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Agenda 05-21-24; 8-f - Comment Letter Addressing Duke Energy’s Proposed Carbon Plan Integrated Resource Plan Submitted to the North Carolina Utilities Commission
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Agenda 05-21-24; 8-f - Comment Letter Addressing Duke Energy’s Proposed Carbon Plan Integrated Resource Plan Submitted to the North Carolina Utilities Commission
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5/21/2024
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8-f
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12 <br /> look forward to our continued collaboration with and support for Duke in the design and <br /> implementation of cost-effective EE and DSM program offerings, especially ones that target LMI <br /> communities, in an effort to ensure expanded program eligibility serves those most in need. <br /> 5. Duke should adopt commercially proven resource generation technologies, <br /> including low-cost renewables, and phase out fossil fuels as soon as possible using <br /> the following strategies: <br /> 5.1. Retire and replace coal power plants with clean energy portfolios to improve <br /> public health outcomes and reduce ratepayer costs. <br /> Duke's proposed CPIRP Pathways 2 and 3 see more than 7 gigawatts (GW) of coal remaining <br /> online past 2030, compared to just over 2 GW in Pathway 1 (and compared to only 4 GW of <br /> coal remaining online past 2030 in the 2022 Carbon Plan proposal). In contrast, Energy <br /> Innovation has concluded that it would be significantly cheaper to build new wind and solar <br /> plants than to continue operating the coal plants in Duke's fleet.13 The longer these coal plants <br /> remain online past their economic life, the more costs customers incur and the more they <br /> negatively impact public health, the economy, and the climate. The CPIRP approved by the <br /> Commission should seek to more aggressively retire coal assets consistent with the schedule <br /> proposed in Pathway 1. Additionally, Duke should better model regulatory risks, such as future <br /> carbon taxes or other potential emission regulations which would make the economic case for <br /> these coal plants even less viable. <br /> Duke has also included almost 9 GW of new natural gas over the next 10 years to replace <br /> retired coal and meet large forecasted load increases, representing one of the largest gas build <br /> outs nationally. In addition to this being incompatible with North Carolina's decarbonization <br /> goals, it is not a prudent economic decision. A recent report found that clean energy portfolios— <br /> combinations of renewable energy, efficiency, demand response, and battery storage—are <br /> cheaper than more than 80 percent of proposed gas plant capacity.14 <br /> While fossil fuels like gas and coal are expensive and volatile, the costs of renewables and <br /> battery storage have consistently fallen faster than expected over the past few years. Even after <br /> accounting for the impacts of the circumvention investigation and inflation, the Ievelized cost of <br /> existing natural gas-fired generation is up 63% in the last year compared to 16% for new solar." <br /> NextEra recently announced that its Florida Power& Light subsidiary will add 92 GW of new <br /> solar and 50 GW of new battery storage capacity and achieve zero carbon emissions by 2045 <br /> without increasing customer bills. <br /> 13 Energy Innovation. Coal Cost Crossover 3.0 Dataset.January 2023,available at https:Henergyinnovation.org/publication/the- <br /> coa I-cost-crossover-3-0/. <br /> 14 Dyson, Mark,Grant Glazer,and Charles Teplin. The Growing Market for Clean Energy Portfolios+Prospects for Gas Pipelines <br /> in the Era of Clean Energy.2019.https://rmi.org/insight/clean-energy-portfolios-pipelines-and-plants. <br /> 15 NextEra Investor Conference,June 2022,available at https://www.investor.nexteraenergy.com/news-and-events/events-and- <br /> presentations. <br /> 10 <br />
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