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<br /> longer sufficient to capture and respond to changes in the large load market. Following approaches in Georgia16
<br /> and Texas17—states also experiencing significant data center growth—the undersigned request that update reports
<br /> be filed more frequently(e.g., quarterly or monthly) and that individual large load requests be reported in a
<br /> structured dataset, including project load, queue status, and load ramp timing.
<br /> These measures will help ensure that planning decisions affecting millions of North Carolinians are evidence-
<br /> based and responsive to rapidly evolving market conditions.
<br /> 2. Require Duke Energy to plan for an affordable, reliable, and resilient energy system by optimizing
<br /> the existing grid and investing in cost-effective, least-risk electricity generation resources.
<br /> Duke Energy's Recommended Portfolio reflects North Carolina's projected economic growth by adding new
<br /> resources to maintain reliable service.The undersigned commend Duke Energy's commitment to procure
<br /> thousands of additional megawatts of solar, energy storage, and hybrid projects, recognizing these technologies
<br /> as essential components of a low-cost, reliable energy system. Investments in clean energy generation also create
<br /> jobs and support customer choices for electricity generation; in 2025, North Carolina ranked ninth in the country
<br /> for clean energy employment, supporting over 113,000 workers.18
<br /> However, Duke Energy's plans to meet near-term needs through adding natural gas generation and delaying coal
<br /> retirements and long-term reliance on indeterminate plans for nuclear, while minimizing proven technologies like
<br /> wind, pose significant economic and resilience risks for both the utility and consumers. Natural gas prices are
<br /> highly volatile, leaving consumers vulnerable to rate increases as fuel costs fluctuate. Greater reliance on natural
<br /> gas, as reflected in the Recommended Portfolio19 expose substantial price risk.This risk is validated by historical
<br /> data: from 2017 to Q12024, approximately 46-68%of the increase in the residential retail volumetric rate
<br /> stemmed from fuel costs, which coincided with high natural gas prices.20
<br /> Additionally, delaying coal plant retirements prolongs negative impacts to air quality and public health and
<br /> introduces further economic volatility for consumers.21 Duke Energy's CPIRP analysis acknowledges that coal
<br /> generation faces growing uncertainty due to declining domestic coal production,transportation challenges, aging
<br /> units, and an unclear regulatory outlook.These risks raise concerns about both grid reliability and long-term
<br /> system costs, and local governments are concerned that prolonging coal operations could shift these financial
<br /> burdens onto North Carolina ratepayers. Near-term investments in natural gas, paired with delayed coal
<br /> retirements, further heighten exposure to fuel price volatility and system risk, making energy prices more
<br /> unpredictable and potentially increasing bills for residents, small businesses, and low-income households.
<br /> 16 Order Adopting Stipulated Agreement,Attachment A,Georgia Public Service Commission Dkt. No.55378,(April 26,2024),
<br /> https://Psc.ga.gov/search/facts-document/?documentld=218484;see also Pablo Vegas et al.,Item 8.1:Long-Term Load Forecast Update
<br /> (2025-2031)and Methodology Changes,ERCOT(Apr.2025),https://www.ercot.com/files/docs/2025/04/07/8.1-Long-Term-Load-Forecast-
<br /> U pdate-2025-2031-a nd-M ethodo logy-Changes.pdf.
<br /> 17 ERCOT,Questions and Answers About the Large Load Interconnection Process(2025),
<br /> https://www.ercot.com/files/docs/2025/12/24/Large-Load-Interconnection-Process-Q-A.pdf.
<br /> 18 E2,Clean Jobs North Carolina 2025,(Nov.2025),https://www.energync.org/wp-content/uploads/2025/11/E2-Clean-Jobs-North-
<br /> Carolina-2025.pdf.
<br /> 19 The Recommended Portfolio over the Base Planning Period(through 2040)includes a net added 3,083 MW of nameplate capacity from
<br /> combustion turbines and 7,900 MW of nameplate capacity from combined cycles.
<br /> 20 EQ Research LLC,Issue Brief:The Role of Fuel Costs in Duke Energy's North Carolina's Retail Rates from 2017 through March 2024, (Apr.
<br /> 2024),https://www.edf.org/sites/default/files/documents/Issue Brief Narrative 4 22 24.pdf.
<br /> 21 The Optimal Coal Unit Retirements in the 2025 CPIRP(Table F-2)suggest delaying retirements of Belews Creek 1,Belews Creek 2,
<br /> Marshall 3,Marshall 4,and Roxboro 2 plants.
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