OTHER-2024-036-Draft CPIRP letter

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communities in order to support emergency services and operations , transit , and other resilience needs . 5. 5. Prioritize and maximize tested technologies that are commercially viable before relying on unproven technologies that carry high risks for ratepayer dollars. As it works to adopt a 2024 CPIRP , the Commission should prioritize proven , cost -effective technologies (such as solar and wind ) that are already commercially viable and can be deployed in a timely manner before relying on energy sources that will require as yet uncertain technology advancement and thus put billions of ratepayer dollars at risk . Duke ' s proposed CPIRP assumes hydrogen will be widely available , cost- effective and can be blended into gas networks at a high percentage to power units that currently run on natural gas . However, research suggests that only up to 20 % hydrogen can be safely blended with natural gas in current pipelines and Duke does not include the cost of necessary retrofits (which can be 10 - 15 % of the cost of building a new plant) into resource planning 22 , 23 In addition , hydrogen -fired gas turbines that accommodate hydrogen blends higher than 30 % are not yet commercially available . 24 If the proposed new natural gas power plants cannot eventually be transitioned to burn 100 % green hydrogen , they may become obsolete and decommissioned years before ratepayers finish paying off the costs to build them . All three pathways Duke proposes also rely on more than 600 MW of nuclear from small modular reactors (SMRs ) by 2035 , even though this technology has not yet been proven and research indicates there may be significant environmental risks . For example , the SMR project previously under development by Nuscale in Utah spent more than a decade under development before it received its design certification from the Nuclear Regulatory Commission ,21 NuScale and the Utah Associated Municipal Power Systems ( UAMPS ) , which was slated to be an offtaker to the project , recently announced that they mutually agreed to terminate the project based on an anticipated lack of project subscription . 26 Given the uncertainty of whether SMRs will be commercially and economically viable at scale , the undersigned local governments encourage NCUC to prioritize and maximize proven , beneficial technologies (through all -source procurement as stated above ) in the CPIRP , and suggest performing pilot projects or allowing for technological advancement to prove cost effectiveness before investing large amounts of ratepayer dollars in unproven technologies . Due to our commitment to the health and safety of our communities , we also have safety and radioactive waste concerns related to SMR . The undersigned local governments recommend that Duke 22 Multiple resources indicate that up to 20% can be blended into the gas network safely . For example , an article by Dentons mentions "20/80 blend (hydrogen/methane , by volume ) is currently considered the upper limit . " Research by NREL (National Renewable Energy Laboratory) also concludes that " If the hydrogen level in natural gas increases beyond 20 % , the overall risk in service lines can significantly increase" . 23 Siemens Energy , 2020 . Hydrogen infrastructure — the pillar of energy transition , available at https ://assets .siemens- energy. com/siemens/assets/api/uuid : 3d4339dc-434e-4692-81 a0-a55adbcaa92e/200915 - whitepaper-h2-infrastructure-en . pdf 24 In Appendix O I Low-Carbon Fuels and Hydrogen , it is mentioned that "Turbine manufacturers , such as General Electric ("GE") , Mitsubishi and Siemens , have shown success with co-firing hydrogen and natural gas (up to 30 % hydrogen by volume ) without significant gas turbine revisions in many of the combined cycle and combustion turbine models currently in operation . " 25 Design Certification Application — NuScale , the U . S . Nuclear Regulatory Commission (NRC ) 26 NuScale , 2023 . Utah Associated Municipal Power Systems (DAMPS) and NuScale Power Agree to Terminate the Carbon Free Power Project (CFPP) [press release] . https : //www. nuscalepower.com/en/news/press -releases/2023/uamps -and -nuscale-power- agree-to-terminate-the-carbon-free-power-project 14