OTHER-2024-036-Draft CPIRP letter

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territory and neighboring utilities , both within Duke 's grid planning region ( Southeast Regional Transmission Planning , SERTP ) and to neighboring transmission planning regions SERTP and PJM . Reports like " The Value of Transmission During Winter Storm Elliott" from ACORE underscore the importance of such connections for improving resilience and reliability , particularly during extreme weather events . Additionally , the joint GE and NRDC study on interregional transmission highlights the vast benefits of expanding interregional transmission throughout the Eastern Interconnection . This approach would not only diversify energy sources and enhance load management but also contribute significantly to the resilience and efficiency of the regional energy infrastructure , all while lowering costs for consumers . By broadening their transmission planning scope , Duke can advance a more sustainable and cost-effective energy future for the Carolinas , and for the broader Southeast region . Proactive , large- scale , long -term transmission planning approaches driven by future generation needs can drive cost- effective power system transformation . For example , the estimated . . average costs of coordinated onshore wind upgrades for renewables , including up to 17 GW of offshore wind , is significantly lower than the average costs of total network upgrades for current interconnection requests—totaling 15 . 5 GW offshore wind . 27 , 28 , 29 This difference implies that proactive , integrated grid planning for larger volumes of capacity additions can offer economies of scale and scope . Planning transmission and generation together can help unlock North Carolina ' s high offshore wind energy potential in a cost-effective manner. Unit transmission costs of offshore wind expansion could be reduced further by planning appropriately for high - capacity lines to enable access to large resource areas , which would be more efficient than an incremental , piecemeal expansion approach . This could capture economies of scale and reduce redundancies by building fewer lines to support more renewables . Inter- regional coordination and transmission expansion would further reduce cost . Researchers calculate that such approaches could reduce the system cost of electricity in a 100 % - renewable US power system by 46 % compared with a state- by-state approach . 30 Accordingly , the undersigned local governments recommend that the Commission direct Duke to integrate transmission planning into resource planning and procurement as well as plan jointly with neighboring grids . Communities of color and low- income communities often face the most health and environmental impacts from fossil fuel plants and energy infrastructure but often lack the 27 PJM ' s feasibility and system impacts studies for current interconnection requests totaling 15 . 5 GW of offshore wind estimate $ 6 . 4 billion in total network upgrade costs , which is as high as $400/kW . However, PJM 's Offshore Wind Transmission Study published in 2021 estimated the cost of coordinated onshore upgrades for 75 GW of renewables , including up to 17 GW of offshore wind , at $ 3 . 2 billion , an average cost of just $40/kW . Such a significant difference implies that proactive , integrated grid planning for larger volumes of capacity additions can offer economies of scale and economies of scope . 28 Based on costs from PJM ' s feasibility and system impact studies for individual generation interconnection requests as reported in Burke and Goggin , Offshore Wind Transmission Whitepaper, October 2020 at p . 40 . 29 PJM , Offshore Transmission Study Group Phase 1 Results , presented to Independent State Agencies Committee ( ISAC ) , July 29 , 2021 . 30 The Value of Inter- Regional Coordination and Transmission in Decarbonizing the US Electricity System . 16