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United States General Accounting Office: 
GAO: 

Report to the Chairman, Subcommittee on Legislative, Committee on 
Appropriations, House of Representatives. 

March 2002: 

Air Quality: 

TVA Plans to Reduce Air Emissions Further, but Could Do More to Reduce 
Power Demand: 

GAO-02-301: 

Contents: 

Letter: 

Results in Brief: 

Background: 

TVA Plans to Reduce SO2 and NOx Emissions but Increase Generating 
Capacity: 

TVA’s Demand-Side Management Programs Have Realized Few Savings to 
Date, but TVA Projects Bigger Savings in the Future: 

Other Utilities More Aggressively Pursue Demand-Side Management 
Programs: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments: 

Scope and Methodology: 

Appendix I: TVA’s SO2 Emissions, 1974-2010: 

Appendix II: TVA’s NOx Emissions, 1974-2010: 

Appendix III: Comments from the Tennessee Valley Authority: 

Table: 

Table 1: Peak Load Reductions from TVA’s Demand-Side Management 
Programs, Fiscal Years 2000 and 2005: 

Figures: 

Figure 1: Location of TVA’s Principal Power Generating Facilities: 

Figure 2: TVA’s Power Supply, by Source, Fiscal Year 2001: 

Figure 3: TVA’s Sources of Electricity Supply, by Hour, on a High-
Demand Day: 

Figure 4: TVA Expects Its SO2 and NOx Emissions to Decrease, and Its 
Capacity to Increase, Through 2005: 

Figure 5: TVA Plans to Rely Primarily on Sources Other Than Coal to 
Meet Demand, 2001-05: 

Figure 6: TVA’s Peak Load Reductions from Demand-Side Management 
Programs, Fiscal Years 1996-2000: 

Figure 7: TVA’s SO2 Emissions at Coal-Fired Plants: Actual Emissions, 
1974-2000, and Estimated Emissions, 2001-10: 

Figure 8: TVA’s NOx Emissions at Coal-Fired Plants: Actual Emissions, 
1974-2000, and Estimated Emissions, 2001-10: 

[End of section] 

United States General Accounting Office: 
Washington, DC 20548: 

March 8, 2002: 

The Honorable Charles H. Taylor: 
Chairman, Subcommittee on Legislative: 
Committee on Appropriations: 
House of Representatives: 

Dear Mr. Chairman: 

The Tennessee Valley Authority (TVA) operates the nation’s largest 
public power system, supplying electricity to about 8 million customers 
across a 7-state region. TVA directly serves 62 large federal and 
industrial customers and serves other commercial, industrial, and 
residential customers through a network of 158 power distributors. TVA 
relied on its 11 coal-burning plants to supply about 60 percent of its 
electric power in fiscal year 2001. These plants account for almost all 
of TVA’s emissions of two key air pollutants—sulfur dioxide (SO2), 
which has been linked to reduced visibility, and nitrogen oxides (NOx), 
which contribute to the formation of harmful ozone.[Footnote 1] 

Demand for TVA’s electricity will increase about 1.7 percent annually
through 2010, according to TVA projections. To meet this demand, TVA
estimates that it will need to expand its current generating capacity of
30,365 megawatts[Footnote 2] by 500 megawatts annually—nearly the 
equivalent of building an average-size power plant, or contracting for 
the power from one, every year. Building new generating capacity can 
result in additional emissions, which raises environmental concerns. 

In part to lessen the need for new capacity, TVA and other electricity
suppliers promote the efficient use of electricity through “demand-side
management” programs, which are designed to reduce the amount of energy 
consumed or to change the time of day when it is consumed. For example, 
some utilities offer their customers incentives to purchase appliances 
and lighting that use less electricity. When current customers use less 
electricity, the utility has to generate less power and thus may 
produce fewer emissions of air pollutants. 

Concerned about TVA’s dual challenge of reducing emissions while 
managing increased demand on its power system, you asked us to: (1) 
determine how TVA plans to meet future demands for electricity through 
2005 while minimizing its emissions of SO2 and NOx; (2) describe the 
scope and impact of TVA’s demand-side management efforts; and (3) 
compare the scope and impact of TVA’s demand-side management efforts to 
those of selected other utilities’ efforts. 

Results in Brief: 

Even though TVA intends to increase its capacity to generate 
electricity through 2005, it also expects to reduce its SO2 and NOx 
emissions during the same time period, primarily by (1) burning lower-
sulfur coal, (2) installing devices to control emissions at its 
existing plants, and (3) relying on fuels other than coal for new 
capacity. TVA expects to expand its capacity by more than 10 percent 
through 2005, with 79 percent of the increase slated to come from 
upgrading existing facilities and constructing new noncoal-burning 
facilities, such as turbines that run on natural gas or oil. TVA 
projects that its SO2 emissions will decline to 525,000 tons (a 28-
percent decrease from the 2000 level) and its NOx emissions will 
decline to 216,000 tons (a 25-percent decrease from the 2000 level). 

Although TVA’s demand-side management programs provide opportunities 
for thousands of its customers to reduce their consumption of 
electricity, these programs make modest contributions to reducing peak-
time demand—an average of 41 megawatts annually between 1996 and 2000 
(equivalent to 1/10th of 1 percent of TVA’s peak capacity). This 
reduction is less than it otherwise could be, in part because TVA has 
limited the scope of its key program to reduce peak-time consumption by 
residential customers; TVA believes the program is not cost-effective. 
TVA projects that its demand-side programs will produce nearly twice as 
much in savings during the period 2001 through 2005 as was achieved in 
the previous 5 years. However, about a third of this projection is 
based on the expected success of a program that began in June 2001. In 
October 2001, TVA began an evaluation of short-term opportunities to 
improve and expand its demand-side management programs. 

Other large utilities have more fully implemented the types of programs 
that TVA currently has in place and have also implemented a greater 
array of demand-side management tools. For example, like TVA, Florida 
Power and Light offers its residential customers a bill credit for 
allowing their water heaters and air conditioners to be switched off 
during periods of peak demand. However, Florida Power and Light has 
involved a much higher proportion of its residential customers in its 
program (about 19 percent) than has TVA (about 2 percent). Unlike TVA, 
Puget Sound Energy piloted a “time-of-use” program for 300,000 of its 
1.4 million residential customers to encourage less electricity use 
during periods of peak demand. The utility established different prices 
for electricity used during four periods of the day—ranging from 6.5 
cents per kilowatt hour at night to 9 cents per kilowatt hour during 
the day—and its customers’ bills depend on the amount of electricity 
used during each period. As a result of the program, customers shifted, 
on average, about 5 percent of their demand from peak to off-peak 
hours. 

In light of the limited scope and impact of TVA’s current demand-side 
management programs when compared to similar programs managed by other 
utilities and the potential benefits (including reduced emissions) that 
may be achieved through the use of additional demand-side management 
tools, we are recommending that TVA evaluate the structure and 
effectiveness of its current programs, review the longer-term potential 
applicability of other programs to its power system, and, as 
appropriate, expand its demand-side management programs. 

In its February 21, 2002, letter responding to a draft of this report, 
TVA described initiatives undertaken that are related to our 
recommendations (see app. III). 

Background: 

TVA was established in 1933 to provide flood control, navigation, and 
electric power in the Tennessee Valley region. As that area has grown, 
in both population and economic activity, TVA customers’ use of 
electricity has grown and is expected to keep growing. TVA estimates 
that demand for its electricity will increase about 1.7 percent 
annually through 2010. To meet its customers’ demand for electricity, 
TVA generates electricity not only at its 11 coal-fired plants 
(consisting of 59 generating units), but also three nuclear power 
plants (five units), 29 hydroelectric dams (109 units), one pumped 
storage site (four units), and five sites with combustion turbines (64 
units). (See figure 1.) It also generates power from landfill gas, 
solar, and wind projects, and it purchases power from others. 

Figure 1: Location of TVA’s Principal Power Generating Facilities: 

[Refer to PDF for image] 

This figure is a map of the Southeastern United States depicting the 
location of TVA’s principal power generating facilities. Three types of 
facilities are represented on the map: nuclear power plants; coal power 
plants; and hydroelectric power plants at dams. 

[End of figure] 

From the 30,365 megawatts of generating capacity available from these 
sources, TVA generated about 156 billion kilowatt-hours of power in 
fiscal year 2001.[Footnote] It also purchased roughly 9.9 billion 
kilowatt-hours of power. Of its power supply, 60 percent came from 
coal, 27 percent from nuclear, 6 percent each from hydropower and power 
purchases, and 1 percent from combustion turbines. (See figure 2.) 

Figure 2: TVA’s Power Supply, by Source, Fiscal Year 2001: 

[Refer to PDF for image] 

This figure is a pie-chart depicting the following data: 

TVA’s Power Supply, by Source, Fiscal Year 2001: 
Coal: 60%; 
Nuclear: 27%; 
Purchased power: 6%; 
Hydropower (including pumped storage): 6%; 
Combustion turbines: 1%. 

Source: TVA. 

Note: TVA also generated power in fiscal year 2001 from “green” sources 
(solar, landfill gas, and wind), which combined formed less than 1 
percent of power generated. 

[End of figure] 

The share of electricity generated by burning fossil fuels has 
implications for the environment. Burning fossil fuels produces SO2 and 
NOx gases, and the Environmental Protection Agency estimates that 
fossil fuel burning from utilities accounted for 67 percent of the 
nation’s SO2 emissions and 27 percent of its NOx emissions in 1999. 
Both gases can be transported over long distances following the 
patterns of air movements. SO2 emissions contribute to the production 
of airborne sulfate particles that contribute to acid rain, which can 
harm waters, forests, and materials. In addition, these particles can 
block the transmission of light, resulting in haze in urban areas and 
the degradation of scenic vistas in many national parks. NOx is also a 
source of acid rain and, through chemical reactions in the atmosphere 
with other pollutants, leads to the formation of ground-level ozone, 
the principal component of smog. Smog can cause chronic human health 
effects, particularly respiratory problems, as well as harming plants. 

TVA’s choices in generating power are constrained by laws, regulations, 
and internal policies. For example, the Clean Air Act, as amended, 
limits emissions of SO2 and NOx from coal-fired power plants. Moreover, 
the Tennessee Valley Authority Act, which established TVA, provides 
that the generation of power from hydroelectric units is a lower 
priority than navigation and flood control. Finally, an internal TVA 
policy limits the time period when TVA can draw down the lakes 
(reservoirs) that it manages for flood control and in the process 
generate hydropower. 

To meet its customers’ increasing demand for electricity, TVA can 
upgrade its existing plants, construct new plants, purchase power from 
others, or— as an alternative to finding additional supply 
sources—provide incentives to its customers—called “demand-side 
management”—to reduce or shift their demand for electricity. 

The Department of Energy defines demand-side management as actions 
taken on the customer’s side of the meter to change the amount or 
timing of energy consumption and identifies several types of programs. 

* Energy efficiency programs involve the use of technologies that 
reduce total energy use, during both peak and off-peak periods, such as 
energy-efficient lighting, appliances, and building equipment. 

* Peak load reduction programs focus on reducing load during periods of 
peak power consumption on a utility’s system. These programs can 
involve the use of technologies that smooth out the peaks (called “peak 
shaving”) in energy demand. Such technologies include control systems, 
such as switches attached to heating, cooling, and ventilation systems 
that allow the systems to be turned off during peak load times. They 
can also include rate-schedule programs where utilities structure their 
rates to encourage customers to modify their pattern of energy use. 

According to the Department, utility funding for demand-side management 
programs in the United States declined nationally between 1994 and 
1998, due in large part to increased competition and uncertainties 
regarding electricity deregulation. Funding for these programs leveled 
out in 1999 and slightly increased in 2000 as concerns over electric 
supply shortages in California led many utilities and state regulatory 
agencies to increase their emphasis on demand-side management. 

TVA can benefit from demand-side management, especially reducing peak 
loads, because electricity use varies substantially within a 24-hour 
period. For example, on August 17, 2000, an unusually hot day, TVA 
customers used about 67 percent more electricity during the hour of 
highest consumption (4 p.m.) than the hour of lowest consumption (5 
a.m.). TVA used its various energy sources in a sequenced manner to 
supply this electricity. (See figure 3.) Nuclear facilities provided 
power steadily throughout the day, while coal facilities provided power 
fairly consistently—somewhat lower at night and higher during the day. 
As demand increased during the afternoon, TVA increased the use of 
hydroelectric power and it purchased power from other utilities. 
Finally, during the hottest, mid-day hours, TVA used its combustion 
turbines. Even though TVA’s customers used more electricity on that day 
than on any other in its history, TVA officials told us that the 
sequencing of power sources was standard practice. 

Figure 3: TVA’s Sources of Electricity Supply, by Hour, on a High-
Demand Day: 

[Refer to PDF for image] 

This figure is a stacked multiple line graph depicting the hour by hour 
supply sources and the total load in megawatts. There are five sources 
of power depicted, as follows: 
Nuclear plants; 
Coal plants; 
Hydropower facilities; 
Interchange (power sales and purchases); 
Combustion turbines and cogeneration. 

Source: TVA. 

Note: The figure details TVA’s load and supply for Aug. 17, 2000. Coal 
generation includes coal burned to move water to pumped storage and 
hydro generation includes power generated from pumped storage. 

[End of figure] 

TVA Plans to Reduce SO2 and NOx Emissions but Increase Generating 
Capacity: 

TVA projects that its SO2 and NOx emissions in 2005 will fall 28 
percent and 25 percent, respectively, below its 2000 levels, despite a 
planned addition of 3,086 megawatts of generating capacity. TVA 
projects that its SO2 emissions will decline as it increasingly uses 
coal with a lower sulfur content at some of its coal-burning power 
plants. TVA projects that its NOx emissions will decline as it installs 
more control devices at its coal-burning plants. Moreover, TVA plans to 
increase its generating capacity largely from sources—other than coal-
burning plants—that generally emit less of these pollutants. Aside from 
constructing new generating capacity, TVA also plans to continue 
purchasing peak power in a range between 1,500 and 3,000 megawatts 
annually during the 2001 to 2005 period. (The emissions associated with 
purchased power—equivalent to 6 percent of TVA’s power supply—are not 
included in TVA’s emissions data.) Finally, TVA estimates that its 
demand-side management programs will offset new peak demand by 396 
megawatts between fiscal year 2001 and 2005. 

TVA Plans to Continue Reducing SO2 and NOx Emissions: 

TVA projects that the SO2 emissions from its coal-burning plants will 
decline from 727,000 tons in 2000 to 498,000 tons in 2003, before 
rising to 525,000 tons in 2005. (See fig. 4.) According to a TVA 
official, the expected increase after 2003 is directly related to 
planned increases in generating capacity at its coal plants. TVA 
attributes overall projected declines in SO2 emissions to the continued 
switching to coal with lower sulfur content at three plants.[Footnote 
4] Specifically, the lower sulfur coal is 0.5 to 0.6 percent sulfur, 
about half the sulfur content of the coal that is currently burned at 
these units. Moreover, according to the same official, even though SO2 
emissions will increase slightly from 2003 to 2005, the average 
emissions rate will remain unchanged during this period.[Footnote 5] 

Figure 4: TVA Expects Its SO2 and NOx Emissions to Decrease, and Its 
Capacity to Increase, Through 2005: 

[Refer to PDF for image] 

This figure is a combination vertical bar and line graph. Vertical bars 
represent calendar year emissions of SO2 and NOx in thousands of tons. 
A line represents yearly capacity changes in megawatts of power. 

Source: TVA. 

[End of figure] 

Beyond 2005, TVA has committed to further reduce SO2 emissions. In 
October 2001, TVA announced that it would install five additional 
scrubbers to limit SO2 emissions at its coal-burning plants between 
2006 and 2010.[Footnote 6] According to a senior TVA official, annual 
SO2 emissions from TVA coal-burning plants are likely to fall to around 
400,000 tons by 2010. 

TVA’s projections show a steady decline in its NOx emissions, from 
287,000 tons in 2000 to 216,000 tons in 2005. TVA attributes this 
projected decline to the planned installation of “selective catalytic 
reduction” systems—which remove nitrogen oxides from the exhaust 
gases—at some of its generating units at its coal-burning plants. TVA’s 
first such system began operating in 2000. According to TVA, by spring 
2005 it will have installed 18 of these systems, or similar such 
systems, which will control NOx emissions on 25 of its 59 generating 
units. 

Moreover, TVA expects to make even sharper cuts in its NOx emissions 
during the summer “ozone season” that extends from May through October. 
Ozone levels are higher during these months because emissions levels of 
NOx and natural hydrocarbons are higher, and there is more sunlight, 
all of which are needed for the formation of ozone, as well as higher 
temperatures, which speed up the chemical reactions. TVA expects its 
ozone-season NOx emissions to fall from 118,000 tons in 2000 to 43,000 
tons in 2005. 

(Additional information on TVA’s SO2 and NOx emissions from 1974 
through 2010 is included in apps. I and II of this report, 
respectively.) 

Capacity Increases to Come Mainly from Energy Sources Other Than Coal: 

Of the 3,086 megawatts of additional capacity that TVA plans to add 
between 2001 and 2005, more than half (1,658 megawatts) will come from 
“peaking” units, which are used only during the parts of the day when 
demand spikes. The rest of the new capacity (1,428 megawatts) will be 
base load units, which are used throughout the day. Most of this 
increased capacity will be generated through hydropower, natural gas, 
nuclear power, and other noncoal sources. (See figure 5.) 

Figure 5: TVA Plans to Rely Primarily on Sources Other Than Coal to 
Meet Demand, 2001-05: 

[Refer to PDF for image] 

This figure is a pie-chart depicting the following data: 

TVA Plans to Rely Primarily on Sources Other Than Coal to Meet Demand, 
2001-05: 
New construction: combustion turbines and other noncoal sources: 60%; 
Upgrades to nuclear and hydropower units: 19%; 
Power purchases: 16%; 
Upgrades to coal-burning plants: 5%. 

Source: TVA. 

[End of figure] 

To increase its base load capacity, in December 2001 TVA began 
purchasing power from a new 440-megawatt coal-burning lignite power 
plant in Mississippi. Although TVA does not own the plant, it purchases 
all of the facility’s output. To further increase its base load 
capacity, TVA plans both to upgrade existing units and to build new 
capacity: 

* constructing a 500-megawatt, natural gas-fired, combined cycle plant 
in Tennessee, to begin operating in 2003; 

* increasing the base load generating output at the Browns Ferry, 
Alabama, and Sequoyah, Tennessee, nuclear plants, between 2003 and 
2005, by 290 megawatts; 

* increasing turbine efficiency at three of its coal-burning plants 
between 2001 and 2005, adding 153 megawatts of capacity; and; 

* increasing its acquisition of “green power” (from landfill gas, 
solar, and wind sources) to 45 megawatts in 2005. 

To increase its own peak load capacity, TVA plans to add: 

* 1,336 megawatts of additional combustion turbine capacity, primarily 
in 2001 and 2002, at facilities in Mississippi and Tennessee; 

* 310 megawatts of capacity between 2001 and 2005 by continuing to 
modernize its hydropower and pumped storage facilities; and; 

* 12 megawatts of peak capacity by constructing a battery storage plant 
in Columbus, Mississippi. 

Finally, TVA plans to meet future needs by continuing to purchase power 
to meet peak-time demand. These purchases are expected to remain in the 
range between 1,500 and 3,000 megawatts through 2005. 

TVA’s Demand-Side Management Programs Have Realized Few Savings to 
Date, but TVA Projects Bigger Savings in the Future: 

Between fiscal years 1996 and 2000, demand-side management programs 
reduced TVA’s peak load by 204 megawatts (about 41 megawatts a year, or 
roughly equivalent to 1/10th of 1 percent of its overall capacity). 
[Footnote 7] Two programs accounted for these savings: the Energy Right 
Program, which promotes the installation of energy-efficient heat pumps 
and other electric appliances; and the Cycle and Save Program, which 
gives residential customers a bill credit for allowing TVA to switch 
off their water heaters and air conditioners during peak demand 
periods. TVA reported no savings from its rate-schedule program for 
commercial and industrial customers. Due in large part to a new program 
introduced in mid-2001, TVA plans to achieve a cumulative peak load 
reduction of 396 megawatts for the fiscal year 2001 through 2005 period 
(about 80 megawatts a year). Finally, TVA is studying ways to expand 
its demand-side management programs and increase their impact. 

TVA’s Demand-Side Management Programs Achieved Limited Energy Savings: 

Each year tens of thousands of customers participate in TVA’s demand-
side management programs. Such programs involve all major types of 
customers—commercial, industrial, and residential. Moreover, they are 
aimed at reducing electricity use both year-round and during peak 
demand periods. 

According to TVA, energy-efficiency and load-reduction programs saved 
97 megawatts in fiscal year 2000, and a cumulative total of 204 
megawatts from fiscal years 1996 through 2000. Furthermore, TVA expects 
these programs to result in an additional 120 megawatts of savings in 
fiscal year 2005 and a cumulative total of 396 megawatts from fiscal 
year 2001 through 2005. According to TVA, its peak load reduction 
impacts are to increase from 0.7 percent of peak load in fiscal year 
2000 to 2 percent of peak load in fiscal year 2005. 

The Energy Right Program Actually Increased Consumption: 

TVA attributes 74 percent of the energy savings for the fiscal year 
period 1996-2000 to its Energy Right Program. This program offers 
incentives to encourage contractors, developers, and homeowners to 
install energy-efficient electric appliances, such as heat pumps and 
water heaters. (TVA attributes the remaining 26 percent to a direct 
load control program, discussed below.) The Energy Right Program 
includes components for new homes, manufactured homes, heat pumps in 
existing homes, and self-audits by residential customers. (See figure 
6.) 

Figure 6: TVA’s Peak Load Reductions from Demand-Side Management 
Programs, Fiscal Years 1996-2000: 

[Refer to PDF for image] 

This figure is a pie-chart depicting the following data: 

TVA’s Peak Load Reductions from Demand-Side Management Programs, Fiscal 
Years 1996-2000: 
New homes: 32%; 
Direct load control: 26%; 
Heat pump: 24%; 
Manufactured homes: 14%; 
Self-audits: 4%. 

Source: TVA. 

[End of figure] 

The Energy Right Program, which has the greatest number of participants 
among TVA’s demand-side management programs, is designed to reduce 
residential customers’ consumption both year-round and during peak-
demand times through increases in energy efficiency. In fiscal year 
2000, 37,182 residential customers became participants in the program, 
a substantial increase from the 15,481 residential customers who became 
participants in fiscal year 1996. TVA anticipates that an additional 
58,900 new participants will join the program in fiscal year 2005. 

Similarly, TVA expects the program’s impacts to increase by fiscal year 
2005. The reduction in year-round consumption, which stood at 23,565 
megawatt-hours in fiscal year 1996 and 54,129 megawatt-hours in fiscal 
year 2000, is expected to reach 83,726 megawatt-hours in fiscal year 
2005. Also, the reduction in peak load demand, which was 19 megawatts 
in fiscal year 1996 and 43 megawatts in fiscal year 2000, is expected 
to reach 62 megawatts in fiscal year 2005. 

Table 1: Peak Load Reductions from TVA’s Demand-Side Management 
Programs, Fiscal Years 2000 and 2005: 

Name of program: Cycle and Save Program; 
Customers targeted: Residential and small commercial; 
Number of participants, fiscal year 2000[A]: 57,913
Estimated savings (in megawatts), 2000: 54; 
Estimated savings (in megawatts), 2005: 58. 

Name of program: Energy Right Program; 
Customers targeted: Residential; 
Number of participants, fiscal year 2000[A]: 37,182; 
Estimated savings (in megawatts), 2000: 43; 
Estimated savings (in megawatts), 2005: 62. 

Name of program: Interruptible Power Program; 
Customers targeted: Commercial and industrial; 
Number of participants, fiscal year 2000[A]: 396; 
Estimated savings (in megawatts), 2000: [B]; 
Estimated savings (in megawatts), 2005: [B]. 

Name of program: Load Buyback Initiative; 
Customers targeted: Large commercial and industrial; 
Number of participants, fiscal year 2000[A]: [C]; 
Estimated savings (in megawatts), 2000: [C]; 
Estimated savings (in megawatts), 2005: 37. 

Total: 
Estimated savings (in megawatts), 2000: 97; 
Estimated savings (in megawatts), 2005: 157. 

[A] For the Energy Right Program components, this is the number of new 
participants enrolled in fiscal year 2000. 

[B] TVA did not estimate the benefits of this program. 

[C] The program did not exist in 2000. 

Source: TVA. 

[End of table] 

According to TVA’s most recent estimate, the program’s overall effect 
on peak demand varied by season. For example, in 1996, the program 
resulted in an annual decrease of 19.4 megawatts in peak summer demand 
and an annual increase of 31.3 megawatts in winter demand, by providing 
incentives to developers and others to install appliances powered by 
electricity rather than natural gas or another energy source. According 
to TVA, such programs help improve the overall efficiency of its system 
and ultimately result in lower costs to consumers. 

TVA Limited the Scope of Its Load-Control Program: 

TVA’s Cycle and Save program allows TVA to turn off certain appliances 
in participating households for short periods when demand is high. TVA 
estimates that its Cycle and Save Program for residential customers 
accounted for about 26 percent of the savings realized from fiscal year 
1996 through 2000. On an annual basis, the program’s savings outpaced 
those attributed to the Energy Right Program. However, because the 
Cycle and Save Program’s benefits are not cumulative, the Energy Right 
Program accounted for 74 percent of the cumulative savings. 

TVA reduced the incentives it offered distributors to participate in 
the Cycle and Save Program and later restricted the number of 
distributors that may participate in the program. According to the 
program manager, TVA determined that the Cycle and Save Program was not 
cost-effective and allowed it to decline over time. As a result, peak-
time consumption was presumably higher than it would have been if TVA 
had not taken these actions. For example: 

* TVA shifted to the distributors the cost of purchasing, installing, 
and maintaining the switches that allow certain appliances to be cycled-
off. While TVA initially paid for all switches installed on appliances, 
including air conditioners, standard water heaters, and storage water 
heaters, it currently pays for the switches only on storage water 
heaters. TVA pays only for these switches because storage water heaters 
are cycled-off for a longer period of time than air conditioners and 
standard water heaters, thereby providing enough peak load savings to 
justify their costs. 

* Between 1992 and 1998, TVA reduced the amount of the monthly credit 
provided to participating distributors. It reduced the credit for 
storage water heaters from $5.70 to $5.50; for standard water heaters 
from $5.25 to $4.75; and for air conditioners and heat pumps from $1.40 
to $1.15 (dollar figures not adjusted for inflation). 

* TVA estimates that 30 percent of the radio-controlled switches that 
allow the water heaters or air conditioners to be cycled off are 
inoperable. TVA currently allows only 14 of its 158 distributors to 
participate in the program. According to the TVA program manager, as 
many as 30 distributors participated in the mid-1980s, but this number 
declined significantly after TVA eliminated incentives for distributors 
to participate in the program. The manager further noted that despite 
TVA’s changes in the program, several non-participating TVA 
distributors continue to express interest in participating in the 
program. 

TVA Reports No Energy Savings for Its Rate-Schedule Program: 

TVA offers rate discounts to its commercial and industrial customers 
who give TVA permission to interrupt their power during periods of peak 
demand (called “interruptible power contracts”). According to TVA, 51 
of the 62 large federal and industrial customers it serves directly 
have such contracts, as do 345 of its distributor-served commercial and 
industrial customers. TVA estimates that these contracts give it the 
ability to curtail up to 1,800 megawatts of power at times of peak 
demand. However, TVA seldom uses this tool. Between 1996 and 2000 TVA 
curtailed power under these contracts on only three occasions, and did 
not measure the savings it accrued. Moreover, according to TVA, the 
customers enrolled in these programs may reduce their consumption by 
300 or more megawatts in response to price increases. 

TVA Projects Bigger Demand-Side Management Savings in the Future: 

TVA projects that its demand-side management programs will save nearly 
twice as much in the fiscal year 2001 through 2005 period as they did 
in the previous 5-fiscal year period. Specifically, it projects 
cumulative savings of 396 megawatts through fiscal year 2005, in 
contrast to the 204 megawatts saved through fiscal year 2000. The 
higher level of savings stems from several factors: increased 
participation in its long-standing programs, and the introduction of a 
new “buyback” program for large commercial and industrial customers in 
June 2001. Specifically, this program allows TVA to buy power back from 
its large commercial and industrial customers whenever it is economical 
for these customers to curtail their power usage or when they can 
generate power from on-site sources. TVA expects that the program will 
reduce peak demand by an average of about 27 megawatts annually between 
fiscal years 2001 and 2005, or 133 megawatts overall for the fiscal 
year 2001 through 2005 period. 

In October 2001, TVA began a study of its demand-side programs, which 
it expects to complete in early 2002. According to the TVA project 
manager, the study’s goal is to identify ways to increase cumulative 
savings to 500 megawatts by the end of fiscal year 2003—75 more 
megawatts than the current estimate of 425 megawatts for fiscal year 
2003. The study will consider a range of options, including real-time 
pricing, rebates to consumers who purchase energy-efficient appliances 
(such as air conditioners and refrigerators), and incentives for 
industrial and commercial customers to install high-efficiency 
lighting. 

Other Utilities More Aggressively Pursue Demand-Side Management 
Programs: 

Some comparable utilities have gone further than TVA in implementing 
demand-side management programs that are similar to TVA’s programs and 
in operating other programs. In an effort to determine how other 
utilities are approaching demand-side management, we contacted four 
utilities with such programs: 

* The Bonneville Power Administration, which sells wholesale 
electricity, primarily generated by hydropower, in Idaho, Oregon, 
Washington, and a portion of Montana; 

* Florida Power and Light, a utility serving a large residential 
population in Florida; 

* Georgia Power, which serves retail customers in Georgia; and; 

* Puget Sound Energy, which sells electricity to retail consumers in 
Washington state. 

The utilities we selected serve different sections of the country and 
face differing regulatory environments. For example, Florida Power 
operates in a regulated environment and recovers expenses from an 
energy conservation cost recovery plan run by the Florida Public 
Service Commission. As compensation for demand-side management 
expenditures, Florida Power and Light requested reimbursement of more 
than $158 million from the Commission in 2000. 

Energy Efficiency Programs: 

Unlike TVA, the Bonneville Power Administration—an agency of the U.S. 
Department of Energy—offers a credit program to wholesale power 
customers who take action to further conservation and renewable 
resource development in the region. Bonneville offers utilities and 
directly served customers a rate reduction of one-twentieth of a cent 
per kilowatt-hour to develop their own conservation and renewables 
programs. 

Peak Load Reduction Programs: 

Like TVA, both Florida Power and Light and Georgia Power have load 
management programs for residential customers. Florida Power 
residential customers receive a bill credit if they allow the utility 
to switch off their air conditioners, hot water heaters, and pool pumps 
at peak times.[Footnote 8] The utility estimates that about 657,000 
(about 19 percent) of its residential customers participate in its load 
control program, as contrasted with about 2 percent of TVA’s 
residential customers. In addition, Florida Power has 14,285 businesses 
enrolled in a similar program for air conditioners. Florida Power and 
Light estimated that peak load savings from its program amounted to 941 
megawatts in 2000. Similarly, Georgia Power operates a program that 
cycles off power to residential air conditioners. The program, begun in 
1997, is projected to reduce peak demand by 44 megawatts in 2004. 

Also, like TVA, Georgia Power has 500 megawatts of interruptible power 
available. Though interruptions are rare, Georgia Power uses an average 
of 350 megawatts when necessary. In the summer of 2000, it interrupted 
power for a total of 12 hours over 3 days. 

Rate-Schedule Programs: 

Georgia Power and Puget Sound Energy have experience with time-of-use 
pricing programs—Georgia Power involves commercial and industrial 
customers, while Puget Sound Energy involves residential customers. 
Georgia Power started a real-time pricing program in 1992, and it has 
become the largest such program in the country, according to the 
Electric Power Research Institute. About 1,600 large commercial and 
industrial customers, or about 25 percent of such customers, 
participate in the program. In response to peak demands for power, 
Georgia Power can initiate a pricing “event.” The company uses e-mail 
to notify participating customers, a day or an hour ahead of time, that 
their prices during the event will be based on the marginal cost of 
producing power. 

During such an event, prices have two components: (1) a baseline charge 
and (2) either a marginal charge or credit, depending on how the 
customer’s energy use varies from its historic energy use. In August 
1999, when prices spiked to more than $1 per kilowatt-hour (15 times 
the average price),[Footnote 9] customers reduced their demand by 800 
megawatts. During typical peak events, customers reduce demand by an 
average of 300 megawatts. 

During 2001, Puget Sound Energy piloted a time-of-use program for about 
300,000 of its 1.4 million residential customers in order to get them 
to use less electricity at peak demand times. It established different 
rates for 4 time periods during the day—from a low of 6.5 cents per 
kilowatt-hour at night to 9 cents during the mid-morning and evening 
hours. Moreover, Puget Sound Energy’s state-of-the-art automated meter 
reading system allowed its customers to log on to its website and track 
their energy consumption throughout the day. The utility found that the 
customers involved in the “informational pilot program” (billed on the 
standard rate but provided with consumption information via the 
internet), on average, shifted about 5 percent of their consumption 
from peak to off-peak hours. Preliminary results indicate that those 
actually being billed on the time-of-use rate reduced their overall 
consumption by 6 percent. Subject to state regulatory approval, Puget 
Sound Energy said it plans to introduce the program to all of its 
residential customers in 2002. 

Bonneville Power has a demand exchange program for large industrial and 
commercial customers who are willing to curtail their consumption 
depending on electricity prices. Program participants are notified via 
the internet of hourly, 1-day-ahead, and 2-day-ahead prices that are 
associated with peak load events. Customers may respond, via computer, 
noting their willingness to curtail their use of power at the posted 
prices. 

Conclusions: 

While TVA plans to substantially reduce its SO2 and NOx emissions by 
three means—installing control devices, using lower-sulfur coal, and 
relying largely on noncoal sources for additional capacity—it could 
reduce emissions even more by more aggressively pursuing an existing 
fourth option—demand-side management. However, TVA’s demand-side 
management programs are generally limited in scope, and they contribute 
little to moderating future demand. As a result, to meet its customers’ 
growing demand for power, TVA will need to generate more power itself, 
or purchase more power from others, which will likely produce more air 
emissions. In contrast, certain other utilities have realized greater 
savings from their demand-side management programs. TVA’s recently 
commissioned study of opportunities to increase the short-term impact 
of its demand-side management programs may serve as a useful first 
step. However, TVA still needs to assess the potential contributions of 
demand-side management over a longer time horizon. 

Recommendations for Executive Action: 

TVA should reevaluate the design of its current programs and evaluate 
opportunities for adopting proven ideas from other utilities. 
Accordingly, we are recommending that the TVA Chairman (1) evaluate the 
structure and effectiveness of its current programs; (2) review the 
longer-term potential applicability of other programs to its power 
system; and (3), as appropriate, implement demand-side management 
practices. 

Agency Comments: 

We provided a draft of this report to TVA for review and comment, and 
received a letter from the Interim Vice President for Governmental 
Relations (see app. III). He said that TVA was evaluating its own 
demand-side management programs, including identifying potential 
opportunities, researching programs offered by other utilities, and 
analyzing the cost effectiveness of potential programs, all of which 
are consistent with our recommendations. In addition, he provided 
technical comments, which we have incorporated in the report as 
appropriate. 

Scope and Methodology: 

To determine TVA’s plans for meeting future power demands for 
electricity while minimizing emissions of SO2 and NOx and to describe 
the scope and impact of TVA’s demand-side management efforts, we 
interviewed officials from TVA and reviewed studies and other documents 
prepared by the Department of Energy’s Energy Information 
Administration and TVA. In addition, we interviewed three TVA 
distributors that participate in TVA’s demand-side management programs 
in order to hear their opinions on the programs’ strengths and 
weaknesses. In addition, we contacted experts at five non-governmental 
organizations—the American Council for an Energy Efficient Economy, 
Edison Electric Institute, Electric Power Research Institute, 
Regulatory Assistance Project, and Southern Alliance for Clean Energy. 

To describe the demand-side activities of other utilities, we contacted 
officials from, and reviewed studies and other documents prepared by, 
the Edison Electric Institute, the Electric Power Research Institute, 
and four utilities: the Bonneville Power Administration, Florida Power 
and Light, Georgia Power, and Puget Sound Energy. We selected these 
utilities for their geographic dispersion, diverse customers bases, and 
reputation for undertaking noteworthy demand-side management efforts. 
These utilities are not necessarily representative of other utilities 
in this country. 

We conducted our review between July 2001 and February 2002 in 
accordance with generally accepted government auditing standards. 

As arranged with your office, unless you publicly announce its contents 
earlier, we plan no further distribution of this report for 14 days 
after the date of this letter. At that time, we will send copies of 
this report to the Ranking Minority Member, Subcommittee on 
Legislative, House of Representatives Committee on Appropriations; 
Senator Fred Thompson; Representative Zach Wamp; the TVA Chairman; the 
EPA Administrator; and other interested parties. We will make copies 
available to others upon request. 

Questions about this report should be directed to me or David Marwick 
at (202) 512-3841. Key contributors to this report were Richard A. 
Frankel, Timothy Minelli, and Richard Slade. 

Sincerely yours, 

Signed by: 

John B. Stephenson: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: TVA’s SO2 Emissions, 1974-2010: 

The planned reduction in TVA’s SO2 emissions from 2001 to 2010 
continues the trend over the previous quarter-century, as shown in 
figure 7. TVA’s emissions dropped from 2,212,000 tons in 1974 to 
727,000 tons in 2000, and are expected to drop to 406,000 tons in 2010. 
This represents an 82-percent decrease over the entire period. TVA’s 
two primary means for reducing SO2 emissions from its coal-burning 
plants are (1) installing scrubbers that remove sulfur from smokestack 
gases and (2) decreasing the sulfur content of the coal it burns to 
generate electricity. 

Figure 7: TVA’s SO2 Emissions at Coal-Fired Plants: Actual Emissions, 
1974-2000, and Estimated Emissions, 2001-10: 

[Refer to PDF for image] 

This figure is a vertical bar graph depicting TVA’s SO2 Emissions at 
Coal-Fired Plants from 1974 through 2010. Actual SO2 emissions (1974-
2000) and projected SO2 emissions (2001-2010) are depicted in thousands 
of tons. 

Source: TVA. 

[End of figure] 

Between 1974 and 1995, when TVA reduced its annual emissions from 
2,212,000 tons to 876,000 tons, there were notable decreases in 1978, 
1982, 1984, and 1995. These decreases reflect the installation of 
scrubbers at TVA’s two largest plants (Cumberland in Tennessee and 
Paradise in Kentucky), as well as at Widow’s Creek in Alabama, in those 
years. Between 1995 and 2000, TVA further reduced its annual emissions 
to 727,000 tons, without adding any more scrubbers, by switching to 
lower-sulfur coal. Over those 5 years, TVA lowered the average sulfur 
content of its coal purchases from 2.26 percent to 1.88 percent. This 
decrease of about 17 percent is roughly equal to the proportional 
decline of SO2 emissions during that period. 

Between 2000 and 2010, TVA plans to use both strategies to further 
reduce its SO2 emissions. Through 2005, TVA plans to reduce its annual 
emissions to 525,000 tons, by continuing to switch to lower-sulfur 
coal. Beyond 2005, TVA plans to further reduce its emissions, by 
installing five scrubbers on 12 units at four coal-fired plants. This 
will increase to 60 percent the share of TVA’s coal-fired capacity 
operating with scrubbers. 

According to TVA, in 2001, TVA emitted SO2 at a rate of 1.18 pounds per 
million British thermal units of fuel energy. TVA expects the rate will 
decline to below 0.8 pounds per million units in 2010. This remains 
above the rate that plants considered new sources are required to meet, 
which is about 0.3 pounds per million British thermal units. 

[End of section] 

Appendix II: TVA’s NOx Emissions, 1974-2010: 

TVA’s planned reduction in NOx emissions at its coal plants from 2001 
to 2010 continues the trend that began after 1995, when emissions 
reached 530,000 tons. (See figure 8.) In that year, phase one of the 
Acid Rain Program (authorized by title IV of the Clean Air Act 
Amendments of 1990) started and TVA began modifying its coal plants to 
reduce their NOx emissions. 

By 2000, when the program’s second phase began, TVA’s annual NOx 
emissions had fallen to 285,000 tons. In that year, TVA’s first 
selective catalytic reduction system went into operation at its 
Paradise, Kentucky, coal plant. According to TVA, by spring 2005, it 
will have installed 18 selective catalytic reduction systems, or 
similar systems, on 25 generating units at 7 of its coal plants. TVA 
projects that, once these systems are installed, the NOx emissions from 
its coal plants will fall to 215,000 tons in 2005. NOx emissions shown 
in figure 8 reflect no additional controls beyond the 18 systems. 

Figure 8: TVA’s NOx Emissions at Coal-Fired Plants: Actual Emissions, 
1974-2000, and Estimated Emissions, 2001-10: 

[Refer to PDF for image] 

This figure is a vertical bar graph depicting TVA’s NOx Emissions at 
Coal-Fired Plants from 1974 through 2010. Actual NOx emissions (1974-
2000) and projected Nox emissions (2001-2010) are depicted in thousands 
of tons. 

Source: TVA. 

[End of figure] 

[End of section] 

Appendix III: Comments from the Tennessee Valley Authority: 

Tennessee Valley Authority: 
Jimmy Johnston: 
Interim Vice President, Government Relations: 
One Massachusetts Avenue, NW, Suite 300: 
Washington, DC 20444-0001: 

February 21, 2002: 

Mr. John B. Stephenson: 
Director, Natural Resources and Environment: 
U.S. General Accounting Office: 
441 G Street, N.W. 
Washington, D.C. 20548: 

Dear Mr. Stephenson: 

Comments By The Tennessee Valley Authority (TVA) On The Draft Briefing 
Report, Air Quality - TVA Plans To Reduce Air Emissions Further, But 
Could Do More To Reduce Power Demand: 

TVA appreciates the opportunity to comment on the subject report. As a 
public power provider and regional development agency, TVA is committed 
to balancing the interests of providing reliable, low cost power and 
improving the environmental performance of our operations. Knowing the 
responsibility inherent in being one of several public stewards of the 
Tennessee Valley's natural resources, TVA is continually researching 
and implementing the most cost effective means to improve our 
operations. 

As your report mentions, current WA programs project to dramatically 
reduce S02 and NOx emissions from our plants while also doubling the 
amount of savings from demand side management programs by 2005. 
Additionally, TVA is currently evaluating our demand-side management 
programs in an effort to identify additional opportunities for savings. 
This process includes identifying potential demand-side management 
opportunities, researching programs offered by other utilities, and 
analyzing the cost effectiveness of potential programs. This effort 
along with almost $3 billion in emissions control spending are strong 
examples of TVA's commitment to improving air quality in the most 
efficient manner possible. 

Enclosed are a number of other, more technical comments on the report. 

Sincerely, 

Signed by: 

Jimmy Johnston: 

Enclosures: 

[End of section] 

Footnotes: 

[1] Ozone is a colorless gas that occurs both in the earth’s upper 
atmosphere and at ground level. We use the term ozone to refer to 
ground-level ozone. 

[2] This total refers to net dependable capacity during the winter and 
includes both base load capacity (used throughout the day) and peak 
load capacity (used during times of peak demand). 

[3] Kilowatt-hours and megawatt-hours measure energy flows, while 
kilowatts and megawatts measure generating capacity. Thus, 1 megawatt 
of capacity used for 1 hour equals 1 million watt-hours (1,000 kilowatt-
hours) of electric energy. 

[4] TVA officials told us that lower sulfur coal is likely to be used 
at its Colbert, Alabama; Gallatin, Tennessee; and Paradise, Kentucky, 
coal plants. 

[5] Measured in pounds of SO2 emitted per million British thermal units 
of heat generated. 

[6] TVA committed to installing two scrubbers at its Kingston, 
Tennessee, coal plant and single scrubbers at its Bull Run, Tennessee; 
Colbert, Alabama; and Paradise, Kentucky, coal plants. 

[7] Reductions in peak-time demand are measured in megawatts. They 
represent reductions in the need to invest in or purchase incremental 
capacity to meet peak load. 

[8] The bill credit is $12.50 for summer months (April through 
October), if the customer enrolls for all three options, and $8.50 for 
winter months. 

[9] According to the Energy Information Administration, in Georgia in 
1999, commercial customers paid an average of 6.67 cents per kilowatt-
hour and industrial customers paid an average of 4.15 cents per 
kilowatt-hour. 

[End of section] 

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