Christina Cress Profile picture
Jul 17 510 tweets 87 min read
A thread summarizing Carbon Plan comments filed by intervenors. This thread is to relay info without editorialization. I'm NOT taking a position--good, bad, or indifferent--re: arguments raised by other intervenors.
A few other caveats:

-These summaries are limited to parties who have, as of today (7/16/2022), been granted intervention by NCUC

-Presented in order in which filed in docket

-Replies turned off because I can't/won't interact with any engagement from parties rep'ed by counsel
This thread will be long and will not be finished today. Mute me and/or this thread if you have no interest in energy reg/policy in North Carolina.
Acronym/jargon dictionary, 1/4:

NCUC = NC Utilities Commission
PS = Public Staff
NG = natural gas
CO2 = carbon dioxide
EE = energy efficiency
LMI = low- to moderate-income
DERs = distributed energy resources
T&D = transmission and distribution
tx = transmission
Acronym/jargon dictionary, 2/4:
CPCN = Certificate of Public Convenience & Necessity
CECPCN = Certificate of Environmental Compatibility and Public Convenience & Necessity
MVP = Mountain Valley Pipeline Project
OSW = off-shore wind
SMR = small modular reactor
PX = Portfolio X
Acronym/jargon dictionary, 3/4:
PVRR = present value of revenue requirement
HB 951 = House Bill 951, enacted as S.L. 2021-165 (N.C.G.A.)
SCC = social cost of carbon
Duke's Plan = Carbon Plan proposed by Duke Energy in its filing with NCUC in Docket No. E-100, Sub 179 on 5/16/2022
Acronym/jargon dictionary, 4/4:

DEC = Duke Energy Carolinas
DEP = Duke Energy Progress
Duke = DEC + DEP

I'm sure I'm inevitably neglecting to include some acronyms. Apologies.
First up: Brad Rouse, author of the book "Climate Warrior: Climate Activism and Our Energy Future." His comments are linked to this tweet. He says:

-Capacity planning modeling seems to be in part a "black box" to extent can't be replicated at this time…
Brad Rouse, 2/4:
-Investments in new NG or nuclear infrastructure should "move slowly" until discrepancies in modeling inputs/outputs are understood
-Retrofitting NG plants to accommodate hydrogen needs more R&D and is "inherently inefficient" means of electricity generation
Brad Rouse, 3/4:
-Rather than build new NG plants, Duke should be req'd to develop another portfolio where some coal is kept online longer for reliability reasons
"Burning coal needs to be minimized but retiring coal plants in favor of building new gas plants may be premature..."
Brad Rouse, 4/4:
-Duke should expand EE programs, LMI ratepayer assistance programs, and DERs

-Duke should be required to model a full electrification scenario by 2050, which would substantially increase the forecasted demand assumptions relied upon in Duke's Plan
Next up: Clean Energy Buyers Association (f/k/a REBA) (1/6). CEBA's comments are linked to this tweet. CEBA says:

-Large customers are demanding access to clean energy resources, which is important for economic development…
CEBA (2/6):

-Duke should leverage corp. investment to drive new project development, reducing costs & providing hedge against fuel price volatility for benefit of all customers

-Duke's Plan "does not meaningfully expand direct customer access to renewable generation resources"
CEBA (3/6):
-Duke's Plan prevents market demand from accelerating non-utility decarb investment in a more cost-efficient way

-Plan does not propose or model any new/expanded RE programs designed to allow large customers to supply/match their electricity usage with RE production
CEBA (4/6):
-Supports diverse gen mix, but states OSW is "a relatively expensive, high-risk generation source that often requires a captive customer-base to achieve economic feasibility[.]"

-Supports comprehensive regional tx planning to "unlock cost-efficient CO2 reductions"
CEBA (5/6):
NCUC should encourage Duke to join an RTO or ISO "in the event Duke demonstrates that it cannot be reliably expected to plan transmission with the goal in mind of meeting regional needs cost-effectively."
CEBA (6/6):
Interregional tx planning while honoring states' rights can proceed just like "regional transmission planning is conducted under existing FERC-jurisdictional tariff processes without encroaching upon states' rights to siting or related matters."
Next up: NC Council of Churches (1/4). Comments linked to this tweet:…
NC Council of Churches (2/4):

"NCUC must adopt a Carbon Plan that meaningfully (1) invests in programs to increase energy security and decrease energy burden and poverty, and (2) incorporates community input using active outreach and engagement with low-income ratepayers."
NC Council of Churches (3/4):
“Substantial investments to promote energy efficiency and the production of renewable energy through customer-owned generation will translate into increased reliability and affordability for hundreds of thousands of North Carolinians."
NC Council of Churches (4/4):

-Stakeholder process should “create expanded public participation and engagement opportunities.”

-Provides a list of demands to NCUC related to stakeholder participation and community outreach, including: Image
PAUSE. Will pick this thread back up with summaries of other intervenors' comments tomorrow.
To add a finer point, I *will* of course eventually take a position on the comments summarized in this thread, but my advocacy will happen in filings/appearances in various dockets at the NCUC, not this Twitter thread.
Picking this thread back up. As a reminder, please see disclaimers and caveats (as well as acronym/jargon dictionary) tweeted up-thread. Image
Next up: Public Staff - NCUC (1/x):

Comments of PS are linked here.…
Public Staff (2/x):

"Taken as a whole, [Duke's Plan] represents an earnest effort by Duke to meet the carbon reduction goals [set forth in HB 951], with an ambitious set of near-term actions and multiple pathways to achieve compliance."
Public Staff (3/x):

However, PS has three "overarching concerns" re: modeled assumptions:

1. Duke "may have overstated the magnitude of the need for NG generation by utilizing aggressive assumptions about hydrogen and NG availability and prices"
Public Staff (4/x):

2. Duke "may have undervalued some renewables through rigid solar and storage modeling and inflexible third-party assets"

3. Duke "may have understated the actual costs ratepayers will bear to implement the transition to carbon neutrality"
Public Staff (5/x):

PS reviewed Portfolios P1-4, in addition to the alternate portfolios, given that P1-4 are based on assumption that firm NG supply will be available via Appalachian gas delivered to NC by NG pipelines that have not yet been completed (MVP & MVP Southgate).
Public Staff (6/x):

-There are thousands of variables that could impact final PVRR/bill impact analysis

-"Due to the significant amount of uncertainty re: the assumptions made in each portfolio," not enough info for PS to select/endorse a particular portfolio
Public Staff (7/x):

Re: P1 - "has the most significant development risk because it relies heavily on interconnecting unprecedented levels of solar and batteries to meet the interim compliance goal, while simultaneously adding significant quantities of both OSW and SMRs."
Public Staff (8/x):

Re: P1, con't. - "Given the lengthy construction schedules estimated for tx system upgrades identified in Duke's recent Transition Cluster Study (TCS), the PS is not persuaded that [the buildout of solar gen contemplated in P1] is possible at this time."
Public Staff (9/x):

Re: P2 - "P2 may be unrealistic given the schedule for OSW development, even if it allows an additional year to bring the first SMR online."
Public Staff (10/x):

Re: P3 - "P3 has no OSW wind planned, ignoring significant resource potential in the Kitty Hawk and Carolina Long Bay lease areas, and instead relies on NG, solar, batteries, and SMR deployment to meet the interim goal in 2032."
Public Staff (11/x):

Re: P4 - "P4 relies upon a balance of resources and a slightly less aggressive interconnection schedule and may represent the most achievable portfolio, particularly given recent supply chain issues and inflationary pressures affecting the entire economy."
Public Staff (12/x):

At this time and based on info currently known, P1 (and to a lesser extent P2) appears to put ratepayers at "the most undue risk of significant rate impacts."
Public Staff (13/x):

"Given the development risks and costs of each portfolio, the PS believes that P4 currently represents the most feasible portfolio[.] However, at this time the PS is not selecting or endorsing any particular portfolio, as too much remains unknown, and . . ."
Public Staff (14/x):

"the iterative Carbon Plan updates should provide a process by which the short-term execution plan can be adjusted to align with long-term goals and developments."
Public Staff (15/x):

As such, PS recommends that the NCUC not "lock onto any one portfolio at this time," while also noting that "a diverse mix of resources, w/o overreliance on any single resource type," will provide Duke's ratepayers w/most robust/least cost path to compliance
Public Staff (16/x):

"All Proposed Carbon Plan portfolios project significant increases in customer bills through 2035, as the resulting increases in rate base and increasing NG prices more than outweigh any fuel cost savings from incorporating high levels of renewable energy."
Public Staff (17/x):

Execution risk will likely post most significant challenge to achieving CO2 reduction goals; simply selecting least-cost portfolio based on PVRR, w/o considering other factors, could "put ratepayers at significant risk of higher than projected costs"
Public Staff (18/x):

There are risks with all generating resource technologies and all portfolios. PS has analyzed these key risk factors across portfolios: Image
Public Staff (19/x):

Important to remember Carbon Plan implementation will be an iterative process, consistent with the biennial review process contemplated by HB 951. PS' "analysis will undoubtedly continue to evolve as these proceedings progress[.]"
Public Staff (20/x):

The costs of each portfolio as presented in Duke's Plan "do not paint a full picture of the total costs to ratepayers. For instance, many costs that are common to all portfolios, such as the Red Zone Transmission Expansion Plan (RZTEP) . . ."
Public Staff (21/x):

", ongoing spending on the Grid Improvement Plan, and storm securitization costs, are not included in the PVRR or bill impact analysis, which leads to understated costs."
Public Staff (22/x):

Not only are PVRRs and bill impact estimates for all portfolios "almost certainly understated," but "the growing rate disparity between the rates of DEC and DEP customers is likely also understated."
Public Staff (23/x):

Approx. 6% of DEC's annual energy demand is served by gen located in DEP territory in all four portfolios by model year 2032 (sic); by 2035, the % grows substantially, with P2 having the highest levels of transfers.
Public Staff (24/x):

"While amending the Joint Dispatch Agreement (JDA) between DEC and DEP could reallocate the costs of this arrangement between the two utilities, the PS is concerned that amending the JDA would be insufficient to equitably allocate shared Carbon Plan costs.."
Public Staff (25/x):

"Duke should promptly evaluate the steps necessary to consolidate the DEC and DEP utilities into a single operating entity and present the Commission with a timeline for implementation."
Public Staff (26/x):

Consolidation would "reduce inequitable cost allocation among customer groups, maximize planning efficiencies, and reduce administrative burdens by eliminating duplicate process and proceedings."
Public Staff (27/x):

PS recommends:
Duke be directed to develop a new portfolio (P5) including refinements listed below and provide results in a supplemental filing by Aug. 19 ImageImageImage
Public Staff (28/x):

In addition to the P5 model run described in previous tweet, PS recommends that the NCUC do all of the following: ImageImageImageImage
Public Staff (29/x):

Including complete snip of Paragraph 32 here. Image
Public Staff (30/x):

W/r/t interim compliance year, PS recommends NCUC consider several factors including but not limited to executability risk & relative costs of earlier compliance, given CO2 emissions of each portfolio follow similar trajectories to carbon neutrality in 2050.
Public Staff (31/x):

For ex, if interim compliance is delayed from 2030 (P1) to 2032 (P2), P2 emits incremental 36M short tons of CO2 thru 2050 while saving ratepayers $2.3B in present value costs.

(also meant to include this snip in prior tweet) Image
Public Staff (32/32):

While P1 could achieve interim compliance in 2030 at an avg. cost of $65/short ton, this outcome (compared to $51/short ton SCC) suggests that incremental cost to ratepayers to achieve earlier compliance is not justified by estimated SCC. Image
Next up: North Carolina Electric Membership Corporation (NCEMC) (1/x)

NCEMC's comments are linked here:…
NCEMC (2/x):

NCUC should utilize discretion provided in HB 951 and extend interim compliance timeframe to enable diverse gen portfolio, "make sure new facilities can be reliably integrated, and minimize rate shock to customers."
NCEMC (3/x):

-NCUC should address cost allocation issues between DEP's and DEC's customers

-NCUC should direct Duke to combine its two balancing authority areas (BAAs), as proposed in Duke's Plan
NCEMC (4/x):

-T&D investments should be thoroughly vetted through current NC tx planning process to determine reliability/enhanced capacity value as well as need

-All gen/tx investments should still be subject to full CPCN/CECPCN processes, respectively
NCEMC (5/x):

Duke should be req'd to continue working closely with NCEMC's Distribution Operator re: coordination and integration of DERs, both via ISOP and as part of the Carbon Plan
NCEMC (6/x):

P4 appears to satisfy "least cost and reliability requirements of HB 951. This portfolio has lower costs, provides the most diversity, and also has the greatest flexibility."
NCEMC (7/x):

"The longer time horizon [of P4] is consistent w/ the least cost planning and flexibility guardrails provided in HB 951, particularly for those portfolios contemplating emerging resources such as OSW and SMR."
NCEMC (8/x):

Duke should be req'd "to fully evaluate add'l off-system low-carbon or carbon-free resources, incl. any applicable tx and wheeling charges to ensure the reliability & availability of those resources, where they provide a cost-effective option" for HB 951 compliance
NCEMC (9/x):

NCUC should require Duke to provide a separate tracking of its corporate and HB 951 carbon compliance accounting to ensure each goal/target is being independently accounted for as it pertains to both compliance and cost allocation
NCEMC (10/10):

NCUC should direct Duke "to continue to evaluate the use of offsets as a least cost compliance mechanism up to the 5% limit allowed under HB 951, provided that the offsets are verifiable and permanent."
Next up, City of Asheville and Buncombe County (Asheville) (1/x):

Their comments are linked below.…
Asheville (2/x):

Both City of Asheville and Buncombe County have adopted GHG reduction goals, including to transition municipal and county ops to 100% carbon-free by 2030, and to transition all of Buncombe County to 100% carbon-free by 2042.
Asheville (3/x):

"[W]e see the Carbon Plan as a pivotal opportunity to expand our partnership with Duke Energy to create a reliable, affordable, resilient, and equitable system . . . We look forward to continuing this partnership and ask that the [NCUC] consider the following:"
Asheville (4/x):

-Duke should be required to "prioritize meeting the 2030 deadline" for compliance with HB 951 CO2 goals

-EE/DSM programs "should be improved to help local governments and other ratepayers address affordability and climate concerns"
Asheville (5/x):

Load forecasts "should be adjusted to proactively and accurately account for the impact of DSM programs and technological advances that reduce load as well as increased load that may result from transportation and building electrification"
Asheville (6/x):

-Tx planning "should be conducted in conjunction w/ capacity expansion & jointly w/ neighboring grids"

-NCUC/Duke should ensure Carbon Plan "builds upon the years of work stakeholders have invested into processes that led to the creation and passage of" HB 951
Asheville (7/x):

-Duke should retire/replace coal plants w/ clean energy portfolios "to improve public health outcomes and reduce ratepayers costs"

-Duke should run "an all-source, competitive solicitation to procure all new gen sources and determine best replacement resources"
Asheville (8/9):

-Duke should increase renewable energy procurement opportunities available to all customers

-Value and encourage development of DERs and "build community resilience through the use of DERs"
Asheville (9/9):

Duke should prioritize/maximize "tested technologies that are commercial viable before banking on unproven technologies that carry high risks for ratepayer dollars"
Next up, Person County (1/x):

Person County's comments linked here:…
Person County (2/x):

The NC "General Assembly has unambiguously indicated its intent that carbon reduction is an end toward which effort should be directed, but carbon reduction is not a hard and fast mandate or requirement that must be achieved at all costs."
Person County (3/x):

-"[W]hatever carbon plan that the [NCUC] develops must not impair the availability of adequate power supply resources nor the reliability of Duke Energy's service."

-NCUC has discretion to consider many factors, including "the impacts to local communities"
Person County (4/x):

-Person County is home to 2 Duke Energy coal plants: Roxboro and Mayo

-These plants employ 328 FT and contract Duke employees

-Duke is a "significant tax-payer to the County, providing tax revenues that are used to fund [many things]."
Person County (5/x):

-Carbon Plan will be expensive for all Duke customers

-"Siting replacement generation in Person County, where significant tx assets are available for use, tends to reduce the costs to Duke Energy's ratepayers" and aligns w/ least-cost mandate of HB 951
Person County (6/x):

-23% of total capacity to meet DEP's winter peak comes from coal-fired generation located in Person Cty

-"Considering that reserve margins have historically been in the range of 10% to 20%," retiring Mayo/Roxboro would have negative reliability consequences
Person County (7/x):

Person County "favors Portfolios 3 and 4, but cautions the Commission that the consequences for maintaining adequacy and reliability of the existing grid may be impaired from the premature closure of these plants"
Person County (8/x):

"Person Cty believes that the costs of blackouts & brownouts may exceed the cost of maintaining the Person Cty plants for emergency purposes. Moreover, a carbon plan that . . . results in blackouts & brownouts" is contrary to HB 951
Person County (9/x):

-Person Cty is a Tier 2 county w/ avg. household income of $54,553 and unemployment rate of 5.28%

-Rate increases stemming from Carbon Plan "will have a serious impact on the ability of the typical Person County resident to make (sic) ends meet[.]"
Person County (10/x):

-"Person County determines that only Portfolios 3 and 4 may be selected by the Commission in developing a carbon plan that is consistent with the requirements of HB 951 to undertake least-cost planning and [existing law]."
Person Cty (11/x):

-"Person Cty recognizes the need for more NG generation & applauds Duke for including NG generation in each of its four proposed" portfolios

-"If MVP is not completed, NC would likely continue to experience constraints on NG supply & associated rising prices"
Person Cty (12/x):

-If MVP not completed, NC "should look to its own NG resources"

-"If NG fracking in NC is not an acceptable solution, then the approval of MVP and MVP Southgate present the only realistic option for resolving NG constraints in" NC
Person County (13/x):

"If capacity constraints are not addressed and prices at Transco Zone 5 continue to be grossly excessive, NC customers will revolt against the higher costs needed to pay for the move to renewable energy."
Person County (14/x):

"Person County finds that NG is a critical 'bridge fuel' that is needed to support the economical operation of NG-powered electric gen as a replacement for" coal-fired gen"
Person County (15/15):

-Person Cty. supports delayed timeframe for compliance while new gen technologies are brought to market

-New gen / replacement gen should be located in Person Cty.
Next up: the Carolinas Clean Energy Business Association (CCEBA) (1/x):

CCEBA's comments linked here:…
CCEBA (2/x):

-HB 951 requires NCUC "to take all reasonable steps to reach 70% reduction of CO2 from 2005 levels by 2030, by the least cost method which maintains or improves the stability and reliability of the grid"

-None of 4 portfolios comply with HB 951 requirements
CCEBA (3/x):

-3 out of 4 proposed portfolios "seek extensions of time that have not yet been proven necessary"

-CCEBA generally agrees work proposed in Near-Term Execution Plan should begin "on those elements that would be consistent with all potential 2030 Carbon Plans"
CCEBA (4/x):

-Duke's constraint on solar procurements in the first 3 years "is unwarranted, skews the Near-Term Execution Plan, & increases the cost of the Carbon Plan for ratepayers"

-NCUC "should forcefully question & push back on premises behind Duke's proposed solar cap"
CCEBA (5/x):

-CCEBA recommends "comprehensive tx planning reform & urges the NCUC to direct Duke to take steps to reform the NCTPC process in order to advance the stated policy of HB 951..."

-CCEBA supports the RZTEP upgrades as critical interim steps to integrate more solar
CCEBA (6/x):

Duke's Plan "places unjustified faith in the development of [SMRs] and green hydrogen technologies, skewing its cost estimates in favor of [SMRs] and new gas generation and against solar, storage, and wind."
CCEBA (7/x):

CCEBA recommends a Near-Term Execution Plan "that lifts the cap on solar, mandates a procurement of both stand-alone storage and Solar+Storage, and encourages the development of off-shore wind resources in North Carolina."
CCEBA (8/x):

CCEBA recommends immediately commencing a stakeholder process to develop a Solar+Storage PPA that:

1. Adequately compensates developers
2. Incentivizes addition of storage to solar projects, and
3. Allows Duke to dispatch storage, consistent w/ HB 951 policy goals
CCEBA (9/x):

CCEBA "supports Duke Energy's recommendation to 'shrink the challenge' through adoption of EE and grid edge programs, but urges the Commission to use reasonable assumptions about the achievable volume of savings."
CCEBA (10/x):

CCEBA "supports Duke Energy's proposal to consolidate system operations across DEP and DEC, including [BAAs], Tx Operators, Tx Service Providers, and Tx Planners as during the near term of the Carbon Plan (2022-2024)."
CCEBA (11/x):

With regard to interim compliance timeframe, CCEBA states that "HB 951 does not authorize the Commission to allow for a delay of more than two years solely because the utility wishes to include nuclear or wind resources in the Carbon Plan." (emphasis on "not")
CCEBA (12/x):

"[W]hile the 70% required reduction in CO2 must take place at least cost and without hampering grid reliability, it nevertheless must be accomplished. One can conceive of HB 951 as adding a third leg to a stool, ... reduction of CO2 emissions."
CCEBA (13/x):

"Positive Attributes of the Carbon Plan":

-Duke's Plan "is a serious and detailed effort at presenting Duke's vision of how it can achieve" Carbon Plan goals

-Concept of Near-Term Execution Plan is good, even if needs some modifications
CCEBA (14/x):

Positive Attributes, con't.:

CCEBA appreciates proposed load reduction efforts through EE/Grid Edge programs; however, NCUC should not be "overly optimistic" about results, which "could lead to an artificially low forecast for the need for clean and renewable gen"
CCEBA (15/x):

Positive Attributes, con't.:
-CCEBA supports plan to combine DEC's and DEP's BAAs and related tx coordinating/planning

-CCEBA supports RZTEP upgrades
CCEBA (16/x):

Back to critiques--

"By not at least modeling an unconstrained solar interconnection in the first few years..., Duke has prevented a true comparison of cost & capability." Results of unconstrained model run should be assessed before interim compliance year delayed
CCEBA (17/x):

"Dependence on SMRs and green hydrogen brings with it substantial risk and uncertainty." Constraining solar/storage/OSW on assumption that "riskier technologies will be available in later years" poses risk of increased costs and delayed CO2 reductions.
CCEBA (18/x):

"In add'n to the tech & cost risks of [SMRs], [there are] significant operational risks. Foremost among these is the production & treatment of nuclear waste, which remains a significant issue with [SMRs] & may, in some cases, be worse than ... [traditional nukes]."
CCEBA (19/x):

Although recognizing may be a need for new NG gen "to provide flexibility in responding to load while integrating renewable generation on the system... The problem is that gas infrastructure is likely to be uneconomic before the end of the planning period[.]"
CCEBA (20/x):

Retrofitting NG plants to accommodate hydrogen may not be silver bullet. "[B]urning hydrogen is not without risk to equipment and the environment, and these challenges need to be overcome before hydrogen can be considered a viable clean energy option."
CCEBA (21/x):

"The cause of reducing CO2 emissions and modernizing NC's electric power system will not be served by repeating the bad bets made by the utility industry in such cases as the VC Sumner Nuclear Plant in SC and the Vogtle Nuclear Plant in GA."
CCEBA (22/x):

-NCTPC should be informed by Carbon Plan w/ NCUC direction

-SPP, CAISO, MISO & NYISO have successfully reformed tx planning

-If current OATTs terms do not allow for proactive tx planning, Duke should be req'd to seek necessary amendments/approval from FERC
CCEBA (23/x):

Solar+Storage "enhances the value of the solar gen & can provide substantial operational and cost-saving benefits to the grid & end users. Duke recognizes this potential value, but...its forecasted storage resources in its various portfolios are confusing[.]"
CCEBA (24/x):

Lots of discussion way down in weeds on stand-alone storage vs. Solar+Storage that I'm not even going to attempt to summarize here. Check it out for yourself at pp. 33-47 (if going off Adobe/PDF viewer, rather than page numbers shown).…
CCEBA (25/x):

Duke's Plan "likely overstates potential for onshore wind development (exclusive of imports)"

"While CCEBA not suggesting...onshore wind additions should be taken off the table, the high degree of uncertainty re near-term availability" falls in favor of more solar
CCEBA (26/x):

-CCEBA recommends that NCUC encourage OSW development in Near-Term Execution Plan

-In response to Duke's requests for relief, CCEBA responds as follows: ImageImageImageImage
CCEBA (27/27):

Remainder of CCEBA's responses to Duke's specific requests for relief: Image
Up next: NC WARN and Charlotte Mecklenburg NAACP (NC WARN/Char-Meck NAACP) (1/x):

Comments linked here:…
NC WARN/Char-Meck NAACP (2/x):

Battery storage "is a rapidly expanding technology" and many of Duke's competitors "consider solar paired with storage to have a production cost which is far less than natural-gas fired generation"
NC WARN/Char-Meck NAACP (3/x):

Relative lack of battery storage in Duke's Plan "is the result of several significant flaws in the...analysis," incl.:

-Flawed formula used to calculate # of hours of battery storage vs nameplate solar capacity

-Artificial/unnecessary constraints
NC WARN/Char-Meck NAACP (4/x):

-NG buildout in Duke's Plan "is based upon several flawed premises"

-Duke's Plan "candidly admits the uncertain nature of this [assumed conversion to Hydrogen by 2050]," yet have not analyzed what happens to new NG should hydrogen prove unworkable
NC WARN/Char-Meck NAACP (5/x):

-Duke's Plan "does not properly account for the volatility of NG pricing," among other flaws

-Proposed NG buildout "partly being driven by excessive reserve margins and unrealistic projected demand growth"
NC WARN/Char-Meck NAACP (6/x):

-Duke's Plan "projects far less NEM solar than was recently forecasted" in Duke's 2020 IRPs

-"In fact, the Companies' NEM tariff proposals in a separate docket will cause substantial harm to the proliferation of NEM."
NC WARN/Char-Meck NAACP (7/x):

"[A]t present, SMRs are not commercially viable, and it is entirely speculative that such technology will ever be practical. Therefore, the Companies' unrealistic proposal to purchase and install substantial amounts of SMRs should be rejected."
NC WARN/Char-Meck NAACP (8/x):

-Gov Cooper's EO 246 recommended NCUC consider the fed. social cost of carbon in its decision-making

-Duke's Plan "fails to address these social costs, esp. incl. the impacts...upon people of color, low-income communities & Indigenous communities"
NC WARN/Char-Meck NAACP (9/x):

Proposing a "counter carbon plan" which they contend "represents the least-cost mix of generation and would receive 100% carbon-free electricity by 2035." Elements of proposed "counter carbon plan" include:
NC WARN/Char-Meck NAACP (10/x):

1. "wholesale urban solar plus storage on C&I buildings and parking lots, large undeveloped urban parcels and brownfields"

2. adding 4 hours of battery storage to existing USS in NC

NC WARN/Char-Meck NAACP (11/x):

3. retiring coal-only units by 2024 and operating dual gas/coal units only on NG until retirement in 2035, and

4. converting nuclear units to synchronous condensers in the post-2035 timeframe.
NC WARN/Char-Meck NAACP (12/12):

In addition to "counter carbon plan" proposal, also recommending also follows: ImageImageImage
Next up: City of Charlotte (CLT) (1/x):

Comments linked here:…
CLT (2/x):

CLT has adopted aspirational goals

1. for its municipal fleet and facilities to be fueled by 100% zero-carbon sources by 2030, and

2. to become a low carbon city by 2050 by reducing GHG emissions to below 2 tons of CO2-equivalent per person annually
CLT (3/x):

"In addition to influencing the City's energy supply, Duke's Plan can also play an essential role in addressing energy burden and to ensure that inequities experienced by low-income CLT residents are mitigated rather than exacerbated through the [energy transition]."
CLT (4/x):

Duke should "improve EE/DSM programs to help local governments and customers address affordability and climate concerns," including

-Expand EE/DSM programs, esp for LMI ratepayers
-Increase annual energy savings target > 1% of full annual retail load
CLT (5/x):

-Utilize local gov's community connections to inform program design and improve customer participation rates

-Reassess value of DSM/EE through (1) factoring in tech advancement; (2) assuming increased participation enabled by on-bill financing; con't.
CLT (6/x):

(3) increasing estimated participation due to enhanced marketing and program targeting; and
(4) considering all cost-effective EE/DSM solutions from other reputable studies to evaluate program cost-effectiveness.
CLT (7/x):

Also makes following recommendations:
-Request Duke "to rerun its modeling and risk assessment of coal plan retirements and proposed buildout of natural gas to account for potential regulatory risks"

CLT (8/x):

-"Explore use of zero-carbon energy portfolios to help ratepayers avoid the associated financial risk of stranded assets"

-"Use all source procurement for new generation as well as in determining the optimal replacement resources for retiring coal capacity"

CLT (9/x):

-Increase RE procurement and resilience opportunities available to all customers

-Include more info re: envisioned customer RE procurement/program options, esp program capacity and timelines
CLT (10/x):

-Want customer RE program options that ensure long-term savings "and allow for contractual flexibility (e.g. term lengths)," include mechanisms for LMI participation, and consider "resilience benefits from renewably powered microgrids"

CLT (11/x):

-NCUC should account for all benefits provided by DERs

-NCUC should ensure future tx planning "prioritizes EJ and equity concerns and maximizes economies of scale to reduce unit cost"
CLT (12/x):

-"[T]ested technologies that are commercially viable" should be prioritized > other tech that has "the potential to carry high risks to ratepayer dollars"

-"Ensure equity is appropriately considered in siting of SMRs as well as spent nuclear...disposal sites"
CLT (13/x):

-Consider "establishing an appropriate min. technology readiness level be achieved before" included in Carbon Plan

-Ensure load growth forecasts "reflect known and emerging trends in transportation and building electrification"

CLT (14/x):

"Impacts of electrification of the electric system and implement best practices for managing load growth and matching increased demand with zero-carbon generation" should be fully analyzed

CLT (15/15):

-Need to further "optimize charging behaviors through rate design that charging and Vehicle-to-Grid services"

-Need to ensure local government feedback from stakeholder collaborations is incorporated into Carbon Plan
Next up: ElectriCities of NC, Inc., NC Eastern Municipal Power Agency (NCEMPA), NC Municipal Power Agency Number 1 (NCMPA1) (collectively, Power Agencies) (1/x):

Comments of Power Agencies linked here:…
Power Agencies (2/x):

The Carbon Plan "will impact the rates, terms, and conditions applicable to wholesale electric service and tx service supplied by DEP," tx service supplied by DEC, and retail electric service for ElectriCities.
Power Agencies (3/x):

-The Power Agencies seek to mitigate such impacts to the extent reasonably possible"

-Duke's Plan cannot be least-cost because it "makes no provision for peak load reduction or implementation of load management measures by wholesale customers"
-For example, recent changes to the FRPPA filed by DEP with FERC, "effectively imposes a firm cap on the quantity of load management for which NCEMPA can receive any financial credit. That cap imposes a significant financial impediment to load management and reduction efforts"
Power Agencies (5/x):

"Contract terms of this sort are inconsistent with [policy goals of] HB 951, & their continued presence forecloses the opportunity for DEP's wholesale customers to bring meaningful load management & reduction to the table through DSM, EE and DER measures."
Power Agencies (6/x):

"[F]acilitating load reduction & management by DEP's wholesale customers is cheaper (& therefore consistent with HB 951's least cost mandate), to the extent such efforts can eliminate the need for some portion of the expensive OSW and SMRs" in Duke's Plan.
Power Agencies (7/x):

"Given the relatively low cost of demand reduction measures, as compared to Duke's projected future costs for resources such as OSW and SMRs," the NCUC should require Duke to make comparable DSM/DR programs available to NCEMPA and other wholesale customers.
Power Agencies (8/x):

"If properly incentivized NCEMPA could add BESS and other DSM/DR programs designed to manage the NCEMPA/DEP system load, which would allow DEP to avoid having to add the highest cost capacity resources (e.g., OSW and/or SMRs)."
Power Agencies (9/x):

Duke's Plan "includes significant transmission upgrades the need for which is unproven and likely to be inconsistent with HB 951's least cost mandate."

-If RZTEP is not part of "least cost" path to compliance, it cannot be part of approved Carbon Plan
Power Agencies (10/x):

-Power Agencies concerned w/ specific aspects of RZTEP, incl:

(1) "Duke proposes to not require any up-front payment from any solar QF for the capital costs of the RZTEP upgrades necessary to interconnect their facility"
Power Agencies (11/x):

(2) "Likewise, Duke proposes that there would be no allocation of the cost of the RZTEP upgrades to any solar QF (although there may be additional network upgrade and interconnection costs associated with individual solar QFs allocated to those QFs)"
Power Agencies (12/x):

Neither 1 nor 2 above "comports w/ current North Carolina Interconnection Procedures, Forms and Agreements, which requires the interconnecting generator to bear the cost of interconnection & network upgrades necessary to facilitate its interconnection."
Power Agencies (13/x):

Duke's proposed cost recovery for RZTEP upgrades "also raises question of under what circumstances Duke will pursue, and expect to obtain, full cost recovery in wholesale transmission rates & bundled retail rates for the capital costs of" RZTEP upgrades.
Power Agencies (14/x);

"Duke cannot know at this point which solar facilities may ultimately be built to eventually utilize the proposed RZTEP upgrades, or if those facilities will be located in the areas Duke modeled in connection with planning the RZTEP."
Power Agencies (15/x):

"The significant issue here is not whether generation will come to the proposed network upgrades (it likely will, eventually), but whether this is the path to achieving least cost compliance with HB 951."
Power Agencies (16/x):

"The Power Agencies challenge Duke's underlying assumption that the RZTEP's field of dreams 'Build It and They Will Come' approach is a path to complying with HB 951's least cost directive."
Power Agencies (17/x):

"Until the lowest cost resources are identified, it is not possible to know where they will be located -- and therefore, to know where any necessary network upgrades must be constructed."
Power Agencies (18/18):

RZTEP "is simply a speculative high risk bet that the...upgrades will attract the lowest cost generation. There is no assurance that this will be the case."

-"Existing established processes for approval and recovery of such" tx investments should control
Next up: Carolina Utility Customers Association, Inc. (CUCA) (1/x):

Comments linked here:…
CUCA (2/x):

Major themes - NCUC should:
-"remain steadfast in its commitment to least-cost planning"
-"refuse to preordain any cost recovery or CPCN approvals"
-"carefully scrutinize Duke's insistence to build NG plants immediately, despite no guarantee of add'l NG supply in NC"
CUCA (3/x):

Major themes - NCUC should, con't.:
-"protect the reliability of our electric grid"
-"enlist customers--in particular, large customers--in our State's carbon-reduction efforts by establishing new cost-competitive customer renewable programs."
CUCA (4/x):

Elaborating on first theme of emphasis on least-cost planning:

-[T]raditional least-cost principles should apply to any new generation assets" Duke proposes to construct or own.

CUCA (5/x):

-It's "difficult to ascertain whether a new resource is the least-cost option for NC ratepayers without knowing whether SC ratepayers will share the resource's cost."
CUCA (6/x):

-Duke "may exceed statutory CO2 reduction targets only if add'l emission reductions will save ratepayers more money"

-NCUC "should ensure that all sub-critical coal plants that are retired are subject to securitization," not just those retired for HB951 compliance
Elaborating on 2nd theme re: pre-determination of cost recovery/CPCNs:

-Carbon Plan proceeding "is not a substitute for a CPCN proceeding," nor is it a cost recovery proceeding

-NCUC "should specifically reject Duke's request for deferral accounting of the development costs"
CUCA (8/x):
Elaborating on 3rd theme re: Duke's Plan to build new NG despite no guarantee of add'l NG supply to NC:

-Duke's Plan "fails to confront the natural-gas crisis facing North Carolina--and, instead, pushes forward with building more gas plants despite the crises"

CUCA (9/x):

-Duke's Plan fails "to account for the price volatility of NG in NC"

-Duke's modeling "failed to account for a lack of more NG"

-Duke's modeling "failed to use realistic forecasts for NG prices"

-"Duke must present a better plan for the risks associated with NG"
CUCA (10/x):

Elaborating on 4th theme of reliability:

"When selecting intermittent renewable resources ..., the NCUC should backstop the resources with availability of dispatchable resources." RE has lower marginal costs & enviro impacts, but intermittency still challenging
CUCA (11/x):

Elaborating on 5th theme of leveraging large customers to help reduce CO2 emissions:

"Many ratepayers are ready, willing, and able to invest in renewable resources..."

CUCA (12/x):

"In particular, some commercial customers are willing to install their own renewable generation to accomplish their own ESG targets, and some industrial customers are eager to have the freedom to purchase clean energy that matches their demand."

CUCA (13/x):

"In each case, the consumers are ready to reduce CO2 and pay for increased cost themselves" (emphasis omitted). "This is a double win for...ratepayers: reduced emissions & at no cost to remaining ratepayers. Customer empowerment is the optimal least-cost pathway"
CUCA (14/x):

-HB 951 calls for a "voluntary program that will allow" customers to purchase from Duke RE "to offset their energy consumption"

-Current program (GSA) is almost entirely subscribed and insufficient to allow NC's industrial customers to offset consumption w/ RE
CUCA (15/15):

Duke "should join stakeholders in proposing specific programs and tariffs that allow industrial customers to contract with RE sources and pay for tx service through the Duke system," in furtherance of least-cost path to meet CO2 emissions reduction goals in HB 951.
Next up: Walmart, Inc. (Walmart) (1/x):

Comments linked here:…
Walmart (2/x):

"Walmart generally supports [Duke's] proposal not to select a specific path forward for HB 951 compliance at this time and does not oppose [for the limited purposes of this first Carbon Plan proceeding],approval of the Carbon Plan for modeling purposes only."
Walmart (3/x):

"The Commission should confirm that any ruling in this proceeding does not alter [Duke's] burden to obtain approval of a specific project or cost recovery in a future proceeding," including but not limited to CPCNs, CECPCNs, and future rate cases.
Walmart (4/x):

-Duke has "failed to justify proposal to add 2.4 GW of new NG in this proceeding."

-"It is premature to find that project development activities are 'reasonable and prudent' for purposes of cost recovery."
Walmart (5/x):

-Duke's request to "recover costs for projects not placed in service is contrary to typical FERC accounting rules. It also improperly shifts" risk to ratepayers

-Even if statutory authority exists to recover project dev. costs, Duke hasn't carried burden of proof
Walmart (6/x):

"It is particularly inappropriate to shift such significant risk to ratepayers for projects" Duke expects "to need for Carbon Plan compliance"

-E.g., Dominion incurred b/w $300-$400M in dev./pre-construction costs before seeking approval of Coastal VA OSW Project
Walmart (7/x):

"It is especially important that the NCUC take steps to protect ratepayers from [Duke's] request to recover costs of certain dev. activities b/c the magnitude of potential costs is significant, and [Duke has] proposed no limitations on the costs they might incur."
Walmart (8/x):

Even if NCUC were to approve some level of dev. cost recovery prior to Duke seeking certification of new gen, NCUC should:

-Require Duke to publish public budget
-Impose cost caps
-Require semi-annual reporting
-Take other reasonable steps to protect ratepayers
Walmart (9/x):

"Too many material issues remain undecided for the Commission to do more than approve [Duke's] Carbon Plan solely for modeling purposes."
Walmart (10/x):

-Some of those material unknowns include that the PSCSC "has not yet weighed in on the Carbon Plan"

-"greater clarity is needed with respect to [Duke's] operations in SC in light of the acknowledged impact any decision from PSCSC would have on NC ratepayers"
Walmart (11/x):

-Duke has not explored customer benefits on system-wide basis of RTO membership in context of HB 951 least-cost mandates/CO2 reduction goals

-NCUC "should require [Duke] to evaluate joining an RTO"

-Duke should report its results in 2024 Carbon Plan proceeding
Walmart (12/x):

NCUC "should ensure [Duke places] significant emphasis on the demand-side of the equation. As demand is reduced, the need to build new resources is similarly reduced and/or delayed."

Walmart (13/x):

"Opening access to participation in wholesale DR opportunities, which could occur if [Duke] joined an RTO, would facilitate even greater reductions in energy usage while simultaneously adding additional resources to ensure resiliency of the grid."
Walmart (14/x):

-"The Commission needs to ensure that robust customer programs are developed as part of the Carbon Plan."

-Programs are needed to allow C&I customers to meet their own ESG corporate goals

-Properly incentivized customer programs can improve resiliency
Walmart (15/15):

Summary of Walmart's recommendations snipped here. Image
PAUSE. I need to eat. 😅

After dinner:
-RHC/Robeson Cty. Cooperative for Sustainable Development
-EJ Groups
-Attorney General's Office
-Kingfisher Energy Holdings
-Tech Customers
-App Voices
-NCSEA, SACE, Sierra Club & NRDC
-Avangrid Renewables, LLC
Next up: Carolina Industrial Group for Fair Utility Rates II & III (CIGFUR) (1/x)

Comments linked here:…
CIGFUR (2/x):

Aside from least-cost mandate and requirement to maintain or improve reliability of existing electric grid, NCGA delegated broad and specific discretion to NCUC to develop Carbon Plan by taking all "reasonable steps" toward CO2 emissions reduction goals in HB951
CIGFUR (3/x):

Part of the discretion delegated to the NCUC includes the ability "to determine optimal timing and generation and resource-mix to achieve least cost path to compliance" with CO2 goals.
CIGFUR (4/x):

In order to determine "optimal timing," NCUC may extend time frame for compliance by 2 years for any reason, an can extend indefinitely thereafter if:

(1) Wind or SMRs are authorized; or

(2) necessary to maintain adequacy/reliability of grid.
CIGFUR (5/x):

"CIGFUR has serious concerns about the short- and long-term economic and affordability impacts associated with Carbon Plan implementation."

CIGFUR (6/x):

"[T]he ability (or lack thereof...) of Duke's customers to finance the energy transition by absorbing the kind of rate increases contemplated in the Carbon Plan will be tested & potentially pushed to the absolute limit-or worse, beyond[]-this decade & beyond."
CIGFUR (7/x):

"As the NCUC well knows, the ability of [] Duke's customer classes to absorb rate increases is not infinite; to the contrary, it is quite finite. That is never truer than in times like [now], when inflation is soaring, and all [signs point] toward a...recession."
CIGFUR (8/x):

"With some modifications/recommendations, CIGFUR generally appreciates--at least in the near-term while substantial add'l information is gathered, and some uncertainty is resolved--the flexibility afforded by the multi-portfolio approach proposed by Duke."
CIGFUR (9/x):

-"CIGFUR has serious concerns that power quality was not explicitly or directly addressed in the Carbon Plan"

-Typically power quality evaluated together with, or underneath umbrella of, reliability concerns
CIGFUR (10/x):

In order to ensure "maintaining or improving reliability" as req'd by H951, need to have metrics (incl. power quality metrics beyond just SAIDI/SAIFI) and a tracking/accounting system analogous to what will be used to measure compliance with HB951 CO2 goals
CIGFUR (11/x):

Bill impact estimates "are concerning enough as is, but unfortunately they are, if anything, severely understated." CIGFUR recommends Duke make a supplemental filing providing updated estimates containing cost-adders not included, like:
CIGFUR (12/x):

-Tx cost adders related to proposed network upgrades
-Costs associated with subsequent license renewals (SLRs) for Duke's existing nuclear fleet.
CIGFUR (13/x):

-Dominion recently applied for SLRs for 4 existing nukes at 2 stations totaling 3,348 MW of gen; relicensing/upgrade costs expected to cost $3.9B

-Duke, by comparison, plans to seek SLRs for 11 existing nukes at 6 stations, totaling 10,773 MW of gen; cost TBD
CIGFUR (14/x):

-Duke did not consider how total PVRR cost/bill impact analyses would be affected if South Carolina rejects Carbon Plan

-Duke did not analyze how a possible future merger of DEP and DEC could impact model inputs/outputs
CIGFUR (15/x):

-Duke did not model CO2 offsets as authorized pursuant to HB 951, as a way to potentially reduce compliance costs

-Duke did not analyze how implementation of new non-residential DSM/demand response programs might be leveraged to provide system/ratepayer benefits
CIGFUR (16/x):

-Duke did not evaluate whether retiring other electric gen facilities, aside from its coal fleet, could potentially result in least-cost path

-Duke did not analyze/model potential cost effects re: NEM reform
CIGFUR (17/x):

-Rate impacts attributable to costs recovered thru fuel rider are not factored into Carbon Plan projected rate increases

-Duke should be req'd to update its cost/bill impact analyses to include ALL projected cost adders, both related and unrelated to Carbon Plan
CIGFUR (18/x):

"W/o having thorough, complete information about anticipated rate impacts...resulting from costs both related & unrelated to the Carbon Plan, how can NCUC be in a position to evaluate whether [Duke's Plan constitutes steps that] are reasonable, as req'd by HB951?"
CIGFUR (19/x):

-Carbon Plan proceeding does not serve as substitute for CPCN (new gen certification), CECPCN (tx cert.), or rate case proceedings.

-Pursuant to HB 951, Duke should be req'd to securitize remaining NBV of subcritical coal fleet
CIGFUR (20/x):

-Some concerns about the reliability impacts in event Duke unable to secure an adequate add'l supply of NG

-Questions whether NG is economical resource choice in the short-term, given domestic/foreign supply chain problems and other geopolitical market pressures
CIGFUR (21/x):

-Several potentially more cost-effective alternatives compared to buildout/rate-basing of all new gen not adequately considered

-CPCN statute requires imports/purchases be considered as alternative

-SEEM not being leveraged to provide cost savings to customers
CIGFUR (22/x):

CIGFUR has concerns re: approval of a Carbon Plan "that is so dependent and reliant upon generating technologies that are either unproven in the context of large-scale adoption or facing extreme market pressures, or both."
CIGFUR (23/x):

Given speculative/uncertain nature of whether development activities will ever result in used & useful generating assets, a pre-determination of reasonableness/prudence "would be premature, inappropriate, & inconsistent with applicable statutes & NCUC precedent."
CIGFUR (24/x):

If CIGFUR approves Duke's request to undertake pre-development activities of OSW, SMRs, and new pumped storage hydro, NCUC should impose limits including cost caps and other parameters to "ensure both that (1) Duke is sufficiently incentivized to manage its...
CIGFUR (25/x):

project development activities in a cost-efficient, reasonable, and prudent manner; and (2) ratepayers are protected from cost overruns and unconstrained spending[.]"
CIGFUR (26/x):

-Duke's Plan much more focused on supply-side solutions rather than less costly demand-side ones

-Duke should be req'd to adopt new, innovative DSM solutions for C&I customers and expand its existing suite of DSM/DR programs
CIGFUR (27/x):
Need more customer renewable programs, which is both consistent w/ spirit of HB 951 policy goals and "necessary as a cost mitigation measure to encourage private sector investment as a means of defraying...costs...which will otherwise have to be rate-based."
CIGFUR (28/x):

Duke's NC ratepayers "should be held harmless from the South Carolina jurisdictional allocable portion of related costs incurred between" initial Carbon Plan approval and 2024 biennial Carbon Plan proceeding.
CIGFUR (29/29):

See pp. 36-42 for more details on CIGFUR's specific requests/recommendations.
Next up, TotalEnergies Renewables, LLC (TotalEnergies) (1/x):

Comments linked here:…
TotalEnergies (2/x):

-TE holds lease OCS-A 0545 issued by BOEM, which grants TE exclusive right to propose an OSW farm in lease area located in federal waters off coast of NC

-TE intends to develop the lease for contribution to HB 951 CO2 emissions reductions goals
TotalEnergies (3/x):

"The approaches presented in [Duke's Plan] make it unlikely that HB 951's 2030 mandate will be fulfilled. It combines a reliance on unproven solutions with a lack of 2023-2024 actions to ensure several paths to fulfill the mandates of HB 951."
TotalEnergies (4/x):

The proposed "approach to OSW would lead to excessive costs for the ratepayer as it fails to leverage a sufficient scale of development to lower costs, doesn't activate the committed investments in local jobs and supply chains by developers, and...
TotalEnergies (5/x):

doesn't take advantage of the years-long work that resulted in 3 offshore lease areas available off the coast of NC."
TotalEnergies (6/6):

"Including OSW resources in the [initial Carbon Plan] will drive development of power grid tx upgrades associated w/ the execution of HB 951 and the payment for those upgrades, and encourage non-utility capital investments in generation and transmission."
Next up: Redtailed Hawk Collective and Robeson County Cooperative for Sustainable Development (RHC/RCCSD) (1/x)

Comments linked here:…
RHC/RCCSD (2/x):

-Carbon Plan "will have significant implications for impacted communities in Robeson County and throughout Eastern NC"

-Carbon Plan outcomes "will have a substantial impact on the quality of life of disproportionately impacted communities, especially in ENC"
RHC/RCCSD (3/x):

-Robeson Cty./ENC has experienced "impacts of climate change" particularly hard

-In 2016 and 2018, Hurricanes Matthew (Cat 5) and Florence (Cat 4) "devastated Robeson County and rural and coastal communities across our Eastern region"
RHC/RCCSD (4/x):

-Many cost/risk factors here, incl. cost overruns, pipeline construction/transportation infrastructure, construction delays, legal fees, new tech, and stranded assets

-SCC, carbon pricing, nonmarket damages, and unmet timeline goals are all factors to consider
RHC/RCCSD (5/x):

-Too many contingencies/risk factors involved in buildout of new NG

-NCUC should "incorporate the social cost of GHG emissions (SC-GHG)"
RHC/RCCSD (6/x):

Though "sometimes difficult to quantify," nonmarket damages such as "moral damages," "health impacts, ecological damages, & community impacts" should be weighed
RHC/RCCSD (7/x):

Carbon tax, cap & trade mechanisms, and carbon offsetting "do not and cannot guarantee that a utility will significantly reduce carbon emissions at their source."
RHC/RCCSD (8/x):

"When applying least cost considerations to the 2050 goal, flexibility itself must also be valued in order for NC to be able to capture the maximum amount of economic benefit, and mitigate as much wasted spending" as it implements HB 951
RHC/RCCSD (9/x):

-"Greater outreach & consultation are needed for certain communities of interest"

-Duke holding stakeholder mtgs "over the course of entire business days made the substantive participation of low-income, Indigenous & working-class parties all but impossible"
RHC/RCCSD (10/x):

-"North Carolina communities should have more access to DSM programs and opportunities for community-ownership of generating assets"

-Duke's "Grid Edge programs do not go far enough to improve access to clean energy" for LMI customers
RHC/RCCSD (11/11):

-"Biofuels are not clean energy"

-While HB 951 authorizes extension of timeframes for compliance in certain scenarios, "such a finding would be improper at this time" because this is the initial Carbon Plan.
Next up: Environmental Justice Community Action Network and Down East Coal Ash Environmental and Social Justice Coalition (EJ Groups) (1/x):

Comments linked here:…
EJ Groups (2/x):

-"Climate change has a major impact on quality of life in Sampson and Wayne Counties."

-Those living in close proximity to flood plains "most likely to suffer extreme damage-from loss of electrical power to flooded roadways-...caused by extreme weather[.]"
EJ Groups (3/x):

Repeats these points raised by RHC/RCCSD
EJ Groups (4/x):

Repeats these points raised by RHC/RCCSD
EJ Groups (5/x):

Repeats these points raised by RHC/RCCSD

EJ Groups (6/x):

Repeats these points raised by RHC/RCCSD

EJ Groups (7/7):

Repeats these points raised by RHC/RCCSD

Next up: The North Carolina Pork Council (Pork Council) (1/x):

Comments linked here:…
Pork Council (2/x):

The Pork Council "is encouraged by the inclusion of low carbon fuels in the Carbon Plan, particularly the use of renewable NG (RNG) as a replacement for conventional NG at CC and CT generation units."
Pork Council (3/x):

"It is well known that the use of RNG derived from animal waste to produce electric power is an overall win on many levels -- at the farm fostering new management practices w/ significant benefits dealing with odor, vectors and fugitive emissions;
Pork Council (4/x):

for the environment by eliminating or reducing the potential for overflows or releases; and overall by reducing GHG emissions that otherwise would be released to the atmosphere."
Pork Council (5/5):
NC "blessed w/swine manure material. Accord'g to recent data, it ranks 3rd nationally in availability. There is (sic) absolutely no reason not to optimize on this[]. It will be here in any event & using manure in a very productive way makes absolute sense."
Ok I have to call it a night. Will pick this back up some time tomorrow, unless for some reason I can't sleep. 🤪

Summaries remaining:
-Attorney General's Office
-Kingfisher Energy
-Tech Customers
-Avangrid Renewables
-Clean Power Suppliers Ass'n
and App Voices, between Tech Customers and NCSEA et al. My apologies!
Alright, y'all ready for more?

As a reminder, please read caveats/disclaimers and acronym/jargon dictionary at beginning of thread.
Next up: NC Attorney General's Office (AGO) (1/x):

Comments linked here:…
AGO (2/x):

Expert analysis by @StrategenNews linked here:…
AGO (3/x):

The portfolios proposed in Duke's Plan "share many commonalities, including the addition of SMRs by 2035, the same levels of EE/DSM savings, the same levels of NEM penetration, and the same amounts of OSW. However, there are some key differences" per this chart: Image
AGO (4/x):

-"[T]he AGO recommends that the Commission decline to adopt Duke's proposed Carbon Plan without first reviewing the impact of problems in Duke's modeling and post-modeling changes."

-NCUC should conduct evidentiary hearing for that purpose
AGO (5/x):

As part of evidentiary hearing, "Duke should be directed to develop add'l scenarios based on EnCompass model runs that reflect revised modeling inputs and that eliminate or significantly reduce the number of 'out of model adjustments'[.]"
AGO (6/x):

-P2, P3, and P4 do not satisfy requirements of HB 951 because they do not have Duke meeting CO2 reduction target by 2030

-Of portfolios currently available, only P1 "is within NCUC's discretion to include because that portfolio achieves 70% CO2 reductions by 2030"
AGO (7/x):

-P1 "provides the most annual CO2 reductions in nearly all years prior to 2050 and the most cumulative [CO2 reductions] by 2050"

-P3 & P4 do not comply with NCUC's "limited discretion [set forth in HB 951] to exceed the compliance deadlines by more than 2 years"
AGO (8/x):

NCUC will not authorize the construction of a new OSW or nuclear facility until 2024 at earliest, so AGO "does not believe this is discretion that the Commission can exercise at this time, but may exercise later"
AGO (9/x):

-Duke "has not shown the delay of any wind or nuclear facility is due to a factor beyond its control" which AGO contends is inconsistent with requirements of HB 951

-2030 interim compliance deadline can be achieved while maintaining adequacy & reliability of grid
AGO (10/x):

-Compliance deadline can only be extended by >2 years if "necessary to maintain the adequacy & reliability of the existing grid"

-P1 & P2 "satisfied Duke's tests for adequacy and reliability," so a delay >2 years shouldn't be acceptable in initial Carbon Plan
AGO (11/x):
"In passing H951, the NCGA-rep'ing the will of the people of NC-recognized that the cost of failing to address climate change was far higher than taking action. It is not the role of NCUC to 2nd guess that decision, but to faithfully implement ... statutory mandates"
AGO (12/x):

"For these reasons, the Commission should not include Portfolios 2, 3, and 4" in the initial Carbon Plan

-NCUC should direct Duke to conduct add'l modeling & allow other parties to do same in order to evaluate "problematic modeling inputs and post-modeling changes" Image
AGO (13/x):

"Equally worrying, Duke inserted add'l 'out of model' changes to its modeling results to develop its proposed Carbon Plan & did not rely on modeling for some items. Strategen identified a number of these out-of-model items that are discussed in more detail in report" Image
AGO (14/x):

-'Out of model' changes "are both subjective and difficult to analyze

-Altogether, the "concerns about Duke's modeling process call into question the resource mix selected for use in the portfolios" in Duke's Plan
AGO (15/x):

Themes of modeling problems identified by Strategen:

-Duke's modeling "relies on overly optimistic assumptions related to NG generation"

-"Because green hydrogen is still a nascent technology, Duke's cost assumptions [re: green hydrogen] are also speculative"
AGO (16/x):

"Duke's fuel expenditures are passed directly to customers through annual fuel rider proceeding. Therefore, customers-not Duke-bear risk of inaccurate NG price forecasts." NCUC "should minimize" new NG, especially new CCs, due to high capacity factors
AGO (17/x):

"While the cost concerns [of NG] are troubling, perhaps equally troubling is the fact that all four portfolios fail to meet the 70% CO2 reduction goal by 2030 when evaluated under the 'High Gas Price' scenario ...
AGO (18/x):

...The reason for this is, as NG prices increase, the model dispatches add'l coal units in place of uneconomic NG units. Under the 'High Gas Price' scenario, emissions increase such that CO2 reductions are forecasted to decrease b/w 6.2-8.4% in interim target years"
AGO (19/x):

"The reliance [in Duke's Plan] on Appalachian NG introduces significant reliability risk in the event of severe cold weather events if Duke is unable to secure new firm gas transportation service, which has been difficult to achieve in the Carolinas in recent years"
AGO (20/x):

"Green hydrogen has not been produced, transported, or used for electric generation at a utility-scale. There is a real possibility that if any of these steps fail to materialize, many of Duke's NG generating units would need to retire early."
AGO (21/x):

"Because green hydrogen is a linchpin in Duke's plan to use its NG units beyond the 2050 net zero date (and thus its entire Carbon Plan), there is a significant risk that these gas units will become stranded assets and that Duke will not be able to meet" 2050 d/l
AGO (22/x):

-"Duke's modeling placed arbitrary limits on solar+storage configurations"

-For ex, "Duke modeled solar+storage resources w/ fixed storage output profile instead of letting the model flexibly dispatch the storage component"
AGO (23/x):

Also, "Duke's modeling only included two possible configurations for solar+storage additions: (1) 75 MWs of solar paired w/ 20 MWs of 4-hr batteries (a 50% battery ratio); and (2) 75 MWs of solar paired with 40 MWs of 2-hr storage (a 25% battery ratio)"
AGO (24/x):

"These limited options do not represent full ranges of solar+storage configurations available to Duke, nor do they represent the configurations that are likely to maximize value into the future. This is especially true considering [Duke's] interconnection limits"
AGO (25/x):

-Duke's modeling "applied cumulative limits for 50% battery ratio solar+storage configuration" even tho "model reached this limit for DEP by approximately 2030"

-Duke "claims limit is necessary to address reliability concerns," but model can resolve w/o constraints
AGO (26/x):

-Duke "placed arbitrary limits on onshore wind"

-Duke "placed arbitrary limits on EE/DSM resources"

-Duke "placed arbitrary limits on residential rooftop solar"
AGO (27/x):

-Duke "failed to appropriately recognize the risk that SMRs may fail to materialize within the expected timeframe or budget"

-Duke "made 'out of model' changes to the modeling results that are difficult to evaluate and were not appropriately explained"
AGO (28/x):

For ex., "Duke adjusted the retirement dates of coal generating facilities to be later than what the model selected"

Also, Duke "replaced standalone batteries with additional [NG] CT units"
AGO (29/x):

A few of Duke's proposed near-term actions can "safely be pursued," including 3,100 MW of USS w/ targeted in-service dates of 2026-28; 1,000 MWs of standalone storage and 600 MW of solar+storage; and at least 600 MW of new onshore wind w/ targeted in-service 2026-27
AGO (30/x):

Duke's "requests for NCUC approval of plans to pursue initial development activities and to assure cost recovery for...possibly OSW, SMRs, and pumped hydro storage should not be addressed in this proceeding."
AGO's (31/31):

AGO's recommendations: ImageImage
Next up: Kingfisher Energy Holdings, LLC (Kingfisher) (1/x):

Comments linked here:…
Kingfisher (2/x):

-"Significantly, [HB 951] does not specify supply/procurement methods for resources not selected by the Commission" (emphasis omitted)

-Least-cost mandate "requires use of lower cost procurement method for resources not selected by NCUC if one is available"
Kingfisher (3/x):

-"[C]ompetitive bidding reps most efficient method for determining least-cost options for resources not selected by the Commission"

-"[W]hen competitive bidding results in PPAs w/ IPPs, there are unique & substantial benefits & significant mitigation of risks"
Kingfisher (4/x):

"Procurement of generation resources under the Carbon Plan through competitive bidding will produce the least cost path to CO2 reduction while maintaining or improving on the adequacy and reliability of the existing grid."
Kingfisher (5/x):

Gov. Cooper's EO 80 NC Energy Regulatory Process (NERP) detailed 2 case studies on gen procurement and based on those studies, identified "general principles" that "support the use of all-source procurement.
Kingfisher (6/x):

"While the NCGA did not enact legislation specifically requiring use of competitive procurement, it did not prohibit use of RFPs as a part of HB 951. Indeed...a number of [HB951] use of comp procurement and RFPs to achieve" CO2 reductions
Kingfisher (7/x):

"The experience of Xcel Energy's Colorado RFP provides real-world evidence that RFPs actually produce lower costs. Xcel's 2016-2017 competitive solicitation returned a $0.0107/kWh bid for wind, $0.023/kWh bid for solar, and $0.03/kWh bid for solar-plus storage"
Kingfisher (8/x):

...contrasted against CO's avg. January 2021 residential electricity price of $0.126/kWh

-NCUC/Duke both have experience with competitive procurement via CPRE Program; can leverage lessons learned to make ASP beneficial in Carbon Plan implementation
Kingfisher (9/x):

When Duke executes PPAs with IPPs, IPP "takes on the responsibility to deliver the project on time with significant penalties for default...
Kingfisher (10/x):

...This mitigates various forms of risk to Duke and its customers re: execution cost/schedule, such as site acquisition and control, environmental permitting, infrastructure expansion, construction delays, and construction cost-overages."
Kingfisher (11/x):

"In addition, the contractual obligations of an IPP to a utility include performance & availability requirements. The consequences to an IPP for failing to meet these contractual obligations include severe financial penalties & harm to the IPP's...reputation"
Kingfisher (12/x):

"In the later years of a [generating] facility's life cycle, the IPP and PPA procurement model mitigates stranded costs risk to the utility and its customers."
Kingfisher (13/13):

NCUC "should require Duke Energy to adjust its execution plan to rely more on competitive procurement for generation needed to comply with HB 951"
Next up: Apple Inc., Google LLC, and Meta Platforms, Inc. (Tech Customers) (1/x):

Comments linked here:…
Tech Customers (2/x):

Tech Customers also submitted an expert analysis of Carbon Plan prepared by Gabel Associates, Inc.

That report is linked here:…
Tech Customers (3/x):

"NC's CO2 reduction goals are clear, and laudable, but the least-cost pathway is far from certain. Duke's proposed Carbon Plan is a constructive start of the conversation, but the portfolios [in Duke's Plan] are unlikely to result in compliance [w/ HB951]..
Tech Customers (4/x):

...given that each of proposed portfolios is ultimately reliant on technological improvements that may or may not occur."

-Tech Customers support NC's "ambitious carbon goals," and each company within Tech Customers "has set its own ambitious carbon goals"
Tech Customers (5/x):

Main themes
-NCUC "should avoid selecting unproven/aging technologies."

-Carbon Plan "can be significantly improved in a manner that will result in "reduced cost to ratepayers, more rapid decarb of the energy grid, and greater benefits to...customers"
Tech Customers (6/x):

Main themes
This is not correct proceeding for consideration of Duke's requests for reg. commitments re cost recovery. NCUC "should decline Duke's invitation for pre-approval of costs associated w/ [initial dev activities] for OSW, SMRs, & pumped storage"
Tech Customers (7/x):
Tech Custs. "support NC's commitment to reducing & eliminating CO2 emissions & applaud NC in its clean-energy leadership role. Comments submitted for NCUC's consideration as it fulfills NCGA's mandate of charting NC's least-cost pathway to CO2-neutral[ity]"
Tech Customers (8/x):

Duke's Plan "is four modest variations on a single pathway forward, each reliant on new and unproven technologies. Rather than explore alternative solutions for achieving CO2 neutrality," all 4 portfolios "converge on essentially the same gen stack by 2050" Image
Tech Customers (9/x):

"Duke characterizes the uniformity in its Portfolios as an 'all-of-the-above' approach to the energy transition... However, this label masks the plan's failure to analyze divergent CO2-reduction pathways."
Tech Customers (10/x):

"And while the Tech Customers agree that it would be premature to commit to one technology at this time, it would be prudent to analyze the different pathways offered by the various technologies" (emphasis omitted)
Tech Customers (11/x):

"Duke's proposed Carbon Plan focuses on maximum utility ownership and control of generation assets, and omits important least-cost alternatives" like the following: Image
Tech Customers (12/x):

"Power purchased from 3rd-party owned resources can advance least-cost planning by sourcing less costly energy & capacity & helping defray need to make investments that entail unacceptable risk."
Tech Customers (13/x):

"Here, such [third-party purchases] may help delay the need for immediate investments in uncertain resources like NG, SMRs, and OSW."
Tech Customers (14/x):

"Duke's proposed Carbon Plan employs the questionable assumption that a portion of any costs associated with new generation will be assigned to South Carolina ratepayers."
Tech Customers (15/x):

"Given the magnitude of costs in issue, considerations of cost recovery [incl. risks associated w/ uncertainties re: cost-sharing w/ SC] may dictate whether a particular resource is least cost and should be evaluated in the context of the Carbon Plan."
Tech Customers (16/x):

"Duke requests Commission approval of reimbursement for a new OSW project, but fails to demonstrate that such generation would be a least-cost resource."
Tech Customers (17/x):

"The Tech Customers support OSW. But it is far from clear that utility ownership of OSW represents a least-cost alternative for NC ratepayers in near term. Indeed, the modeling included in the Gabel Report did not select OSW as a least-cost gen resource"
Tech Customers (18/x):

Ex: Dominion's OSW facility projected to cost nearly $9.8B in capital costs. "VA SCC staff has expressed concerns that total customer benefits from the project could result in a $1.6B loss, and [some] suggests expansion of solar would be cheaper than OSW."
Tech Customers (19/x):

"The cost assumptions and manual constraints chosen by Duke limit the utility of its cost modeling." Image
Tech Customers (20/x):

"The Gabel Report discusses how the correction of some of Duke's modeling assumptions results in a reliable portfolio that addresses some of the execution challenges and mitigates risks associated with investment in new FF generation."
Tech Customers (21/x):

"In doing so, the modeling as detailed in the Gabel Report, also resulted in a cost savings of approximately $3B compared to Duke's Portfolio 1."
Tech Customers (22/x):

-Select only near-term resources that are "not dependent on technological developments to achieve" CO2-neutrality
-Selection of a resource in Carbon Plan proceeding does not constitute pre-determination of CPCN burden of proof
Tech Customers (23/x):

Recs, con't.:

The Gabel Report "solves for these shortcomings by offering meaningful and achievable improvements to [Duke's Plan], including as follows: Image
Tech Customers (24/x):

Recs, con't.:

-"Duke's request for approval of project development costs and deferral accounting is inappropriate for this proceeding"

-"Duke's exclusion of market and 3rd-party solutions is inconsistent with least-cost planning"
Tech Customers (25/x):

-"Current law and practice of least-cost planning requires consideration of purchased power"

-"current practice of least-cost planning includes an assessment of whether purchased power is an alternative to building new generation"
Tech Customers (26/26):

Tech Customers' requests to NCUC: Image
Next up: Appalachian Voices (App Voices) (1/x):

Comments linked here:…
App Voices (2/x):

Affordability Analysis report linked here:…
App Voices (3/x):

[Duke's Plan] "in its current form must be rejected because Duke Energy has failed to fully address bill impacts and affordability for customers, including its nearly one million residential customers who qualify as low-income."
App Voices (4/x):

"At least 1/4 of these LMI customers already struggle to meet monthly payments and any increase in energy bills would exacerbate existing affordability challenges. By failing to appropriate consider the potential that EE and DERs offer for...
App Voices (5/x):

lowering CO2 emissions, energy demand, and bills for LMI customers, while at the same time advocating for rapid large-scale expansion of near-term NG gen resources, [Duke] has failed to present a least cost and affordable plan to meet [HB951 CO2 goals]."
App Voices (6/x):

"Least cost planning requires use of the entire spectrum of demand-side options, including conservation, load management, DERs, and EE programs."
App Voices (7/x):

"Prioritizing energy affordability by focusing onload management and EE resources fulfills least cost path requirements and executive directives to incorporate environmental justice and equity considerations and benefits."
App Voices (8/x):
"Prioritizing investments in low-income & high energy-burdened households helps meet CO2 reduction goals while achieving significant cost & energy savings...result[ing] from expansion of EE, electrification, community solar & DR programs for LMI households"
App Voices (9/x):

"While Duke Energy asserts that 'affordability' is one of four 'core Carbon Plan objectives' & often uses the term 'affordability'..., Duke provides no definition of what constitutes affordability & includes no investment in EE, DERs or DSM for LMI households"
App Voices (10/x):

Carbon Plan must "directly address existing and future affordability challenges and impacts, through short-term bill assistance and long-term investments in EE, DERs, and DSM. Unfortunately, [Duke's Plan] is largely devoid of investment in these resources."
App Voices (11/x):

"[W]hen asked what modeling was done to determine how the estimated cost of each portfolio would impact arrearages and disconnections for residential customers, particularly low-income customers, ...
App Voices (12/x):

...Duke Energy responded that the information was outside the scope of the Carbon Plan proceeding, and again reverted to conflating 'least cost' with 'affordability.'"
App Voices (13/x):

"[R]esource allocation that prioritizes addressing affordability challenges can, at the same time, address DS/EE priorities, working together to create a least cost allocation of resources"

-Some affordability & energy burden data presented graphically ImageImageImage
App Voices (14/x):

"Duke Energy's failure to adequately incorporate EE and DER investment forfeits available co-benefits of addressing energy affordability challenges while reducing energy demand"
App Voices (15/x):

"PSE's analysis demonstrates how investment in EE, community solar, and DR can significantly reduce energy bills of LMI households and achieve significant savings."
App Voices (16/x):

In [PSE's] model, "the total energy affordability gap (the amount of money needed to bring energy bills below the 6% threshold) reduced from $630M to $237M after investments in EE, then to $70M after community solar is introduced, and down to $30M after DR" Image
App Voices (17/x):

"Each of these investments also provides co-benefits in terms of CO2 reduction and demand reduction. As modeled by PSE, the efficiency investments in LMI households alone could reduce annual energy demand by roughly 2,800 GWh"
App Voices (18/x):

-"Carbon Plan must incorporate affordability programs and investments to avoid energy insecurity"

-Carbon Plan can provide numerous alternatives to new NG, including DSM/EE, USS, DERs, add'l wind gen, participation in an RTO
App Voices (19/x):

"Duke's Plan fails to account for risks associated with new NG plants," like "increased GHGs and air pollutants, significant financial risk, and unreasonable reliance on the uncertain MVP"
App Voices (20/20):

App Voices' recommendations to Commission: Image
I need a quick stretch break before I begin NCSEA, SACE, Sierra Club, and NRDC (cc: @pledf, @D_Davidovich)
Ok, next up: NC Sustainable Energy Association (NCSEA), the Southern Alliance for Clean Energy (SACE), the Sierra Club, and the Natural Resources Defense Council (NRDC) (together, the "Coalition of Low-Cost Energy and Net-Zero Intervenors" or "CLEAN Intervenors") (1/x)
Clean Intervenors (2/x):

Comments linked here:…
Clean Intervenors (3/x):

"Duke has asked NCUC to endorse a range of possible Carbon Plan portfolios, all but one of which fail to meet the law's 2030 intermediate CO2 reduction requirements...
Clean Intervenors (4/x):

...All of Duke's portfolios rely heavily on new gas plants in the short term, even as customers are being saddled with extraordinarily high fuel prices. ...
Clean Intervenors (5/x):

...All of Duke's portfolios depend on unproven SMR technology and a zero-carbon hydrogen infrastructure that is not priced into its model in order to meet the law's 2050 mandates. It would be a mistake for the NCUC to adopt [Duke's Plan] as its own."
Clean Intervenors (6/x):

"It would be difficult to hold [Duke] accountable for abiding by HB 951's CO2 reduction requirements under Duke's multiple-choice proposal. NCUC should decline Duke's request to be both the author and reader of a Choose-Your-Own Adventure Carbon Plan[.]"
Clean Intervenors (7/x):

-"[Duke's Plan] would not comply w/ the law"

-3/4 portfolios "fall short of the 2030 interim CO2 reduction requirement, and the one potentially compliant portfolio, P1, would itself fall short...when modeled without new Appalachian gas availability."
Clean Intervenors (8/x):

"And it would be irresponsible to rely on speculative, unproven technologies, such as SMRs, when it is not yet known whether that technology will be safe, cost-effective, or reliable."
Clean Intervenors (9/x):

-"Clean Intervenors fully support deploying wind as rapidly as possible, including beginning the planning process to acquire that zero-carbon resource."

-"Clean Intervenors recommend... a no-regrets energy pathway...particularly [in near-term]"
Clean Intervenors (10/x):

"Building more clean energy resources and relying more heavily on EE in the near term helps to achieve both the 2030 requirements and better positions Duke to achieve the 2050 net zero requirement in a least cost manner."
Clean Intervenors (11/x):

Quick procedural note -- due to extenuating circumstances I will not delve into here, the NCUC issued an Order granting [Clean Intervenors] a 3-business day extension to file the expert analysis report of Synapse. So, that will be filed on 7/20.
Clean Intervenors (12/x):

@pledf and/or @D_Davidovich, pls remind me to update this thread with a link to that report once filed and I will be happy to.
Clean Intervenors (13/x):

But if you're wondering, here's a link to Clean Intervenors' motion:…

And NCUC's Order ruling on said motion:…
Clean Intervenors (14/x):

Separate from Synapse Report, Clean Intervenors "retained RMI to provide a more detailed analysis of the potential ratepayer impacts of the Duke Resources scenario." That analysis is linked here:…
Clean Intervenors (15/x):

"Optimus allows RMI to conduct a forward-looking estimate of rates and bills differentiated by customer class for the various portfolios generated by EnCompass, taking into account Duke's cost of service methodologies."
Clean Intervenors (16/x):
-Duke's Plan "would likely cause disproportionately large rate increases for residential customers in DEC's territory as new gen added b/w 2027-32"
-Contra Duke's Plan "would cause steeper rate increases for industrial customers in DEP from 2024 onwards"
Clean Intervenors (17/x):

-"RMI's analysis suggests [Duke's Plan] would not provide a useful hedge against fuel price shocks"

-"RMI's analysis indicates that an accelerated build of solar will likely help to mitigate those potential price spikes from increased gas/coal prices"
Clean Intervenors (18/x):
"RMI's analysis suggests 'deployment of add'l solar, storage & wind to avoid fuel utilization is likely a no-regrets solution' [to hedge against] fuel price volatility, uncertain future costs re: conversion to hydrogen, & [risk of stranded NG assets]"
Clean Intervenors (19/x):

"The ratemaking tools and securitization of retiring coal plants established in H951 provide additional levers for mitigating costs to ratepayers, ... which, if leveraged sooner, would realize significant savings for ratepayers[.]"
Clean Intervenors (20/x):

"RMI modeled the consequences of supportive federal carbon regulations, which have the potential to reduce the rate impacts of Carbon Plan scenarios that rely more heavily on clean energy resources [vs. Duke's Plan which relies] heavily on new gas."
Clean Intervenors (21/x):

Clean Intervenors also retained Grid Strategies, LLC "to review the transmission-related aspects of Duke's proposed Carbon Plan and to offer any recommendations for improvement."

That report linked here:…
Clean Intervenors (22/x):

Specific tx recs:
1. Carbon Plan "should rely on proactive, scenario-based, multi-value portfolios of tx expansion projects to identify bulk tx upgrades"

2. Carbon Plan "should incorporate results of" SERTP, NCTPC, and Atlantic OSW Tx Study
Clean Intervenors (23/x):

Specific tx recs:

3. Tx upgrades should "leverage existing transmission corridors for future tx needs"

4. Rely on "rigorous analysis of potential regional projects that would support future resource needs, [esp] imports of Midwest wind & [new] OSW"
Clean Intervenors (24/x):
"Although Duke correctly states that actual procurement would remain subject to [CPCN requirement], its request for approval of certain near-term activities [for new NG] is akin to requesting NCUC grease the skids for this massive expansion of [new NG]."
Clean Intervenors (25/x):

"A near-term action plan designed to make the best use of cheap zero-carbon resources and start the least-cost path to H951's CO2 reduction requirements would rely more heavily on solar, storage, wind, and if possible, regional integration."
Clean Intervenors (26/x):

NCUC "must ensure that the final target procurement volume for 2022 solar procurement is sufficiently high to put Duke on-track to [hit least-cost] 2030 carbon limit."
Clean Intervenors (27/x):

[T]o avoid serious risk of interconnection logjams in later years, NCUC should...front-load solar procurement in earlier years to greatest extent possible. This is all the more true [given Duke's Plan] appears to under-deploy solar b/w now and 2030"
Clean Intervenors (28/x):

-"Storage deployment has suffered in Duke's proposed near-term mini-portfolio as a result of deliberate replacement with CTs"

-"OSW and pumped storage hydro technologies are proven to be commercially operable in U.S. Conversely, SMRs [are unproven]."
Clean Intervenors (29/x):

-Duke's requests for pre-determination of reasonableness/prudence/deferral accounting treatment of certain dev. activity costs are premature

-NCUC should require evaluation of costs/benefits of a DEP/DEC merger
Clean Intervenors (30/x):

-Duke "can do more than it proposed" on Grid Edge/Customer programs

-Duke's "projects for future NEM adoption are too conservative"

-NCUC has "an important role to play in providing a supportive framework for customer adoption of rooftop solar"
Clean Intervenors (31/31):

Clean Intervenors' recommendations and requests for relief to NCUC: ImageImageImage
I've got to call it a night. Sorry, y'all -- had really hoped to finish these tonight.

Summaries on deck (circling back to add some parties who were just granted intervention today or whose comments were just posted to docket today):
-Avangrid Renewables, LLC
-Clean Power Suppliers Ass'n
-Sean Lewis
-Mid-Atlantic Renewable Energy Coalition
-350 Triangle/NC Alliance to Protect Our People and the Places We Live
-Environmental Working Group

Will do everything I can to wrap these remaining summaries up tomorrow
Alright, y'all ready to rumble? Picking this thread back up. As a reminder, please read the caveats/disclaimers at the beginning of this thread. Also pls see the acronym/jargon dictionary at beginning of thread as well. Image
Next up: Avangrid Renewables, LLC (Avangrid) (1/x):

Comments linked here:…
Avangrid (2/x):

"Reasonable steps to achieve the emissions reductions required by HB951 must give proper consideration to the abundant potential for OSW gen off the NC coast and a pathway to utilizing these OSW resources as economically, efficiently, & expeditiously as possible"
Avangrid (3/x):

Duke's Plan "artificially constrains the development of OSW resources for NC by proposing inefficient project design capacities, assumes timelines that cannot meet HB951's deadlines, & fails to articulate a low-cost tx strategy for the near-term buildout of OSW"
Avangrid (4/x):

Avangrid is an onshore and OSW developer and owner of the Kitty Hawk Wind lease area (OCS-A-0508) off the coast of NC, "with the potential to deliver abundant and cost-effective OSW gen within timeline required by HB951"
Avangrid (5/x):

"Kitty Hawk is the largest offshore lease capable of delivering to NC, and the only lease area within the Carolinas region to have already submitted applications for federal permits...Kitty Hawk provides the highest value and cost and schedule certainty"
Avangrid (6/x):

Requests that NCUC:
-Require an "independent, objective 3rd party study to evaluate and prioritize each [OSW lease off the Carolinas] and determine the best pathway to incorporate OSW resources into [Duke's Plan]"

Avangrid (7/x):

Requests that NCUC:
-"require that such study consider LCOE, viability, schedule, size and overall plan, along with any other NCUC-determined metrics, in making [study] recommendations"

Avangrid (8/x):

Requests NCUC:
-"provide for stakeholder input and regular reports to the NCUC about the status of the study, for filing of the final study (incl. transparent data and modeling inputs), and an opportunity for intervenors to file comments re: the study"

Avangrid (9/x):

Requests cont:
"following comment period & any further actions that NCUC deems fit, require that Duke select OSW resource additions in a prioritized order, beginning w/ projects that provide NC ratepayers with best overall combo of reliability, schedule, & cost"
Avangrid (10/x):

"Alternatively, should the Commission decline to take the foregoing steps, [Avangrid] requests that, at a minimum, the Carbon Plan be modified to address the shortcomings identified in these limited comments."
Avangrid (11/x):

-"Efficient, cost-effective OSW resources are critical to NC achieving the emissions reductions mandated by HB951"

-"OSW can support system capacity needs during times when other gen sources are less able to do so, including winter peak" Image
Avangrid (12/x):

"OSW wind offers an opportunity to expand renewable energy gen even after the more favorable locations for onshore gen diminish"
Avangrid (13/x):

"As the penetration of onshore gen increases, whether [renewable or fossil], it gradually becomes harder to find gen sites with low levels of conflict among competing landowner, abutter, enviro and other stakeholder interests."
Avangrid (14/x):

"OSW sites, by contrast, have the unique advantage of having already been through a multi-year de-conflicting process by the federal government and are sited far from where most people live, work, and play."
Avangrid (15/x):

"Since 2015, maturing tech, rapidly evolving supply chains, increased competition & experience from utility-scale installations have driven costs down & broadened deployment of OSW energy infrastructure across globe...OSW's LCOE declined by 28-51% b/w 2014-20."
Avangrid (16/x):

-OSW dev. "brings significant economic benefits to local and regional communities"

-"In a study published 2020, Avangrid estimated that to develop & construct Kitty Hawk over next decade...would result in $2B of total economic impact and 1,700+ jobs to VA/NC"
Avangrid (17/x):

-Duke's Plan "to construct OSW capacity in 800-MW phases is inefficient and detrimental to ratepayers"

-Duke's Plan "proposes scenarios that fail to meet the mandated 2030 emissions reduction and does not accurately reflect OSW capacity that can meet 2030 d/l"
Avangrid (18/x):

-Duke's Plan "does not accurately include the lowest-cost or fastest tx strategy for near-term build out of OSW"

-Also, "Kitty Hawk is only wind site that can definitively meet the mandated 2030 emissions reduction deadline" ImageImage
Avangrid (19/19):

-"Kitty Hawk is the most viable wind site that can be utilized for the Carbon Plan"

-"Kitty Hawk has significantly lower risks than the Carolina Long Bay (CLB) OSW leases"

-Kitty Hawk "has the lowest LCOE in the region"

-Recommendations follow: Image
Next up: Clean Power Suppliers Association (CPSA) (1/x):

Comments linked here:…
CPSA (2/x):

Exhibit A -- Expert Analysis performed by The Brattle Group as part of CPSA's comments, a higher-res version of which is linked here:…
CPSA (3/x):

"Rather than attempting to prescribe a detailed pathway to decarbonization, the Gov. and NCGA charged this Commission w/ all-important taks of devising a detailed plan for achieving the reduction in CO2 emissions called for by the Governor and by [HB951]."
CPSA (4/x):

NCUC "appropriately approached this historic task by requiring Duke to submit a plan for achieving the mandates of [HB951] and seeking comments from interested parties to inform NCUC's decisions about the contours and contents of its carbon plan"
CPSA (5/x):

"But ultimately what the law requires is that this Commission, not Duke Energy or anyone else, determine the necessary elements of a carbon plan that achieves the reduction in emissions required by the law at least cost and while preserving system reliability."
CPSA (6/x):

"Duke has performed an important service in providing a useful starting point for NCUC's deliberations, and ... there are many aspects of [Duke's Plan] and approach to the task of decarbonization that CPSA agrees with and comments."
CPSA (7/x):
"However, [Duke's Plan] reflects numerous serious flaws that should not be embraced/repeated by NCUC. The most problematic of these is that, w/o sufficient evidence/explanation, Duke has taken an inappropriately bearish view re rate at which it can add solar [gen.]"
CPSA (8/x):

"B/c solar is both least cost form of new gen & most established, proven & readily available new gen resource in Carolinas, the result of Duke's excessive conservatism is a set of resource portfolios that cost more & present > risk than [ones w/ more solar faster]"
CPSA (9/x):

"Fortunately, NCUC's job is made easier by the fact that, as Duke proposes, it need not make ultimate decisions about all the details of the Carbon Plan now."
CPSA (10/x):

"CPSA agrees that most prudent course for NCUC to take at this time is to approve a 3-year Execution Plan that will support a range of potential resource portfolios & to defer decision on selection of preferred portfolio in a follow-on proceeding 2 years from now"
CPSA (11/x):
"But to preserve the potential for that preferred portfolio to offer least cost option for NC ratepayers, it is essential that Execution Plan require substantially > solar procurement in 2022-24 than has been proposed by Duke[, which is both] reasonable & achievable"
CPSA (12/x):

"CPSA believes that the Carbon Plan is unreasonable and imprudent in a few respects, including the following:" Image
CPSA (13/x):

"CPSA therefore recommends that the NCUC direct Duke to make the following changes to the Carbon Plan:" Image
CPSA (14/x):

CPSA's other recommendations: Image
CPSA (15/x):

Positive Attributes of [Duke's Plan]:
-"CPSA supports Duke's general approach of presenting a set of portfolios designed to achieve HB951's decarb mandates, w/o asking NCUC to select a preferred path, while seeking approval of a near-term Execution Plan..."
CPSA (16/x):

"Except as discussed below, CPSA does not take issue w/ the vast majority of the modeling inputs & assumptions utilized by Duke in its modeling. This does not mean that CPSA necessarily agrees w/ those inputs/assumptions, and it necessary to revisit later"
CPSA (17/x):

"However, given wide array of contested issues that must be resolved by NCUC, & preliminary nature of [initial] Carbon Plan, the parties and NCUC should focus attention only on those issues of greatest import, rather than litigating every aspect of the Carbon Plan"
CPSA (18/x):

"An aspect of Duke's Carbon Plan modeling approach that CPSA actively supports is Duke's decision to model emissions from new generating facilities that may be located in SC."
CPSA (19/x):

"CPSA believes that a resource plan that reduces CO2 emissions in Duke's South Carolina territories is consistent with resource planning principles required under South Carolina law."
CPSA (20/x):

Issues with Duke's modeling assumptions:
-"Duke's solar interconnection cap is unexplained and unsupported, increases costs, and makes [HB951] compliance more uncertain" Image
CPSA (21/x):

In Brattle modeling, "Duke's solar interconnection cap reduces amount of solar selected by the model for 2030 compliance by nearly half, from ~9500 MW in the unconstrained case to 5200 MW," which forces in "more expensive wind resources, ...
CPSA (22/x):

... increasing annual system cost by $900M in 2030 and $800M in 2032."

-Duke hasn't justified solar interconnection cap

-Interconnection rates likely to improve in near term

-Other states achieving higher interconnection rate Image
CPSA (23/x):

CPSA "proposing a set of portfolios that incorporate moderate annual interconnection limits that in CPSA's view are achievable." Image
CPSA (24/x):
"Duke provides no info on their modeling results when it comes to the levels of economic paired vs. standalone storage built across scenarios. Rather, Duke simply puts forward a seemingly arbitrary 600 MW of paired storage...along with 1,000 MW of standalone storage"
CPSA (25/x):
"CPSA strongly recommends future solar procurements call for significant amounts of solar+storage. However, existing contracting procurement & structures are not well-suited to procurement of solar+storage, primarily b/c they do not capture full resource value"
CPSA (26/x):

-"HB 951 does not permit compliance to be delayed past 2032 in the manner proposed by Duke"

-CPSA's alternative portfolios, CPSA1-5, represent alternatives to achieve compliance with 70% CO2 reduction by 2030 & 2032, respectively ImageImage
CPSA (27/x):

-Supports RZTEP upgrades, which CPSA states are needed for HB 951 compliances
-Supports proactive tx planning
-Need to factor benefits as well as costs of tx improvements
-Duke should be req'd to investigate role for grid enhancing technologies in the system (GETs)
CPSA (28/28):

CPSA makes the following recommendations to the NCUC: Image
On deck after dinner:
-Sean Lewis

And because I'm evidently a glutton for punishment, I also agreed to summarize comments filed in docket by non-intervenors (i.e. non-parties), which include Vote Solar, John Locke Foundation & Durham County.
Up next: Sean Lewis (Lewis) (1/x):

-Climate change is happening as "a direct result of human activity in the form of GHG emissions"

Comments linked here:…
Lewis (2/x):

"I do believe in capitalism. ... I also believe that capitalism, from time to time, must be tempered, for the good of society. That is the role of our government. Especially so in this case, given that Duke...operates as a monopoly without competition"
Lewis (3/x):

"It is hopefully clear that Duke Energy's emissions are of paramount importance in the uphill battle we face to dramatically shift towards renewable energy sources in order to avoid the worst effects of an already shifting climate."
Lewis (4/x):
"Which puts you, NCUC, in a very unique position. You regulate the 1st or 2nd largest GHG emitter in the US. Which puts you in a position [of] immense power. This also comes w/ a great deal of responsibility. [Y]our decisions & actions will be felt around the world."
Lewis (5/x):

-Incentives are skewed

-"Currently, [Duke's] incentive is to build expensive infrastructure in order to guarantee higher returns, regardless of efficiency or any other social considerations."
Lewis (6/6):

"We...cannot afford to adopt [Duke's Plan]. We need to have Duke invest more substantially in renewable sources. Those renewable sources are cost competitive, & in fact most are already cheaper than fossil fuels, even before accounting costs"
Next up: Mid-Atlantic Renewable Energy Coalition (MAREC) (1/x):

"MAREC specifically supports CCEBA's positions on...the unreasonable and unjustified constraints on solar procurements in the Near-Term Execution Plan; ...

Comments linked here:…
MAREC (2/x):

... the need for comprehensive tx planning reform; and, the unjustified reliance on the development of [SMRs] and green hydrogen."
MAREC (3/x):

"MAREC also fully supports CCEBA's recommendations to significantly increase the levels of solar..., including by mandating solar and Solar+Storage; and the need to encourage OSW development in NC[, which should be underscored]."
MAREC (4/4):

"MAREC anticipates that the non-Duke leaseholders of OSW lease areas will contest the need to extend the plan past the 2030 timeline. The Commission should hear testimony on this and statements in the Carbon Plan indicating otherwise."
Next up, 350 Triangle & NC Alliance to Protect Our People and the Places We Live (350 Triangle/NC-APPPL) (1/x):

Comments linked here:…
350 Triangle/NC-APPPL (2/x):
-"As proposed, [Duke's Plan] will provide the least benefit to those most at risk from climate change, energy insecurity, and pollution impacts from fossil fuel generation."

-Each portfolio relies "heavily on the construction of costly new NG plants"
350 Triangle/NC-APPPL (3/x):

Incorporate concerns and evidentiary support offered by App Voices, NC WARN, and the Environmental Working Group re: "how the reliance on new NG is inconsistent with HB 951"
350 Triangle/NC-APPPL (4/x):

"Despite its status as a private stockholder-owned corporation, Duke is able to pass the costs for construction of new energy generation facilities onto rate-paying consumers, plus a 'rate of return' on the costs of the assets to ensure profits"
350 Triangle/NC-APPPL (5/x):

"This public subsidy of private risk and guaranteed profits includes not only costs of construction, but of maintenance and fuel costs as well. Moreover, these cost breakdowns are not publicly disclosed in the proposed Carbon Plan."
350 Triangle/NC-APPPL (6/x):

"Certain other intervenor groups have access to cost information after signing covenants not to disclose the data but have indicated in a recent filing that the data have still not been provided in a usable form."
350 Triangle/NC-APPPL (7/x):

"All intervenors and ratepayers, as the parties who will ultimately have the burden of these costs, should have access to cost data to understand the inputs included in Duke's modeling[.]"
350 Triangle/NC-APPPL (8/x):

"[T]he Commission must evaluate whether Duke is adequately considering the full scope of costs, including social costs, of the proposed Plan."
350 Triangle/NC-APPPL (9/x):

Social costs of FF energy gen include:
-EJ concerns
-"disproportionate impact of externalities such as air/water pollution and accompanying impacts on the health of people in the local communities where power plants are sited"
-water supply issues
350 Triangle/NC-APPPL (10/x):

Social costs, con't.:
-Agricultural productivity
-Cultural impacts ("particularly on Native American and historically Black communities)

"add'l social costs stem from myriad impacts of climate change on these vulnerable communities"
350 Triangle/NC-APPPL (11/x):

-SCC = $51/ton CO2

-Corresponding cost for methane is $1500/metric ton, by comparison, but "no reckoning of these externalities whatsoever anywhere in Duke's proposed Carbon Plan"
350 Triangle/NC-APPPL (12/x):

"CP does not disclose whether fuel costs and future fuel cost increase projections are incorporated into Duke's modeling and proposals. These costs must be included to accurately assess the financial viability of add'l [FF gen vs. renewables]"
350 Triangle/NC-APPPL (13/x):

[Duke's Plan] "fails to include cost estimates for any new supply infrastructure, incl both direct and social costs of taking private land for pipeline easements, and dates of construction and completion."
350 Triangle/NC-APPPL (14/x):

Duke "fails to adequately consider avoided/reduced costs from meaningful EE measures, ratepayer-paid infrastructure, [DERs] & other proven non-FF tech that would save ratepayers $, improve resiliency, increase diversification & abate climate change"
350 Triangle/NC-APPPL (15/15):

"Given that the costs of [Duke's Plan] will be borne by the ratepayers, all costs, including construction, maintenance, and fuel costs, stranded-asset costs, supply and transmission costs, and social costs should be factored in."
Up next: Environmental Working Group (EWG) (1/x):


Expert analysis 1:…

Expert analysis 2:…
EWG (2/x):

Duke's Plan "is deficient in at least the following respects":
-P1-P4 "are substantially similar, thereby limiting NCUC's ability to objectively develop a least cost path that meets or exceeds present grid reliability levels"

EWG (3/x):

Deficiencies, con't.:

-Duke's Plan "does not adequately consider the latest technological breakthroughs and other approaches to achieve the least cost generation and resource mix, such as optimizing deployment of DERs"
EWG (4/x):

Deficiencies, con't.:

-Duke's Plan "does not evaluate the social costs of carbon in comparing the costs of its four portfolios and related emissions reduction targets"

-Reliance on "putative 'green hydrogen market' in all 4 portfolios is unrealistic and speculative"
EWG (5/x):

-Duke's Plan "likely underestimates demand growth due to electrification of transportation and of non-electric energy uses in the residential and commercial sectors"

-"fails to adequately capture requirements for maintaining or increasing grid reliability/resilience"
EWG (6/x):

Deficiencies, con't.

-no "analysis of economic risks & reliability considerations associated w/new & existing nuclear technology"

-"option to put hydrogen in existing pipelines may increase indoor air pollution, disproportionately impacting resi/commercial NG users"
EWG (7/x):

-None of 4 portfolios "consider lower cost approaches and advanced technologies"

-Duke's Plan "undermines the reliability of the electric grid"

-Duke's "proposed nuclear technology and reliance on existing nuclear is not a reasonable and prudent step"
EWG (8/x):

-"Nuclear power is not economically competitive and presents great risks"

-"The historical delays in nuclear deployment will make it unlikely for Duke's Carbon Plan to meet emission reduction targets of HB951"
EWG (9/x):

-"SMRs are an economically impractical alternative and do not provide a suitable complement to wind or [solar]"

-Duke "should not be permitted to bypass other opportunities for regulatory oversight" (i.e. CPCNs, reasonableness/prudency evaluation in base rate cases)
EWG (10/10):

Plan disregards "potentially lower cost technological innovations that could have a major role in a future decarbonized grid" like vehicle-to-grid technology

-SCC would provide "objective" basis for NCUC to determine least cost pathway to comply with HB 951
And while I think/hope/pray that's the end of all intervenors of record, I promised I'd summarize the 3 sets of comments filed in the docket by non-parties who haven't intervened (b/c I'm a glutton for punishment): Vote Solar, John Locke Foundation & Durham County.
Vote Solar (1/x):

"Vote Solar seeks to promote development of solar at every scale, from distributed rooftop solar to large utility-scale plants, & to encourage common-sense electrification of the economy, all as part of the transition away from FF-powered energy consumption"
Vote Solar (2/x):

"In 2020, in a settlement agreement w/ Vote Solar, Duke agreed to convene a Working Group to study the impact of climate change on its physical infrastructure investments in the electric grid. As part of this work, Duke has released a web map that...
Vote Solar (3/x):

...'provides an overview of selected climate change hazard projections for Duke's service territory in North and South Carolina.'

This tool can be accessed here:
Vote Solar (4/x):

"This tool is remarkable in its detail & implies widespread risk to assets in the service area from sea level rise, increased precipitation, & extreme heat as early as 2030... high potential for Major Event Disruptions in NC and SC" is dangerous for customers
Vote Solar (5/x):

"Vote Solar contends that direct integration of resilience into the Carbon Plan process is necessary b/c the cost of resilience (such as hardening assets) & cost of inadequate levels of resilience (economic/social impacts of outages) should be critical factors"
Vote Solar (6/6):

Integrating resilience into the Carbon Plan looks like: ImageImage
Up next: John Locke Foundation (JLF) (1/x):

JLF's Comments and Analysis of Duke's Plan and a Least Cost Decarb Alternative linked here:…
JLF (2/x):

"Our analysis models the cost and reliability implications for Duke's 4 CO2 reduction plans and provides an alternative scenario, the Least Cost Decarbonization (LCD) scenario, that is lower-cost and more reliable than any of Duke's [portfolios.]"
JLF (3/x):

"The main takeaway is this: North Carolinians can either have a least-cost, reliable electric grid or reduce carbon dioxide emissions. They cannot have both."
JLF (4/x):

"[N]one of the 4 [Duke portfolios] appear ready for prime time. Each would rely heavily upon investments in variable renewable energy (VREs) to meet HB951 requirements..., & speculative technologies they have not proved they can scale at a reasonable cost thereafter"
JLF (5/x):

"Each of the scenarios studied, including the LCD scenario, would cost > $100B through 2050 and increase the cost of electricity by at least $170 per customer per month by 2050."
JLF (6/x):

"Given the magnitude of these costs, these carbon plans deserve a thorough vetting by the public and the state legislature to ensure North Carolinians are willing to pay the costs associated with meeting the goals established in HB 951"
JLF (7/x):

"It is important to note that in order to achieve 100 percent CO2 neutrality by 2050, each scenario in Duke's CO2 Reduction Plan would rely heavily on the use of hydrogen fuel at new and some existing NG units, which constitute b/w 8800-9900MW of capacity, depending"
JLF (8/x):

"The primary shortcoming of this strategy is Duke's fuel-cost assumptions for hydrogen, which are substantially lower than current costs. Duke assumes a cost of $1 per kg of so-called green hydrogen, which is made using carbon-free electricity. $1/kg = $7.4/MMBtu"
JLF (9/x):

"Duke also notes the uncertainties surrounding whether there will be an adequate supply of hydrogen fuel for these facilities, as powering these facilities with green hydrogen would necessitate the construction of an entirely new supply chain."
JLF (10/x):

"Each of the [portfolios] discussed would cause substantial increases in electricity costs for North Carolina families and business, but a portfolio that focuses on building reliable, dispatchable power plants would decarbonize at the lowest cost"
JLF (11/x):

"Furthermore, nuclear power plants, which can last for up to 80 years, would provide lower-cost electricity in the future as they depreciate and repay initial capital costs. That is not the case for wind/solar assets that only last 20 and 25 years, respectively."
[Apologies, I got distracted mid-stream, but I'm back to finish up JLF and then summarize Durham County and then we are DONE]
JLF (12/x):

con't. from JLF (11/x) -- "[This] would necessitate a constant 'build and rebuild' treadmill of capital expenditures that virtually guarantee ratepayers never have low-cost electricity after capital costs are recouped."
JLF (13/x):

"[Duke's Plan is] predicated on large capex for wind and solar and rely on optimistic hydrogen cost assumptions that are not reflective of the current state of the technology. For this reason, more study is needed by stakeholders thru a thorough public info process"
JLF (14/x):

-Costs of P1-P4 would range from $141.7B-$162.3B by 2050, w/ most costs "backloaded" after 2035

-Resi bills by 2050 would have increased $86-$95 per month, and C&I bills "would see great increases as well"
JLF (15/x):

"Hourly load estimates during a model week in August found capacity shortfalls of 31-41 hours, which could be significant enough to trigger load-shedding"
JLF (16/x):

Avg. cost of CO2 reduced would range b/w $246-$259/metric ton, "which would be several times higher than even the Obama admin's...SCC"
JLF (17/x):

"[A]ll of this would occur [via] a great increase in the amount of installed capacity in NC."

P1 - 92.3% increase in capacity
P2 - 88.4% increase in capacity
P3 - 87.3% increase in capacity
P4 - 84.3% increase in capacity
JLF (18/18):
"Without a doubt a significant reason for seeking such a massive buildout in installed capacity is the perceived need to overbuild [renewables], which do not emit CO2 but which are inherently intermittent and unreliable, in order to overcome their intermittence"
And finally, Durham County (Durham) (1/x):

Comments linked here:…
Durham (2/x):
"Implementing the systematic changes needed to meet the goals of the Carbon Plan is good for the economy of Durham County and North Carolina. Clean energy investment in NC totaled more than $1.6B in 2020 and has contributed $22.5B to gross state product b/w 2007-20"
Durham (3/x):

"In 2007, Durham became the first community in NC to adopt a GHG emissions reduction plan. That plan includes goals to reduce emissions in government operations by 50% and in the community as a whole by 30% by 2030."
Durham (4/x):

"The Board of County Commissioners subsequently adopted an additional goal in 2019 to transition government operations to 80% renewable energy by 2030 and 100% by 2050 in a just and equitable manner."
Durham (5/x):

"We have invested staff time and financial resources, implemented policies, and completed numerous projects that have already reduced our energy use intensity by 15% even as our square footage increased by 74%."
Durham (6/x):

"Even w/ implementing everything possible w/in our own control, we will not be able to meet our operational or community goals w/o significant and swift decarb of the electricity grid that includes phasing out FFs and quickly ramping up renewables, EE, and storage"
Durham (7/x):

Recommendations to NCUC -

1. "All pathways in the Carbon Plan adopted by NCUC must align with the state goals of a 70% reduction in emissions by 2030 from 2005 levels"
Durham (8/x):

"2. Increase the role of EE/DSM programs in the Carbon Plan to help all customers address affordability, reduce emissions of GHGs, manage peak loads, and reduce the need for overbuilding generation capacity."
Durham (9/x):

"The plan's target of 1.0% of retail load is significantly below the performance of many states and just barely meets the national average of states that have energy efficiency resource standards (EERS)."
Durham (10/x):

"We applaud Duke's efforts to develop an on-bill financing pilot and encourage stakeholders to improve EE measures and programs through the DSM/EE Collaborative and the Low-Income Affordability Collaborative."
Durham (11/x):

"We further encourage incorporating more strategies from these processes and those identified in the NC Energy Efficiency Roadmap into the Carbon Plan modeling and the Market Potential Study."…
Durham (12/x):

More recommendations to NCUC, including "rapidly reduce FF generation and replace it with commercially proven, low-cost renewables."
Durham (13/x):

NCUC should "retire and replace coal power plants w/ clean energy portfolios to improve health outcomes and reduce ratepayers costs while working to mitigate workforce and tax base impacts in affected communities."
Durham (14/x):

Carbon Plan should "increase renewable energy procurement opportunities available to all customers who more than what the grid provides."
Durham (15/x):

Carbon Plan "does not fully account for the benefits of DERs. On-site solar, battery energy storage, and microgrids can support energy resilience and reduce probabilities of outages in the wake of severe weather or other grid disruptions."
Durham (16/x):

"Durham relies on FF generators for backup power to critical infrastructure and those generators will have to be phased out per [Durham's] Renewable Energy Plan."
Durham (17/x):

"Microgrids powered by DERs and storage would be ideal options for replacing the generators because they can island during grid disruption. DERs have other enviro and economic benefits beyond resilience and emergency management."
Durham (18/x):

"The necessary T&D infrastructure upgrades will not only allow for more DERs, but can also result in their own efficiency improvements, thus reducing overall load growth."
Durham (19/x):

NCUC should "prioritize proven technologies that are commercially viable rather than relying on unproven technologies that carry high risks to ratepayer dollars."
Durham (20/x):

NCUC should "adjust load forecasts to account for changes due to beneficial electrification and decreases due to demand side management and technological advances to improve utility planning and load management."
Durham (21/21):

NCUC should "incorporate robust and inclusive stakeholder engagement through implementation, evaluation, and iterative versions of the Carbon Plan."
And here is a link to the encore thread of supplemental comments/expert report filed today by CLEAN Intervenors (NCSEA, SACE, Sierra Club, and NRDC):

• • •

Missing some Tweet in this thread? You can try to force a refresh

Keep Current with Christina Cress

Christina Cress Profile picture

Stay in touch and get notified when new unrolls are available from this author!

Read all threads

This Thread may be Removed Anytime!


Twitter may remove this content at anytime! Save it as PDF for later use!

Try unrolling a thread yourself!

how to unroll video
  1. Follow @ThreadReaderApp to mention us!

  2. From a Twitter thread mention us with a keyword "unroll"
@threadreaderapp unroll

Practice here first or read more on our help page!

Did Thread Reader help you today?

Support us! We are indie developers!

This site is made by just two indie developers on a laptop doing marketing, support and development! Read more about the story.

Become a Premium Member ($3/month or $30/year) and get exclusive features!

Become Premium

Don't want to be a Premium member but still want to support us?

Make a small donation by buying us coffee ($5) or help with server cost ($10)

Donate via Paypal

Or Donate anonymously using crypto!


0xfe58350B80634f60Fa6Dc149a72b4DFbc17D341E copy


3ATGMxNzCUFzxpMCHL5sWSt4DVtS8UqXpi copy

Thank you for your support!

Follow Us on Twitter!