more. As entire communities rebuild from Helene’s devastation, TVA should be doing all it can to build a resilient energy future by transitioning our energy system to one powered by renewable and distributed energy solutions like solar with battery storage – not fragile fossil fuels that pollute our communities and contribute to deadlier storms.

On top of this, TVA’s $9 billion methane gas buildout is aggravating energy costs in the region. TVA ratepayers spend some of the highest percentage of their income on energy bills in the country. Yet to build more gas plants and pipelines, TVA has raised rates nearly 10% in the last 14 months. Another 25 years of gas, as proposed in the draft 2025 IRP, will saddle families with even higher bills, making it that much harder to access life-saving electricity to power medical devices, heat homes during the winter, and keep the lights on when extreme weather inevitably strikes.

Methane is a potent greenhouse gas that carries a host of public health and safety risks that simply cannot be overlooked. Methane gas plants also emit dangerous pollutants, like NOx and volatile organic compounds, that exacerbate respiratory illnesses. TVA has already done its fair share of ramming through fossil fuels in the past two years with the proposed Kingston and Cumberland gas plants and flat-out ignoring the serious air pollution impacts of new fossil resources. Valley communities deserve better than an expensive, unhealthy, and risky gas-filled future. The next generation deserves a livable future.

To improve this IRP, we urge TVA staff and the Board to:

- Model an additional strategy for 100% clean energy by 2035, in line with federal climate targets. Such a scenario should rely on proven renewable technologies, specifically solar, battery storage (including long-duration batteries), wind, energy efficiency, demand response, and microgrids.

- Prioritize renewable distributed generation alternatives. Rooftop and community solar with battery storage are critical for local energy and climate resilience. As extreme weather events occur more frequently, these resources are critically needed.

- Develop a 3- to 5-year near-term action plan. As it stands, the draft IRP is too broad with large resource ranges that provide far too much flexibility for un-elected TVA executives and staff to continue maximizing methane gas builds while slow-walking renewable energy. The decisions TVA makes in the next 5 years are critical. A near-term action plan can put TVA on track with achieving federal decarbonization goals with investments in efficient and renewable generation over the next 5 years.

- Hold a public hearing on the draft 2025 IRP. This IRP will impact communities in the Valley for decades. It is standard practice for regulated utilities to have an IRP hearing where experts can offer feedback on a utility’s plan. TVA’s process should be no different, but it does not include meaningful public participation. TVA should therefore hold an accessible public hearing that allows for testimony by experts and incorporates opportunities for robust community engagement.

- Publish an interim report. Prior to the final IRP, TVA should publish an interim report with results of additional sensitivity analysis conducted based on comments on the draft IRP. Furthermore, there should be another 30-day public comment period, which should influence final IRP outcomes.

CC: Tennessee Valley Board of Directors

Sincerely,