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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 as
<br /> 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.16
<br /> However, Duke Energy's plans to meet near-term needs by adding natural gas generation, delaying coal
<br /> retirements, and relying on indeterminate plans for nuclear, while minimizing proven technologies like wind, pose
<br /> significant economic and resilience risks for both the utility and consumers. Natural gas prices are highly volatile,
<br /> leaving consumers vulnerable to rate increases as fuel costs fluctuate. Greater reliance on natural gas, as reflected
<br /> in the Recommended Portfolios', exposes substantial price risk.This risk is validated by historical data:from 2017
<br /> to Q12024, approximately 46-68%of the increase in the residential retail volumetric rate stemmed from fuel
<br /> costs,which coincided with high natural gas prices.18
<br /> Additionally, delaying coal plant retirements prolongs negative impacts to air quality and public health and
<br /> introduces further economic volatility for consumers.19 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 /> To support planning for a least-cost, least-risk system,the undersigned recommend that the NCUC pursue two
<br /> strategies: 1) adopting all-source procurement processes that expand and streamline opportunities to procure
<br /> renewable energy,and 2)evaluating targeted transmission and distribution upgrades that optimize existing grid
<br /> assets and reduce the need for costlier new generation.
<br /> There are precedents for these approaches.The Northern Indiana Public Service Company(NIPSCO)20 has
<br /> incorporated all-source procurement into its resource planning, and states such as Indiana21 and Utah" now
<br /> require utilities to study grid-enhancing technologies (GETs) in their integrated resource plans. Similar strategies in
<br /> North Carolina could improve system efficiency and reduce costs.The NCUC could require Duke Energy to conduct
<br /> an all-source procurement as part of the next CPIRP to gather real-world data to inform planning assumptions and
<br /> 16 E2,Clean Jobs North Carolina 2025,(Nov.2025),
<br /> httl2s://www.energync.org/wp-content/uploads/2025/11/E2-Clean-Jobs-North-Carolina-2025.1df.
<br /> "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 /> 18 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 /> 19 The Optimal Coal Unit Retirements in the 2025 CPIRP(Table F-2)suggest delaying retirements of Belews Creek 1, Belews Creek 2, Marshall
<br /> 3,Marshall 4,and Roxboro 2 plants.
<br /> 20 For its 2018 IRP,The Northern Indiana Public Service Company(NIPSCO)released an all-source procurement to gather information about
<br /> the lowest cost means to meet system needs.This process gave NIPSCO critical information that brought the reduced system forecast costs
<br /> down$1.1 billion in its 2018 IRP relative to the 2016 IRP,which did not include an all-source procurement practice.The lowered forecasted
<br /> costs were due to earlier coal plant retirements and investments in solar,storage,wind,capacity market purchases,and demand side
<br /> management as these demonstrated lower cost options relative to natural gas investments.
<br /> 21 Indiana law now requires all IRPs filed to study the use of at least one GET to meet demand starting in 2026 and include a description of
<br /> transmission and distribution systems starting in 2030(Ind.Code Ann.§8-1-8.5-3.4).
<br /> 22 As of 2025,Utah requires that utilities analyze GETs as a part of resource planning processes as well as general rate cases and
<br /> transmission system addition or expansion proceedings(Utah Code Ann.§54-17-11-1101).
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