SEA provided support to Potomac Hudson Engineering (PHE) in their independent review of the Final Environmental Assessment (FEA) to the Paradise Fossil Plant prepared by the Tennessee Valley Authority (TVA). The work was requested by a law firm due to perceived inadequacies in the TVA’s FEA. SEA focused on identifying deficiencies in the areas of wetlands, floodplains, air and water quality, noise, and traffic. SEA’s findings were instrumental in PHE’s conclusions that the project should have been the subject of an EIS, had significant environmental impacts, and did not follow TVA NEPA procedures, CEQ Guidance, and several Executive Orders.
Wetlands/Floodplains Review and Findings
- Selection of preferred alternative fails to comply with EO 11988 (Floodplain Management) or 11990 (Protection of Wetlands)
- Wetlands analysis fails to clarify whether disturbances require Nationwide Permits or an Individual Permit from the USACE
- Cumulative impact analysis fails to provide examination of all past and future activities for the life of the project.
Air Quality and Energy Review and Findings
- EA fails to comply with EO 13514 (Federal Leadership in Environmental, Energy and Economic Performance)
- Greenhouse gas analysis fails to consider methane and N2O emissions
- Indirect impacts analysis does not include methane emissions from gas extraction and transportation to the plant