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rr <br /> r, <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 . 16 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 I: <br /> the associated risk of stranded costs and help local governments meet our stated climate and k <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- C <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 k <br /> environmental remediation to protect these - communities over the long term . <br /> 4 <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 - 1 65 requires I <br /> G <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 /> I <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/ I` <br /> 1 <br /> 11 <br /> 1 <br /> 1% <br />