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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 levelized cost of <br /> existing natural gas-fired generation is up 63 % in the last year compared to 16 % for new solar . , 5 <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 : //energyinnovation . org/publication/the - <br /> coal -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 : Hrmi . 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 />