Only a tiny fraction of this IRP’s worldwide greenhouse gas emissions’ impacts on our fellow humans will be felt within TVA’s service area or within our lifetimes. University of Tennessee ethics professor John Nolt in 20111 conscientiously and conservatively calculated that each average American’s greenhouse gasses will cause “the suffering and/or deaths of one or two future people.” From that I calculated that per the 2024 IRP‘s 25-year strategies, barring economy-wide carbon regulation, about half of TVA’s essentially captive customers’ carbon footprint would continue to come from fossil sources, since normal upstream methane gas leakage makes methane as harmful as coal.2 Even with its nuclear and hydro generation, TVA would have contributed roughly 20% of its customers’ total GHG emissions. Over the 2024 IRP’s twenty-five years, then, not even accounting for now substantiated, largely irreversible, mutually accelerating warming feedback loops, TVA’s energy would have come at the horrifying cost of very roughly 666,000 to 1,333,000 future human casualties, from, per Nolt, “intensifying heat, storms, drought, wildfires, and floods, as well as rising ocean levels, the spread of tropical diseases, and forced migration with its attendant violence.” Both the 2026 IRP’s determination to indefinitely keep all of TVA’s coal plants operating alongside their intended replacements indefinitely and its elimination of new renewables, storage, etc., will greatly increase that casualty count.
That appalling slaughter would be the price of intentionally – and illegally, per Section 113 of the U.S. Energy Policy Act of 1992’s objective, least-cost planning requirement,3 – skewing the IRP’s conclusions by arbitrarily limiting the cheapest, fastest to build out, and cleanest generation, solar and the storage to make it 24/7; requiring the grandfathering-in of then-nonexistent gas plants; using high, long-obsolete solar and storage costs; and comparing overnight costs instead of the Act’s required “all direct and quantifiable net costs for an energy resource over its available life, including the cost of production, transportation, utilization, waste management, environmental compliance, and, in the case of imported energy resources, maintaining access to foreign sources of supply.”
All those knowing violations of the Energy Policy Act’s least cost requirement open TVA to costly lawsuits it's likely to lose. And as happened with tobacco lawsuits, as public opinion on climate harm shifts, judges will also be increasingly likely to hold TVA liable for the irrevocable harm the IRP will cause to us, our children, and every child to come, and to our now-verdant world.
I strongly urge the TVA Board not to approve the 2026 Integrated Resource Plan until it fairly – and legally – weighs the economic and the human costs of fossil fuel generation versus cheaper, more reliable, quicker-to-install, cleaner – and vastly more humane – solar and storage.
Thank you!
1. How Harmful Are the Average American's Greenhouse Gas Emissions? John Nolt, May 4, 2011
2. Evaluating net life-cycle greenhouse gas emissions intensities from gas and coal at varying methane leakage rates Deborah Gordon, et al, Environmental Research Letters, July 17, 2023 (Open Access) 3. Energy Policy Act of 1992