Legal Petition Demands Tennessee Valley Authority Halt Electricity Shutoffs, Fund Debt Relief

For Immediate Release, August 25, 2020

Contact:

Howard Crystal, Center for Biological Diversity, (202) 809-6926, hcrystal@biologicaldiversity.org
Brianna Knisley, Appalachian Voices, (937) 725-0645, brianna@appvoices.org
Daniel Tait, Energy Alabama, (256) 812-1431, dtait@alcse.org
Isabella Killius, Sunrise Tennessee, (615) 762-6665, sunrisetennessee@gmail.com

WASHINGTON— Dozens of climate-justice organizations petitioned the Tennessee Valley Authority today to immediately impose a moratorium on electricity shutoffs in the region and fund debt relief for its customers.

The petition also calls on the massive utility company to accelerate the Valley’s clean energy transition to address compounding COVID-19 unemployment, climate and racial injustice crises.

“TVA has the responsibility and the money to prevent people from needless suffering and crushing debt,” said Howard Crystal, legal director for the Center for Biological Diversity’s energy justice program. “The company can seize this opportunity to genuinely serve the public interest and become a model for other utility companies. TVA must acknowledge the environmental damage from its dirty energy choices and chart a new course toward a clean, democratic energy future.”

Congress has yet to impose a federal moratorium on utility shutoffs, leaving thousands of families in TVA’s service territory at risk of losing electricity during a summer of climate-induced, record heatwaves.

“In the face of a public health, environmental and economic crisis not seen since the Great Depression, we are calling on TVA to return to its original mission to improve quality of life here in the Tennessee Valley,” said Brianna Knisley, Tennessee campaign coordinator with Appalachian Voices. “TVA can and should protect vulnerable communities from power shut offs, eliminate unnecessary and harmful coal ash production, and bring new, public jobs to the Valley. At the very least, our public utility should be reaching out to communities to better understand their issues and needs during these critical times.”

The COVID-19 pandemic and related unemployment crisis have brought severe economic strain to the Southeast, a region where low-income communities, Black communities and other communities of color are already disproportionately burdened by pollution, high energy bills and utility shutoffs.

“If TVA wants to get serious about reducing the burden of COVID-19 on residents in the Valley, it is time for TVA to get serious about strong energy efficiency and renewable energy programs, specifically for low-income customers,” said Daniel Tait, chief operating officer of Energy Alabama.

The petition urges TVA to reallocate its vast resources to help customers pay their bills and fund equitable economic recovery through clean energy and efficiency programs. This would require a series of public hearings, which the petition says should begin as soon as possible.

“In the midst of the pandemic, when people are unemployed and without basic needs like power, food, water, and broadband services, TVA has a responsibility to support its customers by instituting a moratorium on utility shut-offs, thus upholding its original mission to serve the people of the Tennessee Valley,” said Isabella Killius with Sunrise Tennessee. “This petition encapsulates the need for institutional change within the TVA such that customers are provided adequate relief and, in addition, necessary actions are taken to mitigate the ongoing climate crisis.”

TVA has the funding and the mandate to provide debt relief to residential customers, rapidly retire its fossil fuel infrastructure, and invest in clean, distributed energy and energy efficiency efforts. These efforts will create local jobs vital to the region’s economic recovery.

The petition is named in honor of S. David Freeman, a former TVA board chair and a tireless advocate for renewable energy. The self-proclaimed “green cowboy,” who died in May, had sought for a long time to free people from polluting, centralized TVA power.

TVA is a federally owned corporation and the nation’s largest public power provider. It generates electricity for more than 9 million customers in Tennessee, northern Alabama, northeastern Mississippi, southwestern Kentucky, and portions of northern Georgia, western North Carolina and southwestern Virginia.

 

The Center for Biological Diversity is a national, nonprofit conservation organization with more than 1.7 million members and online activists dedicated to the protection of endangered species and wild places.

Appalachian Voices works at the nexus of the ongoing shift from fossil fuels to clean, 21st-century energy sources — we fight mountaintop removal coal mining, fracked-gas pipelines and other harms to the people and places of Appalachia, and we advance energy efficiency, solar and wind power, and other economic solutions that create community wealth and sustain Appalachia’s mountains, forests and waters.

Energy Alabama is a membership-based non-profit organization accelerating Alabama’s transition to sustainable energy. We accomplish our mission by educating at all levels, informing smart energy policy, building the next generation workforce, and providing technical assistance to deploy more sustainable energy. We believe in sustainable energy for all.

Sunrise Tennessee is a statewide coalition of Sunrise hubs that represents young organizers from Nashville, Knoxville, and Franklin, Tennessee. We are fighting for a Green New Deal on both state and federal levels, ensuring a just transition away from the fossil fuel economy and the creation of millions of good-paying jobs.

###

RELEASE: Groups challenge TVA’s plan to lock local power companies into perpetual contracts

Contacts:
Scott Smallwood | SELC | ssmallwood@selcga.org | 770-598-0111
Ward Archer| Protect Our Aquifer | ward@protectouraquifer.org | 901-355-0515
Brianna Knisley | Appalachian Voices | brianna@appvoices.org | 937-725-0645
Daniel Tait | Energy Alabama | dtait@alcse.org | 256-812-1431

 

MEMPHIS, TN – The Southern Environmental Law Center (SELC), on behalf of Protect Our Aquifer, Energy Alabama and Appalachian Voices, is challenging in federal court the Tennessee Valley Authority’s (TVA) monumental decision to implement never-ending contracts designed to keep local power distributors captive customers of the federal utility forever.

The contracts further entrench TVA’s control over a vast network of power systems across portions of seven Southeastern states. The never-ending contracts lock the federal utility’s local power customers into exclusive energy contracts likely to last forever which will forever deprive distributors and ratepayers the opportunity to renegotiate with TVA to obtain cheaper, cleaner electricity. The anticompetitive contracts also place harsh caps on the ability of local power companies to use renewable power from non-TVA sources, and they seek to guarantee that TVA’s customer base, made up of municipal and member-owned local utilities, never leaves the utility.

“TVA is using these eternal contracts to stamp out any competition for the next century,” said Amanda Garcia, SELC’s Tennessee office director. “These never-ending contracts threaten to prevent local distributors from ever renegotiating their contract with TVA, let alone consider leaving the utility if it continues to lag behind in transitioning towards cheaper, cleaner renewable energy. These contracts will take the public’s interest completely out of public power.”

Previously, the average length of the termination provision in the distributors’ contracts was under seven years, offering periodic opportunities for publicly- and member-owned utilities to revisit contract terms with TVA or seek cheaper, cleaner power elsewhere. The newly signed contracts, which require a 20 year notice to terminate, renew automatically each year so that the length of the contract term never ends. The complaint alleges that the contracts will have potentially significant effects on the environment, including, among other things, influencing TVA’s decisions to invest in energy resources, increasing greenhouse gases and other pollution, and increasing water usage across the Tennessee Valley.

“TVA’s continued reliance on fossil fuel resources has a lasting impact on Memphis’ primary drinking water source, the Memphis Sand Aquifer,” said Ward Archer, President of Protect Our Aquifer. “TVA has stored coal ash in a way that puts our drinking water aquifer at risk, and its use of billions of gallons of our clean drinking water to operate its gas plant for decades to come threatens the sustainability of our community. The public has a right for federal agencies to look at alternatives when making major decisions, and TVA deprived communities of that right before asking local distributors like Memphis Light, Gas & Water to sign these never-ending contracts.”

An important federal law requires TVA to analyze and disclose the consequences of major federal programs that may significantly affect the environment. That law also requires TVA to consider alternatives and seek public input about major proposals before TVA moves forward with the project. Conservation groups allege that TVA failed to meet the basic requirements of that law, called the National Environmental Policy Act, or NEPA, before its monumental move to lock 138 of its 153 power distributors into these never ending contracts.

“While TVA keeps the lights on across the Valley, our utility kept the public in the dark around its game-changing decision to essentially trap power distributors’ customers and members in these regressive contracts for the foreseeable future,” said Brianna Knisley, Tennessee Campaign Coordinator for Appalachian Voices. “Ultimately, TVA blocked an opportunity for the public to participate in a major policy decision that will likely stall our region’s critically needed transition to renewable resources.”

Last year, several of TVA’s distributors, including its largest customer, Memphis Light, Gas & Water, announced that they were evaluating whether to leave TVA in favor of cheaper, cleaner options. In response, TVA’s Board of Directors authorized the utility to restructure its relationship with its distributors by amending its power supply contracts to these never-ending contracts that automatically renew every year and include punitive 20-year notice of termination provisions.

“Over the past two years, TVA has taken a series of actions to further cement its monopoly status and shut down customers’ access to distributed energy resources, including solar power and energy efficiency programs,” said Daniel Tait, Chief Executive Officer at Energy Alabama. “As a result, TVA lags behind other utilities in our region, both in terms of renewable energy capacity and its overall commitment to decarbonize the grid. By locking in its customer base, TVA can dictate the pace of its energy transition from fossil fuels to renewable energy at whatever pace suits its own interests, rather than the interests of the communities it serves.”

The challenge also alleges that TVA violated the federal law that created the federal utility back in 1933 by entering into never-ending agreements with power distributors. That law, called the TVA Act, says that federal utility’s power supply contracts cannot exceed 20 years. By drafting the agreements so that they never expire, the conservation groups allege that TVA ran afoul of that limit on its monopoly power.

# # #

TVA sign at Hyde Park, NY, By Billy Hathorn - Own work, CC0

The History of the Tennessee Valley Authority (TVA)

The History of the Tennessee Valley Authority (TVA)

TVA’s history is really interesting, especially given how much things have changed from its original mission. TVA was established in 1933 as part of President Franklin Delano Roosevelt’s New Deal. TVA was created for economic development and environmental conservation. And yes, energy too. 

TVA was created not just to help electrify the south. TVA was tasked with modernizing the Tennessee Valley, one of the most impoverished regions of the country. Goals included improving the navigability of the Tennessee River, providing flood control, and developing agriculture, industry, and commerce in the seven-state area of the Tennessee Valley. Along with providing electricity to many rural areas for the first time, TVA would also bring jobs and economic development.

TVA played a major role in the World War II effort, especially making fertilizer. For decades, TVA was progressive,open to unions, and was responsible for some of the earliest movements in the South for desegregating and opening the workforce to everyone. They really pushed the envelope from an environmental, economic, and social justice perspective long before it was accepted in much of the South. That’s not to say TVA was without issues that can be papered over. The creation of TVA dams displaced thousands of families, taking an especially difficult toll on black communities.

Because it was a public utility, TVA could typically generate power at lower costs than investor owned utilities, which are usually more concerned with shareholders rather than the local community.

The Transition Away from Public Power Values

The TVA is now the largest public utility and one of the largest providers of power in the country. Unfortunately, in recent decades TVA has transitioned from operating as a public utility to operating much more like a private investor-owned utility, with a CEO that makes $8.61 milion/year. CEO Jeffrey Lyash’s high salary has drawn the ire of President Donald Trump. 

Why has TVA moved away from public power values? Some place the blame as far back as President Reagan, whose conflict with TVA appears to have stemmed from the early 1960s. Reagan had called for the privatization of TVA.

Some place the blame at the feet of the previous CEO, Bill Johnson. Johnson had a background in investor-owned utilities, rather than public power, and instituted many policies from private business. Those policies have resulted in the lack of transparency and many of the problems that we see today.

Regardless of the specific date, TVA has been on a decades long march away from the values of public power. 

The Problems with TVA

As we at Energy Alabama see it there are several major issues with the TVA. While they don’t all have easy answers, TVA can and should improve the situation.

Lack of transparency and public input

Given that TVA is a public utility, it is surprising the public has very little say in what they do. While they do provide occasional opportunities for the public to speak on specific topics, the public is largely ignored. We at Energy Alabama, as well as other great groups from around Valley, make every effort to speak out and publicly comment as much as possible. However, TVA tends to follow the typical federal rule-making process. They create a plan, collect public comments, then follow-up by telling the public how they already addressed the public’s concerns in their plan (whether they have or not).

TVA is a member of the Utility Air Regulation Group (UARG) and Utility Solid Waste Activities Group (USWAG), off the books collaboration of utilities that sue the EPA, DOE, and federal government to roll back and destroy environmental regulations. TVA uses public money (that means money from your electric bill) to fund these groups to fight the regulations that they are subject to. Basically, a federal agency using our money to sue another federal agency. 

Apparently, this has been happening despite being against the directives of the board of directors. The board had written a policy about how the TVA is supposed to use public money when it comes to lobbying and litigation, but UARG and USWAG expenditures seem to be in complete contradiction to that. They are spending our money against the public benefit; and in many cases, it appears the board doesn’t even know what’s happening.

TVA has gotten really good over the last few years of going through the motion of accepting public comments. They make sure that people like us, their customers, have the opportunity to speak up, but have no real intent of doing anything with the feedback. Basically, they will say just enough to placate and give the appearance that we’ve been heard. We, for one, cannot remember a time in which public comments we sent in to TVA were adopted or addressed substantively.

Equity and Justice

Persistent poverty is a problem in the Tennessee Valley. TVA was created to bring people out of poverty and alleviate it, not make it worse. But there are so many places in the valley where we have completely unsustainable electric bills. Those high, unsustainable electric bills only serve to keep people in these areas in poverty. 

There is no focus from the TVA on helping people save energy. In fact, TVA recently cut almost all its funding for energy efficiency and its new long-range planning magically says energy efficiency is not cost-effective. After years of pressure, TVA has run limited pilots for low-income energy efficiency but it has yet to expand these across the Valley at the scale needed. As usual, they look good on a press release but fail to fully address the problem.

By helping people solve the issue of high electric bills at the source, and fix these issues for people first, we can work towards solving the larger issues.

Customers are paying high electric bills for three main reasons.

We are paying for uncontrolled high consumption. Electric use is high in the Tennessee Valley for natural reasons. We have warmer weather which increases the need for air conditioning in the summer and when heat is needed, we are more likely to use electric heat. TVA has been historically woeful on helping people lower their consumption. In fact, they take steps to ensure that we use more energy instead of less.

We are paying for bad decisions of the past. TVA was built to create affordable energy for the people. However, unwise decisions made in the 1970s and 1980s created an undue burden on the ratepayers that will exist for many years to come.

In the early 1970’s the TVA began building 17 nuclear facilities to meet increased power demands. However, after several years the build-out for 10 of those reactors was cancelled due to lack of need. Unfortunately, the costs had already been largely incurred and continue to be passed on to the customers.

So, we now have billions of debt on the books for power plants that were never finished. That debt gets passed to the customers in the form of higher utility bills.

We are paying to maintain uneconomic power plants. Many existing coal and gas power plants around the country are losing money. Some of these are running despite a lack of need, and those that are needed could be replaced by efficient energy sources, such as solar and wind.

Despite this, TVA wants to add even more unneeded natural gas!

 

Communities in Transition

Attention also needs to be paid to how we deal with communities in transition. In areas where there were coal plants that are closed/closing, or areas where TVA has simply decided to outsource jobs. How do we take care of those people and make sure they are not hurt in this transition? This energy transition needs to take place but we need to make sure people aren’t hurt in the process. When people are being hurt, we can’t be surprised when they are resistant to the transition that needs to take place.

If we fix the problems that would help people the most, it would be easier for other things to fall into place after that. If policies are centered around people then our priorities will be in the right place.

TVA has little to no published information or planning about helping communities in transition. Will it be retraining workers? Will TVA and local power companies build renewable energy and invest in local energy efficiency in these communities? By now, you probably know the answer to date. 

 

TVA’s Lack of Ambition Regarding Renewable Energy

We’ve seen a lack of ambition from TVA regarding moving towards renewable energy, or any focus on energy storage and electric transportation. You’d think that electric companies would be out hawking electric cars as it would generate more revenue for them under the current structure. Much as they did with refrigerators and appliances in the 1940’s. However, what we’ve seen from TVA is the opposite. Their efforts seem focused on removing incentives for renewable energy and largely standing on the sidelines of the electrification discussion.

TVA’s Green Power Providers Program, launched in 2003, allowed regular people and businesses to sell excess energy from solar/renewable energy at a predefined rate. When it launched it was one of the most progressive programs in the country. It was very aggressive and provided above retail rates for renewable energy sources to stimulate economic growth. There was always an intention that those rates wouldn’t continue forever, and over the years the price of their buyback went down to around retail rates as expected.

Along the way, however, TVA decided distributed generation was a threat, not an economic driver. They got more aggressive and slashed the buyback below retail and then took it even further, paying a fraction of retail. What started as a reasonable reduction of the buyback rate, turned into a way for TVA to gut competition to their monopoly. Gutting buyback rates to the point where there was no economic incentive to participate; so, no one wanted to participate. When no one participates in a flawed program they had the justification to kill the program instead of just fixing it. While this was all happening, they were also trying to raise grid access fees (charging people more to even connect to the grid), basically decimating small scale solar in the process. Energy Alabama is currently challenging the “Grid Access Charge” in federal court.

TVA may market like it’s doing wonderful things with renewables but it is mostly hype. At the end of the day, they are doing slightly more utility scale solar that they own and operate but eliminating any options for the average person, small businesses, and communities. They can’t claim they are going to all this effort for renewable energy when they are planning a massive unneeded gas build-out.

 

TVA’s relationship with local power companies

When TVA was created and much of the south was being electrified, TVA grew quickly, much to the alarm of neighboring power companies like Southern Company. They didn’t like TVA growing into their territory. So when a private company doesn’t like something, they call their lobbyists. Federal legislation passed to put a fence around the TVA limiting where they could operate… and also limiting the ability of other utilities to operate inside that area.

TVA has long-term contracts with its local power companies. This is not uncommon in the utility industry and often referred to as “all-requirements” contracts. TVA has massive power plants that generate and sell power to local power companies that they then sell to their members. Contracts were typically 5-10 years, but today TVA is increasing the length of those contracts to 20 years with rolling contracts that require a 20-year notice to cancel. This makes it virtually impossible to get out of the contract.

This still wouldn’t be a totally terrible thing if TVA was responsive to the people. The new contracts claim to allow local power providers 3-5% choice in generation, giving them the option to choose things like rooftop solar and battery storage. It’s an improvement over the complete lack of choice they have now; but, as we see with other power providers across the country, 5% is just unsustainable. Other areas, like Colorado, have tried similar things and found that, given the abundance of cheap, renewable energy, you can hit the cap very quickly. Oh, and it turns out that what TVA said was 5% local choice, was really more like 1-2%. Chalk it up to fuzzy math.

The current setup only benefits TVA; not you and not local communities. It guarantees their revenue in perpetuity and hoses the rest of us, making sure we are always on the hook for TVA’s decisions regardless of how good or bad they are.

 

How can we get out from underneath TVA?

After understanding TVA’s long march away from public power values, there is a desire to just get out from underneath the TVA or to enact serious reforms. To some degree this is more possible now than ever before due to advances in technology. There are options for regular people or businesses to install renewables and energy storage, or for local power companies to substantially generate their own power and not necessarily rely on TVA.

For instance, Memphis is looking at leaving TVA, becoming their own independent utility, and saving a lot of money. That could be great for them. But it could also have a huge effect on any remaining members of the TVA as those costs are passed back.

There is no good answer here. Memphis has an obligation and a responsibility to take the possibility of hundreds of millions in customer savings seriously, and by all accounts it is. The rest of Valley must be concerned about the impact of Memphis leaving TVA. If Memphis did leave TVA, one could only hope it is a sizable enough event to wake TVA out of its slumber.

Memphis is a perfect example of the potential consequences of the failure to adhere to the core principles of public power. To be clear, Energy Alabama does not generally support privatization of public utilities. 

If only there were another way….

What you can do: Tennessee Valley Energy Democracy Movement

The Tennessee Valley Energy Democracy Movement was founded to return TVA to its roots, bring back good paying jobs, and benefit communities. In other words, put the public back into public power.

The largest objective is to bring the people power back to the TVA. It was founded as a public agency but has become less and less responsive to the needs, wants, and demands of the people who are supposed to be in charge of it. That’s you! 

We at Energy Alabama have joined the TVED Movement because we are excited about bringing that voice back.

The movement is about listening to the people and learning what they want their public power to do for them besides just sending them a bill.

Tennessee Valley Energy Democracy Movement is focused on:

  1. Efficient and renewable energy
  2. Local and decentralized generation – economic development opportunities, helping to ensure support of coal communities as those transition, making sure that the transition is equitable and fair for all.
  3. Democratic control – people want to know that their voice matters.
  4. Bills and equitable access – a lot of people don’t think about these issues beyond seeing their bill and struggling to pay it. We have extremely high poverty rates and people often struggle to decide whether to pay their electric bill or feed their family or pick up medicine. This is an unacceptable choice.
  5. Healthy communities and environment – making sure we aren’t just generating electricity but are also feeding the health of the people and the environment.  Here in the south we all have a very strong connection to the outdoors and nature. TVA should continue looking after those aspects as well.
  6. Safe, high quality jobs

How you can help:

  • Visit EnergyDemocracyYall.org and follow them on social media to learn more about the policy platform
  • Talk to your representatives about making sure that TVA is listening to the people. We are starting to see reps at the federal level starting to listen more and understand that we do want to preserve the public power and we need to be acting holistically to avoid privatization.
  • Talk to your local power company – local utilities are usually sub-units of the local government. They should be responsive to local leaders, to local residents.
  • If you are a member of a local electric cooperative, get involved. Run for office, vote, campaign to push these cooperatives to get involved in making change.
  • Keep an eye out for and join us at town hall meetings starting this summer.

It takes people power from the bottom up. 

 

TVA sign at Hyde Park, NY, By Billy Hathorn - Own work, CC0

Sources:

Energy Alabama, Center for Biological Diversity, and Appalachian Voices Call for Inspector General Investigation into TVA’s Membership in Utility Air Regulatory Group

Energy Alabama, the Center for Biological Diversity, and Appalachian Voices are calling on the Tennessee Valley Authority (TVA) Office of Inspector General (OIG) to open an investigation into TVA’s membership in and use of ratepayer dollars for the Utility Air Regulatory Group (UARG) and other unincorporated trade groups including the Utility Solid Waste Activities Group (USWAG), and Utility Water Act Group (UWAG).

To view the full document calling for the investigation, click here.

In a letter to the TVA OIG, advocates are voicing serious concerns about the use of ratepayer dollars for use in litigation and/or lobbying by UARG and its sister organizations. Any such activities would be in direct violation of TVA’s board-approved policy, which stated, “These organizations will not lobby on behalf of TVA or represent TVA in litigation without specific authorization to do so”.

TVA has repeatedly claimed the dues paid to UARG and related groups have not been used for litigation or lobbying. TVA’s own records demonstrate that its 2017 UARG dues were substantially higher than what UARG claimed went to technical expenses. TVA paid $462,967 to UARG in 2017, almost double the $265,721 UARG claimed was spent on technical expenses.

A reasonable observer can only conclude the difference of TVA’s dues were in fact spent on lobbying and/or litigation, which UARG described as “legal” expenses. TVA either gave permission to use ratepayer money for legal expenses or UARG broke its agreement with TVA.

In light of the facts outlined above, TVA appears to be in direct violation of the policy adopted by the TVA Board of Directors on November 10, 2016.

Therefore, TVA either provided specific authorization to UARG to lobby or litigate on its behalf, while refusing to disclose such authorization to the public, or TVA has violated its Board of Directors’ directive.

“What troubles us the most is that TVA forced its customers to make political speech by taking money from their utility bills and using it for DC-based lawyers,” said Daniel Tait, Chief Operating Officer of Energy Alabama. “Most Alabamians don’t like an arm of the federal government taking their money meant to keep the lights on in order to sue another arm of the federal government.”

“UARG and its secretive affiliates sue the federal government on behalf of polluters with the sole goal of weakening bedrock environmental protections,” said Howard Crystal, Senior Attorney at the Center for Biological Diversity.  “It’s appalling that TVA customers are being forced to subsidize these dirty efforts through their rate payments, which put utility profits above the public interest.”

TVA’s stated mission is to improve the quality of life throughout the Tennessee Valley through the integrated management of the region’s resources. This mission makes no provision for using ratepayer money to fund lobbying and/or litigation activities in the pursuit of regulatory rollbacks.

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