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13 <br /> An increasing number of utilities have been canceling proposed gas plants before construction - <br /> one study found that over 50% of proposed gas plants were canceled from 2019-2021.11 The <br /> cost-effectiveness of renewables can be further advanced if Duke is able to capture economies <br /> of scale with bulk transmission and upgraded integration of large-scale renewable <br /> developments (discussed again later in section 7 of this comment letter). This is especially <br /> important to the development of offshore wind, a clean and abundant energy source for North <br /> Carolina. <br /> Accordingly, the undersigned local governments urge Duke to produce a more robust risk <br /> assessment of its maintenance of coal plants and proposed buildout of natural gas, as well as <br /> explore clean energy portfolios, ideally through all-source procurement, to help ratepayers avoid <br /> the associated risk of stranded costs and help local governments meet our stated climate and <br /> equity goals. When retiring coal plants, the undersigned local governments urge Duke to <br /> reinvest savings from switching coal to lower cost energy sources into transition assistance to <br /> help workers and communities prosper in a decarbonized economy as they face important near- <br /> term risks and costs in the transition. We encourage Duke to incorporate equity and <br /> environmental justice considerations during the coal retirement process, including <br /> environmental remediation to protect these communities over the long term. <br /> Additionally, to ensure the most optimal pathway, including minimizing stranded asset risk and <br /> ratepayer costs, we strongly encourage Duke to use all-source procurement for any additional <br /> capacity required. The benefits of all-source procurement are explained in detail below. <br /> 5.2. Run an all-source, competitive solicitation to procure all new generation sources <br /> and determine the best replacement resources. <br /> Transparent and robust all-source competitive procurement processes are critical to achieving <br /> carbon reduction goals at the lowest cost to ratepayers. Section 1(1) of S.L 2021-165 requires <br /> that the CPIRP should achieve the least cost path to achieve compliance with the authorized <br /> carbon reduction goals. As required by the S.L. 2021-165, 2,660 MW of new solar generation <br /> will be competitively procured, 55% of which would be owned by the utility and 45% of which <br /> would be supplied through power purchase agreements. Although partial competitive <br /> procurement is a step in the right direction, the undersigned local governments recommend that <br /> Duke utilize all-source solicitations for both power purchase agreements and any replacement <br /> resources owned by Duke. <br /> By allowing a full range of potential resources to compete on equal footing, all-source <br /> procurement can create a pathway for renewable energy, energy efficiency, demand-side <br /> management, and storage to play a critical role in addressing future energy and capacity needs. <br /> Selecting for market-based portfolios of optimal utility-scale and distributed energy resources <br /> can capture the value of interaction between resources, drive prices down, and benefit <br /> consumers. Experiences in multiple states demonstrate that all-source competitive procurement <br /> is a proven way to reduce costs for ratepayers while increasing access to cleaner electricity. For <br /> 16 Lauren Shwisberg, Alex Engel, Caitlin Odom, Mark Dyson, Headwinds for US Gas Power,2021, available at <br /> https://rmi.org/insight/headwinds-for-us-gas-power/ <br /> 11 <br />