The Carolinas Clean Energy Business Association (CCEBA) filed initial comments on the carbon plan submitted by Duke Energy sixty days ago.
CCEBA makes the following comments and recommendations, detailed in Executive Summary below:
- HB951 requires the Commission 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. Duke Energy’s four portfolios do not achieve those required results, and three of them seek extensions of time that have not yet been proven necessary.
- CCEBA agrees with Duke Energy that the Commission should adopt a Near-Term Execution Plan to begin work on those elements that would be consistent with all potential 2030 Carbon Plans portfolios have in common.
- Duke Energy’s constraint on solar procurements in the first three to four years of the Carbon Plan is unwarranted, skews the Near-Term Execution Plan, and increases the cost of the Carbon Plan for ratepayers. Due to the negative impact on ratepayers, the Commission should forcefully question and push back on the premises behind Duke Energy’s proposed solar cap.
- CCEBA recommends comprehensive transmission planning reform and urges the Commission to direct Duke Energy to take steps to reform the NCTPC process in order to advance the stated policy of HB951 and the Carbon Plan through long-term, proactive and holistic transmission planning that will allow for the least-cost, timely integration of new low carbon resources.
- In the meantime, CCEBA supports the “Red Zone” transmission upgrades set forth in Appendix P to the Carbon Plan as critical steps to allow the required volumes of solar to move forward at least-cost by 2030.
- Duke Energy’s Carbon Plan places unjustified faith in the development of Advanced Nuclear and green hydrogen technologies, skewing its cost estimates in favor of Advanced Nuclear and new gas generation and against solar, storage, and wind.
- 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 offshore wind resources in North Carolina.
- CCEBA recommends beginning an immediate stakeholder process to develop a Solar+Storage PPA that adequately compensates developers, incentivizes the addition of storage to solar projects, and allows Duke Energy to dispatch the storage associated with Solar+Storage, as required by HB951. CCEBA believes that all solar procured through HB951 after 2022 should be paired with energy storage, and recommends the Commission direct Duke Energy to model the dispatch of energy storage, including storage associated with Solar+Storage.
- CCEBA supports Duke Energy’s recommendation to “shrink the challenge” through adoption of energy efficiency and grid edge programs, however, reasonable assumptions for the achievable volume of savings should be used.
- CCEBA supports Duke Energy’s proposal to consolidate system operations across DEP and DEC, including Balancing Authorities, Transmission Operators, Transmission Service Providers, and Transmission Planners as during the near term of the Carbon Plan (2022-2024).