Whereas, the Association of Tennessee Valley Governments (ATVG) represents local governments within more than 200 Tennessee Valley River Region Counties which closely monitor issues associated with the
Tennessee Valley Authority (TVA); and

Whereas, TVA's mission focuses on providing low cost, reliable electricity, environmental stewardship and economic development to the people of the Tennessee Valley; and

Whereas, the TVA Act of 1933 mandates that TVA provide power to its customers at the lowest feasible cost; and

Whereas, TVA is currently evaluating a proposal to purchase a large amount of wind generated electrical power from the Oklahoma panhandle from Clean Line Energy Partners, LLC, and transport It 700 miles using a single high voltage direct current transmission line that will bypass the existing network of power
lines to Memphis, Tennessee; and

Whereas, such a partnership between Clean Line and TVA would likely transport wealth outside the Tennessee Valley to the detriment of the nine million residents of the Valley; and

Whereas, TVA has stated that electricity demand in the Tennessee Valley is not expected to return to 2007 levels until 2020; and

Whereas, the nation's power grid is a complex, interconnected network of generating plants,
transmission lines and distribution facilities; and

Whereas, bypassing the grid to purchase electricity from such a long distance away increases security threats by providing additional exposure for natural or malicious events due to the extreme distance between generation and point of use without needed network redundancy; and

Whereas, wind is an intermittent power source that lacks the dispatch capability of other resources and does not eliminate the need for base load or dispatchable power plants like other more dependable resources such as nuclear, natural gas, coal and hydropower; and

Whereas, the number of property parcels and property owners that may be negatively affected by eminent domain as a result of the construction of this proposed 700 mile transition line is unknown;

now, therefore

BE IT RESOLVED by the Association of Tennessee Valley Governments (ATVG), that we strongly encourage the Tennessee Regulatory Authority to exercise caution as it considers the application of Clean Line Energy Partners, LLC, for a certificate of public convenience and necessity to operate as a
public utility with powers of eminent domain within the State of Tennessee until it is proven that its proposal meets TVA's obligation to provide reliable power to its customers at the lowest feasible cost.

1. Does purchasing electricity from this distance increase security threats to TVA's
power supply? Former U.S. Secretary of State George Schultz has said we should
pay attention to generating more energy where we use it because of national
security risks.

The power grid is a complex, interconnected network of generating plants,
transmission lines, and distribution facilities. This system is designed with
redundancy and resiliency at its core to ensure a reliable electric power system.
Some increase in security risk is unavoidable as distance increases between
generation and point of use. The extra distance provides additional exposure for
natural or malicious events to force a transmission path out of service. The potential
for an interruption with long duration to power supply increases if full transmission network redundancy is not provided or as greater amounts of supply are obtained
from more remote sources. The Department of Defense has become aware of this
risk; it is implementing a program to make its major installations self-sustaining in
energy to mitigate the potential interruption from the grid.

2. What is the cost of purchasing wind electricity compared to TVA generating or
purchasing other types of electricity generation?

TVA is studying the addition of new wind energy resources as part of the
development of its new Integrated Resource Plan (IRP). This process provides
opportunity for public participation. When TVA evaluates the cost of wind energy,
we include the value of the energy itself, as well as the cost to transmit out-of-valley
wind energy to the Tennessee Valley. In addition, there are costs associated with
the intermittent nature of wind generation. Through the IRP, TVA will rigorously
compare wind energy purchases against other alternative sources of energy
(renewables, new and existing TVA generating assets, or purchased power) to
serve local power companies and directly-served customers in a cost-effective
manner.
In FY2013, TVA's average fuel rates by asset type were as follows: nuclear,
$6/MWh; coal, $32/MWh; and gas, $39/MWh. The TVA average system fuel cost,
which includes hydro (no fuel cost) and purchased power, was $24/MWh. By
comparison, off-system wind purchases were $80/MWh (including transmission).
The cost of both wind and solar have trended steadily down in recent years. Lazard
Freres and Company, LLC, a leading financial advisory firm, does a periodic study
on the costs of renewable energy. Its most recent report states that the cost to
generate wind with the Federal production tax credit (PTC) is as low as $23 MWh;
without the credit, the costs are as low as $45 MWh. (Note that these are
production costs that do not take into account the cost of delivery to or the impact on
the TV A system.)

3. There is substantial opposition in Congress to the wind production tax credit. Will
TVA ratepayers be at risk of increased rates if the wind production tax credit is not
renewed?

TVA does not benefit directly from the PTC. As noted in the prior response, the
PTC has a material impact on the cost structure of wind developers and, in turn, the
price they can offer to TVA or other purchasers of the wind energy. Any TVA
purchase of wind energy would be under a long-term contract that would place risk
associated with the tax credit on the seller.

4. What is the reliability of purchasing wind power as compared to other types of
electricity generated by natural gas, nuclear, coal, or hydropower?

Because wind is an intermittent resource that lacks some of the dispatch capability
of other resources, it does not eliminate the need for base load or dispatchable
power plants like nuclear, natural gas, coal and hydropower. Adding intermittent
generation resources like wind can be challenging to manage, particularly as the
volume of generation from those sources increases. Wind patterns are fairly
predictable, but not entirely so; in addition, weather and other factors can affect
output. To maintain reliability, a wind energy purchaser must keep adequate
capacity and spinning reserves to cover the variability inherent to wind. Spinning
reserve is typically calculated as the amount of capacity available to cover the loss
of the largest generation source on the system. Utilities across the country have
been integrating more wind into their systems over the last several years, and TVA
already integrates 1,515 megawatts of off-system wind power. The industry has
growing experience with this issue, but it does make ensuring reliability more
complex.

5. TVA's peak power demands tend to be between 4:00 p.m. and 7:00 p.m. and wind
tends to mostly blow at night. How does wind power fit into TVA's overall demand
structure if the electricity isn't being produced when TVA needs it the most?

TVA analyzes historic and forecasted wind patterns to determine expected wind
deliveries at our system peak. Our forecasting and planning processes reflect
adjustment to wind generation at our summer peaks based on this analysis. Clean
Line has told us that a production profile provided by the independent meteorology
firm, 3Tier Oklahoma, shows that panhandle wind energy produces at about a 50
percent capacity factor between the hours of 4:00 p.m. and 7:00 p.m., thus
contributing to meeting peak demand. TVA's current wind resources produced
about 25 percent average capacity factor over that peak period last summer, with
significant variation each day (between 5 and 65 percent capacity factor). TVA will
take the seasonal and time-of-day energy patterns of wind into account when
evaluating adding additional wind energy to its portfolio.

6. At a roundtable in September 2013, hosted by Senators Corker and Alexander, you
said that TVA didn't need additional electricity generation capacity as the result of
reduced electricity demand. Has this projection changed?

Electricity demand is not expected to return to 2007 levels until the end of this
decade. We are projecting growth in demand of approximately 0.6 percent per year,
net of TVA's energy efficiency efforts. TVA believes that we have adequate
supplies to meet the near- to mid-term energy needs of the Valley reliably. Cleaner
energy sources, including nuclear, renewables, hydro and energy efficiency, provide
diversity within TVA's existing balanced energy portfolio. TVA is evaluating future
power needs and opportunities to meet them through the IRP. Wind and other
generating resources are regularly evaluated against existing or planned asset
additions to address changing conditions.

7. If the projection for TVA's electricity demand has changed since September 2013,
does it make more sense to purchase this wind power from Clean Line Energy
Partners, to build additional nuclear capacity, or to build additional natural gas or
coal capacity?

While demand over the next decade or so is predicted to be stable with low growth,
the TVA generation fleet is in transition. TVA has retired or will retire a substantial
portion of its coal fleet; we are committed to the completion of Watts Bar Nuclear
Plant Unit 2 and to a large new gas combined cycle plant in Paradise, Kentucky.
We have the potential to get incremental megawatts from the hydro system and a
significant amount from power uprates in the nuclear fleet. We have to either
retrofit, retire, or replace the Allen Plant in Memphis before 2019 under the terms of
an agreement with EPA and others. (Clean Line cannot supplant Allen because of
the need for a generation source physically located in that area to provide
transmission support that imported wind generation cannot provide.) In addition,
other market participants have approached TVA with expressions of interest to
provide electricity from gas, nuclear, wind and solar assets. TVA also factors in
energy efficiency and demand response programs into its resource decisions. The
recently announced draft 111 (d) rule from EPA, if enacted in its current form, will
also have a national impact on future decisions.
Clean Line will be evaluated in this context of low growth, transitioning fleet and
other options by application of the statutory mandate and guidance noted in the
preamble of this letter.

"We don't think a long time about things, she says.  "That seems like a good idea!  Let's do that!  That's the extent of our long range planning."

A majority of Americans oppose new high-voltage transmission lines in their community, but that opposition drops precipitously to 17% if those lines are delivering clean, renewable energy from wind. Support for new transmission lines leaps from just 46% to 83% when respondents are asked specifically about high-voltage transmission lines delivering wind power.

The survey of 1,239 adults nationwide was conducted last week (April 21-23) by The Saint Consulting Group, the political land use consulting firm that also issues the annual Saint Index© survey of attitudes toward real estate development projects, including energy-generation projects such as wind, nuclear and hydro facilities.

Ben Kelahan, energy practice leader at Saint Consulting, said the new results are a clear sign that Americans support cleaner, renewable power and that it has carried over to the distribution of that power through their own backyard.

“High-voltage transmission lines generate some of the most adamant NIMBY (Not In My Back Yard) opposition in the country. That such a large percentage of people are willing to allow green lines in their community says a lot about the awareness and importance of renewable energy and climate change issues in addition to the education efforts undertaken by the renewable energy industry,” Kelahan said.

I'm disturbed to see that you're regarding Lu Nelsen and Center for Rural Affairs as a primary source.  Center for Rural Affairs is not an intervenor in this project.  Center for Rural Affairs is a paid transmission advocate, through the RE-AMP program, it is paid to to promote transmission.

A CfRA Director also sits on the RE-AMP Steering Committee.   It's unfortunate that these facts are not included in your article -- this interest should be disclosed, because they are neither objective nor representing public interests or farmer interests.  If their paid advocacy was not disclosed to you, that's an even more significant problem.