The Commission is a policy-making body, not a rubber stamp. It has an opportunity to take an independent look at the data from all parties involved, request outside support if needed, and offer its own plan. It’s too soon to tell whether the NCUC will take ownership over this process — but we encourage them to do so! 

While Duke held its required stakeholder meetings, the process was performative and did not enact real change. Ultimately, Duke did not adequately incorporate stakeholder feedback into their selection of portfolios.

Though Duke Energy states several times throughout its proposed carbon plan that the clean energy transition in North Carolina is supported by a wide array of stakeholders, it fails to mention why a clean energy transition is necessary and why the goals of HB 951 are structured as they are: the urgency of emissions reduction.

Duke mentions recommendations that emerged from the Clean Energy Plan process, but there is no indication that those recommendations were seriously considered during the carbon plan stakeholder process. There is no attempt to coordinate carbon plan work with the development of other measures already underway, and Duke refuses to even study mechanisms such as a wholesale market advanced by other stakeholders.

The amount of solar and storage in Duke’s plan is increased compared to the company’s latest Integrated Resource Plan (IRP), but still much less than is possible. The amount of offshore wind less than in the IRP, less than the amount for which leases have already been sold, and much less than Governor Roy Cooper’s target. These constraints are likely due to the fact that Duke can make more money from building gas infrastructure and promising us future technologies that are not currently available, such as hydrogen and small modular nuclear reactors.

It is a total failure that Duke’s proposed carbon plan extends the life of multiple coal plants beyond the 2029 date that was included in Duke’s last IRP. Getting rid of coal quickly is one of the most efficient ways to meet the carbon reduction goals established by HB 951.

Building new gas infrastructure and increasing our reliance on fracked gas to generate electricity risks climate catastrophe due to fugitive methane, threatens to saddle ratepayers with billions in stranded costs, puts us at the mercy of gas price volatility, and requires destructive pipelines that may never be permitted. Duke plans up to 4,000 MW of new gas, arguing it is needed to keep the grid reliable. It is not

The plan fails to compare demand-side programs to supply-side resources such as new gas or nuclear plants, making it impossible to determine the least-cost pathway to reduce carbon.

Today, rates are already unaffordable for the thousands of people struggling to pay their bills and even being disconnected for the inability to pay. While there are concurrent conversations about affordability dynamics in the Low-Income Affordability Collaborative and elsewhere, there is nothing specific in the carbon plan to address affordability.

Communities living in the shadow of dirty power plants have already paid dearly for our reliance on energy sources that are not clean – suffering more health impacts and adverse impacts to local economies than other communities. To ensure a just transition, a carbon plan must acknowledge the role these facilities continue to play in communities across North Carolina and ensure their voices are heard in visioning a clean energy future.

Duke Energy’s draft carbon plan is too dependent on centralized infrastructure, fails to take advantage of developing distributed technologies like microgrids and vehicle-to-home storage applications, and ultimately lacks the transparency needed to allow communities to adequately prepare for our changing climate.

It is not enough to decide what Duke Energy is willing to do to decarbonize. Other local and state policies are needed to allow everyone – cities, businesses, homeowners, renters and others – to contribute to the clean energy transition. Duke and the NCUC should identify and support policies that would complement utility actions.