Ashley Farless, PE, AICP NEPA Project Manager Tennessee Valley Authority 1101 Market Street, BR 4A Chattanooga, Tennessee 37402
[email protected] Dear Ms. Farless: The undersigned groups are writing to provide scoping comments on the Tennessee Valley Authority (TVA) Environmental Impact Statement for the Closure of CCR Impoundments (EIS). We are specifically responding to the request for comments that accompanied your August 19, 2015 Notice of Intent.1 In our view, a programmatic EIS is not an appropriate vehicle for consideration of the environmental impacts associated with closure in place or closure by removal at TVA’s CCR impoundments. As explained in more detail below, each of the eleven sites identified in the Notice of Intent have unique features, such as karst, relationship to the floodplain, seismic issues, proximity to the water, unique construction features, and long, varied histories. Each of these factors, and others, must be considered for each site and therefore, a programmatic EIS will not suffice. Indeed, a programmatic decision to adopt a specific approach to closure would predetermine the result of the required site-specific analysis in contravention of the informed decision-making mandate of NEPA. Under NEPA, TVA is required, at a minimum, to analyze the impact on each of the following environmental factors at the individual, site-specific level: Water resources (surface water, groundwater quality, and use); Vegetation; Wildlife; Aquatic ecology; Endangered and threatened species; Geology; Land use; Transportation; Recreational and managed areas; 1 http://www.tva.gov/environment/reports/ccr/. Visual resources; Archaeological and historic resources; Solid and hazardous waste; Public health and safety; Noise; Air quality and climate change; Socioeconomics and environmental justice.