OTHER-2026-018-Comment Letter Addressing Duke Energy’s Proposed CPIRP

Browse Search

sensitivities. Following the 2025 CPIRP,the NCUC could have Duke Energy utilize an all-source procurement with an independently run and transparent evaluation process to meet forecasted demand with least-cost solutions. For the 2025 CPIRP,the NCUC ordered Duke Energy to include a report on how GETS can be leveraged for an efficient, cost-effective system.23 Local governments commend this step but encourage the NCUC to pursue additional actions to support least-cost, least-risk planning.These could include establishing a utility working group to study advanced transmission technologies (ATTs)24, identify which solutions are best suited to the system, and evaluate how they can enable new load interconnections.The NCUC could also request that Duke Energy publish a report on transmission system efficiency and points of congestion, assessing where ATTs could cost-effectively relieve constraints. Finally,the undersigned encourage the NCUC to consider hiring an independent engineering firm to work with the utility and/or system operator to identify near-term, cost-effective ATT deployments and long-term strategies. 3. Encourage Duke Energy to create viable, cost-effective clean energy procurement pathways for large customers, including local governments, to achieve established climate and clean energy goals. The Near-Term Action Plan (NTAP) and Recommended Portfolio create significant challenges for local governments and other large customers with near-term climate and clean energy obligations.The continued operation of coal plants, coupled with the addition of new natural gas resources, increases the share of fossil fuels in North Carolina's electricity mix over the next decade. While the Recommended Portfolio is projected to meet the statutory requirement of carbon neutrality by 2050, Figure 3-14 of the CPIRP shows that meaningful, sustained emissions reductions do not begin until the late 2030s. In the meantime, annual emissions across Duke Energy's Combined Carolinas system are expected to remain flat or even rise, peaking above 55 million tons of CO2 in 2036. Many North Carolina local governments have set clean energy or carbon reduction targets for 2030 or 2035—well before the emissions reductions anticipated in the CPIRP (Appendix A). Relying solely on Duke Energy's standard generation mix makes meeting these near-term public commitments effectively impossible.To comply with targets (some of which are legally binding) and public climate obligations, local governments need access to viable, cost-effective clean energy procurement options that deliver real additionality without excessive premiums or administrative burdens. Given the NTAP and Recommended Portfolio,the need for robust, scalable, and accessible clean energy procurement options for large customers is more urgent than ever. Programs such as Green Source Advantage (GSA) and GSA Choice have been essential tools for large customers seeking to directly support new renewable generation, demonstrating strong demand and attracting significant economic investment. However,these programs remain difficult for local governments to use due to complex processes, restrictive requirements, long timelines, and cost structures that can make participation financially or administratively prohibitive.These barriers directly suppress program uptake—an outcome misaligned with both customer demand and the Carbon Plan's intent. Accordingly,the undersigned recommend that the NCUC direct Duke Energy to establish a transparent, well-structured stakeholder engagement process dedicated to North Carolina local governments' procurement of clean energy. Local governments respectfully request that this dedicated process include clearly defined objectives,timelines, and milestones; a shared understanding of what specific program fixes or redesigns will be evaluated; greater transparency around program cost drivers; and a focus on creating procurement options that are easier, simpler, and as low-cost as possible for public entities and the residents they serve. A successful model already exists: the PowerPair stakeholder process, which local governments found valuable for its good faith collaboration,transparency, and opportunities to jointly explore technical and operational 23 Duke Energy Carolinas LLC and Duke Energy Progress,LLC 2023 Biennial CPIRP,Commission Dkt.No.E-100,Sub 190. 14 GETs include hardware and software technologies that improve functionality of the transmission system.ATTs encompass GETS and additional technologies,such as high-performance conductors. 6