Tennessee Valley Authority Statement 

EPA Public Hearings: Clean Power Plan Proposed Rule 

Atlanta, Georgia 

July 30, 2014 

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Good Morning, my name s John MyersJirector of Environmental Policy with the 

Tennessee Valley Authorit 'vve B!l!lFec· e the opportunity to be among the many 

voices at this public hearing. Congress tasked TVA with promoting the social and 

economic well-being of the residents of the Tennessee Valley. Reliable and affordable 

energy, economic development, and environmental stewardship are tools TVA uses to 

achieve this mission. TVA operates the nation's largest public power system serving 

parts of Tennessee, Alabama, Mississippi, Kentucky, Georgia, North Carolina, and 

Virginia with a population of over nine million people. Although the region has 

progressed far in attaining a better quality of life, many of our residents and their 

communities still are struggling economically and have yet to recover from the economic 

recession. It is important to TVA that the proposed rule not undermine the progress that 

has been made. 

We are continuing to review and analyze this complex rulemaking and will be providing 

EPA detailed comments. Today I want to talk about Building Block 3, "Using an 

Expanded Amount of Less Carbon-Intensive Generating Capacity." It is appropriate that 

we deliver these comments here in Atlanta because the Southeast is uniquely impacted 

by this building block and the treatment of nuclear units under construction. Generation 

fleets across the Southeast have been transitioning to supplying electricity with lower 

carbon emissions. For TVA, this means relying more on renewable energy resources, 

natural-gas fired generation and, importantly, nuclear energy. 

TVA is completing construction of a second unit at its Watts Bar Nuclear Plant in 

Tennessee. We have invested billions of dollars in this carbon-free resource and when 

Watts Bar Unit 2 comes on line in late 2015, it will be the first new nuclear unit in the 

21st century and provide nearly 10,000 GWh of emission-free generation per 

year. Watts Bar Unit 2 is an integral component of TVA's goal to achieve a more 

balanced, cleaner portfolio of energy resources. We expected this investment to give 

TVA a good start toward complying with any carbon emission regulations. Under EPA's 

rule as proposed, that does not happen. Rather, TVA and other utilities with nuclear 

units under construction are handicapped because generation from these units is used 

to set more stringent limits on affected fossil fleets in our States. Rather than gaining 

compliance margin under the proposed rule, TVA's and Tennessee's compliance risks 

are increased. That is not right. That is poor environmental policy. 

EPA asserts that there is flexibly for a state to use some, none, or all of the building 

blocks in crafting State Plans, but States with nuclear under construction have no valid 

options to assuage the impact of this block due to its size. Any single source making this 

much contribution to a state's reduction provides a compliance risk to the region. The 

proposed rule effectively punishes this early action and investment by our ratepayers by 

creating a big compliance risk. 

We wanted to bring this to EPA's attention and appreciate the opportunity to make these 

brief comments. 

Thank You.