Public Comments

Energy Alabama Signs On To Public Comments About TVA 2019 Draft IRP

Energy Alabama has signed on to public comments on the Tennessee Valley Authority’s (TVA) draft 2019 Integrated Resource Plan (draft IRP) and accompanying draft Environmental Impact Statement. The comments were developed in conjunction with the Southern Environmental Law Center (SELC) Tennessee Environmental Council, Gasp, Tennessee Clean Water Network, Harpeth Conservancy, Alabama Rivers Alliance, and Protect Our Aquifer (collectively referred to below as “Conservation Groups”).

The way TVA provides electricity has far-reaching effects on the Tennessee Valley, the Southeast region, and beyond. The results presented in the draft IRP highlight that—no matter what the future holds—a strategy that promotes and leverages distributed energy resources (DER), including energy efficiency, demand-response, distributed solar, and storage will best achieve TVA’s statutory mandate to provide electricity at the lowest system cost, as well as its mission to improve the quality of life in the Valley through the integrated management of the region’s resources.

Although the study confirms that DER is competitive with, and preferable to, a traditional supply-side approach, we Conservation Groups believe that, as presented, the draft IRP underestimates the potential for DER to contribute to the future of the Valley’s grid.

To read the Conservation Groups’ full public comments, click here.

Additionally, Energy Alabama has submitted independent comments regarding non-technical and process concerns. The full comments are available here, and can be summarized at a high level with the following bullet points:

  1. Non-disclosure agreements for IRPWG members stifle discussion and are unnecessary
  2. The IRPWG needs actual power to influence the IRP
  3. TVA should refrain from changing programs during an IRP
  4. TVA should have explicitly shown the IRPGW material changes between the 2015 IRP and the 2019 draft IRP
  5. TVA should pursue a distributed IRP with all possible speed

To read Energy Alabama’s complete independent comments, click here.

Energy Alabama Submits Comments on Volkswagen Beneficiary Mitigation Plan

Energy Alabama, in conjunction with the Southern Environmental Law Center (SELC) and Gasp, Inc., has submitted public comments on the Alabama Department of Economic and Community Affairs (ADECA) draft Volkswagen Environmental Mitigation Trust, Beneficiary Mitigation Plan. The draft plan was posted on ADECA’s website on December 27, 2018, and discussed at a public hearing on January 15, 2019.

Our comments can be viewed in full here.

The mitigation trust offers a great opportunity for Alabama to make meaningful advances toward the electrification of its transportation system. As outlined in our comments, we commend ADECA for proposing to spend the maximum allowable percentage of its mitigation trust fund allotment on electric vehicle charging stations, and we recommend that Alabama spend the remainder of its funding on electric transit and school buses, as well as electric airport ground support equipment.

In addition, we recommend that Alabama prioritize funding for communities that have been disproportionately impacted by air pollution. Finally, we recommend that ADECA provide 100 percent funding for government-owned projects, maximize DERA funding, clarify how projects will be selected, and require emissions reduction information to be made publicly available.

To read the full comments, click here.

Energy Alabama Provides Comments for Public Service Commission on EV Charging Stations

Energy Alabama, along with the Southern Environmental Law Center and Gasp, provided comments to the Alabama Public Service Commission regarding its Proceeding to Determine the Commission’s Jurisdiction Over Electric Vehicle Charging Stations.

Our comments included two important points for the Commission to consider:

  1. An entity owning and/or operating an Electric vehicle charging station (EVCS) should not be subject to Title 37. In other words, these entities should not be under the jurisdiction of state utility regulators. This position represents the consensus among all commenting parties in the proceeding.
  2. Investments by Alabama Power in EVCS should maximize public benefits.

Concerning Alabama Power’s investments in the electric vehicle charging space, we included two further points:

  1. The Commission should require that utility investments in EV infrastructure provide net benefits to customers and promote EV adoption while still allowing a competitive market to develop. Ideally, the Commission should give utilities clear guideposts for these investments.
  2. We recommend that the Commission propose a technical conference or other forum where rate design questions can be explored further with respect to EV charging stations.

Our full comments can be found here: https://alcse.org/wp-content/uploads/2018/03/2018-01-26-SELC-Reply-Commments-Re-EVCS.pdf

Energy Alabama Signs On to Comments Opposing TVA’s NEPA Rule Changes

Energy Alabama, and a host of energy and conservation groups, signed on to comments prepared by the Southern Environmental Law Center opposing changes to TVA’s implementing regulations for the National Environmental Policy Act (“NEPA”).

Energy Alabama is extremely concerned that TVA’s proposed changes undermine transparency, stifle public involvement in TVA’s decisions, and bestow upon TVA almost boundless discretion to decide whether and how it must review the effects of its activities on the people and environment throughout its seven-state service territory, which includes nearly all of Tennessee, and portions of Alabama, Georgia, Kentucky, Mississippi, North Carolina, and Virginia.

To view the full comments, please visit: https://alcse.org/wp-content/uploads/2017/09/2017-09-06-Comment-on-TVA-Proposed-NEPA-Rule.pdf

Energy Alabama Signs On to Comments for Department of Energy’s Grid Reliability Study

Energy Alabama, along with many southeastern groups supportive of sustainable energy, signed on to comments prepared by The Southern Environmental Law Center in regards to the Department of Energy’s Grid Reliability Study. A 60-day inquiry is currently being undertaken by the Department of Energy concerning the reliability of our nation’s electricity grid.

We decided to sign on to these comments because Alabamians are starting to reap the benefits of affordable, reliable renewable energy resources that are diversifying our grid and producing clean, sustainable power. This study has the opportunity to significantly strengthen or weaken sustainable energy in South. We wanted to take any opportunity we could to give our voice in support of sustainable energy.

The full comments are shared below.

Download the PDF file .