The Tennessee Valley Authority (TVA) has finally released its 2025 Draft Integrated Resource Plan (IRP) and draft Environmental Impact Statement (EIS). The release of these draft documents comes after a nearly six month delay from the original scheduled release date in late March of this year.
The 2025 Draft IRPdescribes, in some detail, the range of electricity generation options that TVA is considering to meet its anticipated load growth (demand for electricity), meet expectations for affordability and reliability, while also complying with federal requirements to lower carbon and greenhouse gas emissions.
In this article, we offer a few insights into the good, and the bad, of the draft IRP.
Before we get to those points, we want to let you know that the IRP process includes a 60-day public comment period so that you can offer written input into the draft IRP and draft EIS. The comment period opened September 23, 2024 and closes November 26, 2024. At this page you can find more information the IRP, a link to the online comments option where you can type in or upload your comments, along with the link on how to submit a comment by email. You will also find more information about the IRP process.
What Is an IRP and Why Does it Matter?
As we explained last year, an Integrated Resource Plan is intended to be the roadmap, developed by a utility like TVA, for meeting TVA’s duty to provide electricity sufficient to meet the demand of customers in the TVA territory at a price that is affordable and that is reliable, environmentally responsible, flexible, diverse and low risk.
The planning process occurs over a year or more. We won’t get into the weeds of how this draft IRP was put together, but suffice it to say the process is imperfect and not as transparent as it should be, despite TVA’s claims of transparency. These two resources will give you some background reading, if you’re interested.
Since the IRP is intended to be the roadmap for generation and transmission decision-making by TVA’s management, it is important that the IRP be based on sound assumptions, good data, and the most accurate modeling possible.
One of the immediate issues with this draft IRP is the wide range of possibilities that are offered up for consideration: Six scenarios are presented, with five strategies, yielding 30 potential paths for TVA to adopt but none selected as a preferred pathway. It’s almost like the original Baskin-Robbins ice cream menu from back in the day, which offered us 31 flavors of ice cream.
We’re still digesting the details, models and assumptions, and will have more to say on those in the coming weeks. For now, we’ll stick with the key early issues we’ve identified.
What We Like
TVA will continue to (slowly) phase out its coal-fired generation assets, maintaining its commitment to close the coal facilities by 2035.
TVA at least opens the door to considerable growth in solar and wind generation, although the range of new solar generation is broad and new wind additions is relatively low. The Draft IRP contemplates 3 to 20 GW of new TVA nameplate solar by 2035 and up to 4 GW of TVA nameplate wind additions through 2035.
TVA has stated its intention to expand demand response and energy efficiency programs for TVA customers.
TVA acknowledges the need for grid enhancing technologies and expansion of transmission capacity, which could enable even more renewable energy.
TVA says it could increase energy storage by up to 6 GW. Unfortunately, the details in the narrative portions of the draft IRP reveal little effort by TVA to meaningfully consider storage as a near-term option.
Reducing carbon emissions is considered in the draft IRP, even if it does not go far enough.
What’s Missing
The Draft IRP Is Built on A Weak Consideration of Storage Technology
As noted above, the draft IRP references an expansion of storage technology of up to 6 GW. Significant added storage capacity would maximize the value of added solar for generation. Unfortunately, the details fall short in terms of any meaningful addition of storage.
Instead, TVA’s main storage solution for the next decade is to go “all in” to add a new hydro pumped storage unit by 2035.
Other forms of long-term storage options seem to all be lumped into the maybe-someday category. Due to flawed assumptions about the commercial viability of long-term storage technologies, TVA’s scenario modeling fails to consider new long-term storage options, like Form Energy’s 100-hour battery, that are now in use, or in the early stages of commercial deployment, in the U.S.
The Draft IRP Relies on Modeling Errors
Solar + Storage Are Modeled Separately
TVA’s modeling (which we’ll get to in more detail shortly) fails to consider solar and storage together.
In other word, the analysis fails to consider that solar and storage are (or should be) often deployed together and work in tandem. Instead, TVA models solar generation and storage capacity on a separate basis. We believe this understates the synergistic value of solar + storage and, therefore, reduces the economic benefits of solar and storage in the cost analysis required under the “Least Cost Principles” required under the Energy Policy Act of 1992. The same is true for wind and storage.
Transmission Will Be Studied and Addressed Separately
TVA’s actual transmission planning will be part of a separate planning process. We do like that there will BE a transmission planning process, which hasn’t been the case in the past. But transmission, like storage, will need to be fully integrated with planning for generation to best understand the full value renewable energy can bring to the system.
The Bad Stuff
Gas, Gas & More Gas
The 2025 Draft IRP reveals a range of 4 – 19 GW of new gas generation capacity, coupled with the deployment of unproven hydrogen and carbon capture and storage (CCS) technologies.
Ranges That Bely Meaningful Planning
As we noted at the outset, the 6 scenarios and 5 strategies yield 30 options. And the capacity ranges for the resource types make the 2025 Draft IRP more akin to a concept of a plan, than an actual integrated resource plan. As proposed under this Draft IRP, TVA’s management could choose to do just about anything they want, unless meaningful constraints are imposed to advance clean energy, grid enhancing technologies, and meaningful emissions reductions.
Modeling Assumptions
Some of the assumptions used in the scenario modeling range from weak to inaccurate
As one example, TVA chose to model 50 MW solar arrays, rather than larger systems with more advantageous cost benefits. Most utility solar projects are designed as 80 MW to 200 MW facilities, but the assumptions used by TVA do not reflect this, so the economies of scale are likely ignored.
Other assumptions presuppose that hydrogen and carbon capture and sequestration (CCS) will be ready for prime time before 2035. Conversely, the assumptions effectively ignore the commercial viability of long term storage and enhanced geothermal, and downplay the value of distributed generation options.Finally, TVA says historical data are used to determine the assumptions used in its modeling. TVA has been a laggard in the deployment of solar and storage, so the historical data used in its modeling assumptions is an underestimation of the contribution of solar and storage. Likewise, TVA has been slow to upgrade its transmission capacityand has long interconnection queues, further penalizing solar + storage in favor of its gas buildout.
Wrap Up
We’ll continue to study TVA’s 2025 Draft IRP and its accompanying Draft EIS. We encourage you to do the same and to participate in the open houses that TVA will be holding around its region. We also encourage you to submit comments through TVA’s online or email option so that your voice is heard. If you don’t already receive our email newsletter, sign up here, so you receive any updates we send out on TVA issues (and other Alabama-related clean energy news).
TVA 2025 Draft IRP Has Been Released
The Tennessee Valley Authority (TVA) has finally released its 2025 Draft Integrated Resource Plan (IRP) and draft Environmental Impact Statement (EIS). The release of these draft documents comes after a nearly six month delay from the original scheduled release date in late March of this year.
The 2025 Draft IRP describes, in some detail, the range of electricity generation options that TVA is considering to meet its anticipated load growth (demand for electricity), meet expectations for affordability and reliability, while also complying with federal requirements to lower carbon and greenhouse gas emissions.
In this article, we offer a few insights into the good, and the bad, of the draft IRP.
Before we get to those points, we want to let you know that the IRP process includes a 60-day public comment period so that you can offer written input into the draft IRP and draft EIS. The comment period opened September 23, 2024 and closes November 26, 2024. At this page you can find more information the IRP, a link to the online comments option where you can type in or upload your comments, along with the link on how to submit a comment by email. You will also find more information about the IRP process.
What Is an IRP and Why Does it Matter?
As we explained last year, an Integrated Resource Plan is intended to be the roadmap, developed by a utility like TVA, for meeting TVA’s duty to provide electricity sufficient to meet the demand of customers in the TVA territory at a price that is affordable and that is reliable, environmentally responsible, flexible, diverse and low risk.
The planning process occurs over a year or more. We won’t get into the weeds of how this draft IRP was put together, but suffice it to say the process is imperfect and not as transparent as it should be, despite TVA’s claims of transparency. These two resources will give you some background reading, if you’re interested.
Read Our Blog Post on a Petition for Public Hearing on the IRP
More On The Need for Transparency in the IRP Process
Since the IRP is intended to be the roadmap for generation and transmission decision-making by TVA’s management, it is important that the IRP be based on sound assumptions, good data, and the most accurate modeling possible.
One of the immediate issues with this draft IRP is the wide range of possibilities that are offered up for consideration: Six scenarios are presented, with five strategies, yielding 30 potential paths for TVA to adopt but none selected as a preferred pathway. It’s almost like the original Baskin-Robbins ice cream menu from back in the day, which offered us 31 flavors of ice cream.
We’re still digesting the details, models and assumptions, and will have more to say on those in the coming weeks. For now, we’ll stick with the key early issues we’ve identified.
What We Like
TVA will continue to (slowly) phase out its coal-fired generation assets, maintaining its commitment to close the coal facilities by 2035.
TVA at least opens the door to considerable growth in solar and wind generation, although the range of new solar generation is broad and new wind additions is relatively low. The Draft IRP contemplates 3 to 20 GW of new TVA nameplate solar by 2035 and up to 4 GW of TVA nameplate wind additions through 2035.
TVA has stated its intention to expand demand response and energy efficiency programs for TVA customers.
TVA acknowledges the need for grid enhancing technologies and expansion of transmission capacity, which could enable even more renewable energy.
TVA says it could increase energy storage by up to 6 GW. Unfortunately, the details in the narrative portions of the draft IRP reveal little effort by TVA to meaningfully consider storage as a near-term option.
Reducing carbon emissions is considered in the draft IRP, even if it does not go far enough.
What’s Missing
The Draft IRP Is Built on A Weak Consideration of Storage Technology
As noted above, the draft IRP references an expansion of storage technology of up to 6 GW. Significant added storage capacity would maximize the value of added solar for generation. Unfortunately, the details fall short in terms of any meaningful addition of storage.
Instead, TVA’s main storage solution for the next decade is to go “all in” to add a new hydro pumped storage unit by 2035.
Other forms of long-term storage options seem to all be lumped into the maybe-someday category. Due to flawed assumptions about the commercial viability of long-term storage technologies, TVA’s scenario modeling fails to consider new long-term storage options, like Form Energy’s 100-hour battery, that are now in use, or in the early stages of commercial deployment, in the U.S.
The Draft IRP Relies on Modeling Errors
Solar + Storage Are Modeled Separately
TVA’s modeling (which we’ll get to in more detail shortly) fails to consider solar and storage together.
In other word, the analysis fails to consider that solar and storage are (or should be) often deployed together and work in tandem. Instead, TVA models solar generation and storage capacity on a separate basis. We believe this understates the synergistic value of solar + storage and, therefore, reduces the economic benefits of solar and storage in the cost analysis required under the “Least Cost Principles” required under the Energy Policy Act of 1992. The same is true for wind and storage.
Transmission Will Be Studied and Addressed Separately
TVA’s actual transmission planning will be part of a separate planning process. We do like that there will BE a transmission planning process, which hasn’t been the case in the past. But transmission, like storage, will need to be fully integrated with planning for generation to best understand the full value renewable energy can bring to the system.
The Bad Stuff
Gas, Gas & More Gas
The 2025 Draft IRP reveals a range of 4 – 19 GW of new gas generation capacity, coupled with the deployment of unproven hydrogen and carbon capture and storage (CCS) technologies.
Ranges That Bely Meaningful Planning
As we noted at the outset, the 6 scenarios and 5 strategies yield 30 options. And the capacity ranges for the resource types make the 2025 Draft IRP more akin to a concept of a plan, than an actual integrated resource plan. As proposed under this Draft IRP, TVA’s management could choose to do just about anything they want, unless meaningful constraints are imposed to advance clean energy, grid enhancing technologies, and meaningful emissions reductions.
Modeling Assumptions
Some of the assumptions used in the scenario modeling range from weak to inaccurate
As one example, TVA chose to model 50 MW solar arrays, rather than larger systems with more advantageous cost benefits. Most utility solar projects are designed as 80 MW to 200 MW facilities, but the assumptions used by TVA do not reflect this, so the economies of scale are likely ignored.
Other assumptions presuppose that hydrogen and carbon capture and sequestration (CCS) will be ready for prime time before 2035. Conversely, the assumptions effectively ignore the commercial viability of long term storage and enhanced geothermal, and downplay the value of distributed generation options.Finally, TVA says historical data are used to determine the assumptions used in its modeling. TVA has been a laggard in the deployment of solar and storage, so the historical data used in its modeling assumptions is an underestimation of the contribution of solar and storage. Likewise, TVA has been slow to upgrade its transmission capacity and has long interconnection queues, further penalizing solar + storage in favor of its gas buildout.
Wrap Up
We’ll continue to study TVA’s 2025 Draft IRP and its accompanying Draft EIS. We encourage you to do the same and to participate in the open houses that TVA will be holding around its region. We also encourage you to submit comments through TVA’s online or email option so that your voice is heard. If you don’t already receive our email newsletter, sign up here, so you receive any updates we send out on TVA issues (and other Alabama-related clean energy news).
Sheree Martin