As has been noted in a number of previous blogs, the need for new electric transmission to help connect new, but far-flung, wind farms and solar farms to the grid is growing.

However, these are not the only transmission lines that need to be given priority, according to a letter written on January 3, 2024, by Jacinda Woodward, senior vice president, Power Operations, of the Tennessee Valley Authority (TVA), to the Federal Energy Regulatory Commission (FERC), noting that similar and equal important consideration needs to be given to other transmission projects – in particular a gas pipeline designed to facilitate TVA’s closing of one of its coal plants..

In her letter, Woodward noted that, in December 2023, FERC issued a Sunshine Act Meeting Notice, announcing the agenda for the Commission’s December Open Meeting on December 19, 2023 (Sunshine Notice).

“Per the Commission’s Sunshine Notice, Tennessee Gas Pipeline Company, L.L.C.’s (TGP) proposed Cumberland Project was not included on the Commission’s December agenda,” said Woodward. She went on to say that TGP’s Cumberland Project is needed to serve a new combined-cycle combustion turbine natural gas plant that TVA, the “sole shipper” on the Project, is planning to construct to replace a portion of the generation capacity lost from the retirement of old coal-fired units at TVA’s Cumberland Fossil Plant.

“Any further delay in Commission action on the Cumberland Project threatens to delay TVA’s scheduled retirement of the coal units at the Cumberland Fossil Plant,” said Woodward. “TVA respectfully requests the Commission act on TGP’s Application without further delay.”

Woodward explained that TVA had adopted the alternative of retiring the Cumberland Fossil Plant (a coal-fired plant) and replacing the generation of one of the retired coal units with the Cumberland Gas Plant. “TVA is the sole shipper for the Cumberland Project, has a precedent agreement with TGP for all the gas capacity for the Cumberland Project, and needs the Cumberland Project to help implement its action to construct and operate the Cumberland Gas Plant,” said Woodward.

The Cumberland Project will facilitate TVA’s retirement of unit 1 of the Cumberland Fossil Plant and provide the necessary 1,450 MW of firm, dispatchable, replacement generation needed to help ensure that TVA is able to meet required year-round generation, maximum capacity system demands and planning reserve margin targets, particularly during peak load events, by 2026.

“The Cumberland Project will also improve the reliability and resiliency of TVA’s power system and meet near term energy production goals,” said Woodward. “Further, the Cumberland Project would facilitate TVA’s long-term goal of integrating 10,000 MW of solar generation onto the grid by 2035.”

According to Woodward, continued delay in FERC’s acting on TGP’s Application has the potential to:

1 – Delay TVA’s retirement of unit 1 of the Cumberland Fossil Plant, which would lead to additional construction, repairs, and maintenance upgrades and costs to maintain reliability and comply with environmental regulatory requirements such as Environmental Protection Agency’s (EPA) Effluent Limitation Guidelines and Clean Water Act Section 316(b) requirements.

2 – Delay TVA’s ability to develop and implement a path to approximately 80 percent carbon reduction by 2035, and to realize its aspiration to achieve net-zero carbon emissions by 2050.

3 – Create additional environmental, economic, and reliability risks. Further, the North American Electric Reliability Corporation (NERC) assesses that between 2024 and 2028, TVA’s service territory has a high risk of future electricity shortfalls under normal as well as extreme conditions. The Cumberland Project is critical to helping TVA meet its current and future customers’ electric supply needs as well as sustaining and enhancing the long-term reliability and resiliency of TVA’s electric grid.