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16 <br /> communities in order to support emergency services and operations, transit, and other <br /> resilience needs. <br /> 5.5. Prioritize and maximize tested technologies that are commercially viable before <br /> relying on unproven technologies that carry high risks for ratepayer dollars. <br /> As it works to adopt a 2024 CPIRP, the Commission should prioritize proven, cost-effective <br /> technologies (such as solar and wind) that are already commercially viable and can be deployed <br /> in a timely manner before relying on energy sources that will require as yet uncertain technology <br /> advancement and thus put billions of ratepayer dollars at risk. Duke's proposed CPIRP <br /> assumes hydrogen will be widely available, cost-effective and can be blended into gas networks <br /> at a high percentage to power units that currently run on natural gas. However, research <br /> suggests that only up to 20% hydrogen can be safely blended with natural gas in current <br /> pipelines and Duke does not include the cost of necessary retrofits (which can be 10-15% of the <br /> cost of building a new plant) into resource planning.22,23 In addition, hydrogen-fired gas turbines <br /> that accommodate hydrogen blends higher than 30% are not yet commercially available.24 If the <br /> proposed new natural gas power plants cannot eventually be transitioned to burn 100% green <br /> hydrogen, they may become obsolete and decommissioned years before ratepayers finish <br /> paying off the costs to build them. <br /> All three pathways Duke proposes also rely on more than 600 MW of nuclear from small <br /> modular reactors (SMRs) by 2035, even though this technology has not yet been proven and <br /> research indicates there may be significant environmental risks. For example, the SMR project <br /> previously under development by Nuscale in Utah spent more than a decade under <br /> development before it received its design certification from the Nuclear Regulatory <br /> Commission.21 NuScale and the Utah Associated Municipal Power Systems (UAMPS), which <br /> was slated to be an offtaker to the project, recently announced that they mutually agreed to <br /> terminate the project based on an anticipated lack of project subscription.26 Given the <br /> uncertainty of whether SMRs will be commercially and economically viable at scale, the <br /> undersigned local governments encourage NCUC to prioritize and maximize proven, beneficial <br /> technologies (through all-source procurement as stated above) in the CPIRP, and suggest <br /> performing pilot projects or allowing for technological advancement to prove cost effectiveness <br /> before investing large amounts of ratepayer dollars in unproven technologies. Due to our <br /> commitment to the health and safety of our communities, we also have safety and radioactive <br /> waste concerns related to SMR. The undersigned local governments recommend that Duke <br /> 22 Multiple resources indicate that up to 20%can be blended into the gas network safely. For example,an article by Dentons <br /> mentions"20/80 blend(hydrogen/methane, by volume)is currently considered the upper limit." Research by NREL(National <br /> Renewable Energy Laboratory)also concludes that"If the hydrogen level in natural gas increases beyond 20%,the overall risk in <br /> service lines can significantly increase". <br /> 23 Siemens Energy,2020.Hydrogen infrastructure—the pillar of energy transition,available at https://assets.siemens- <br /> energy.com/siemens/assets/api/uuid:3d4339dc-434e-4692-81a0-a55adbcaa92e/200915-whitepaper-h2-infrastructure-en.pdf <br /> 24 In Appendix O 1 Low-Carbon Fuels and Hydrogen, it is mentioned that"Turbine manufacturers,such as General Electric("GE"), <br /> Mitsubishi and Siemens,have shown success with co-firing hydrogen and natural gas(up to 30%hydrogen by volume)without <br /> significant gas turbine revisions in many of the combined cycle and combustion turbine models currently in operation." <br /> 25 Design Certification Application—NuScale,the U.S. Nuclear Regulatory Commission(NRC) <br /> 26 NuScale,2023. Utah Associated Municipal Power Systems(UAMPS)and NuScale Power Agree to Terminate the Carbon Free <br /> Power Project(CFPP)[press release]. https://www.nuscaIepower.com/en/news/press-releases/2023/uamps-and-nuscale-power- <br /> agree-to-term inate-the-carbon-free-power-project <br /> 14 <br />