MountainTrue, the Creation Care Alliance of WNC (CCA), and other local renewable energy advocates are pushing for a stronger decarbonization plan to help North Carolina meet the renewable energy goals laid out in HB 951, the “Energy Solutions for North Carolina” bill passed by the NC General Assembly in October 2021.

The North Carolina Utilities Commission (NCUC) is hosting a series of hearings in the coming months to receive public feedback on Duke Energy’s draft Carbon Plan. MountainTrue, CCA, NC Interfaith Power and Light (NCIPL), the Sierra Club and other local groups are encouraging the public to show their support for a stronger decarbonization plan at NCUC’s hearing in Asheville on July 27.

MountainTrue, CCA, and NCIPL hosted a free webinar about Duke Energy’s draft Carbon Plan on Wednesday, July 13. The webinar featured MountainTrue Central Regional Director Gray Jernigan and NCIPL Director Susannah Tuttle, M.Div, as guest speakers. Webinar attendees learned about the implications and shortcomings of Duke Energy’s Carbon Plan and left with the information needed to take action in support of our state’s clean energy future at the upcoming NCUC hearing on July 27. Click here to watch the webinar recording on the MountainTrue YouTube channel.

During the public hearings, NCUC asks that only one representative from a given organization speak. In addition to organizational representatives, independent individuals may offer testimony and those that do not wish to testify may observe the proceedings and/or gather and demonstrate outside of the hearing venue. Demonstrations are not allowed in the hearing room. A virtual statewide hearing is scheduled for August 23, 2022. Click here for more information on the process, schedule, and opportunities for public input.

Advocating for a just, equitable, and science-based carbon plan is central to MountainTrue and CCA’s green energy and climate change-focused work. “Everyone has the right to clean and affordable energy with the assurance of equitable energy production, transmission, distribution, and consumption that won’t harm our health, the health of non-human creatures, or the climate,” says CCA Director Sarah Ogletree, “we invite all who are interested to attend this webinar and we look forward to working together to shape North Carolina’s clean energy future.” 

The details of Duke’s draft Carbon Plan:

HB 951 charges NCUC with developing a Carbon Plan that takes reasonable steps toward achieving our state’s clean energy future and addresses the threats posed by climate change. The bill directs state regulators to cut carbon emissions from energy plants owned and/or operated by Duke Energy by 70% from 2005 levels by 2030 and reach carbon neutrality by 2050. Last November, NCUC ordered Duke Energy to file a draft Carbon Plan by May 16, 2022. 

Duke Energy is proposing four different portfolios to achieve carbon neutrality by 2050, and they are requesting that NCUC approve all four options, essentially asking for blanket approval for whatever strategies and infrastructure the company wants to employ. Only one of the portfolios achieves HB 951’s interim goal of 70% carbon reduction by 2030, and that portfolio is the most costly of the four according to Duke’s analysis. All four portfolios achieve the 2050 carbon neutrality goal, though the means used to achieve said goal are starkly different from one another.

Each portfolio also includes 2400 megawatts (MW) of new natural gas and around 1000 MW of gas-fired peaking capacity.  And each one includes between 4900 and 6200 MW of coal plant retirements and efforts to reduce energy use through energy efficiency and demand side management programs. Here are the highlights:

Portfolio 1: Achieves the 70% carbon emissions reductions by 2030 with 800 MW (one 800 MW block) of offshore wind, 5400 MW of new solar, and the addition of nearly 1,800 MW of new battery energy storage capacity. The average annual bill impact estimated by Duke’s analysis is a 2.5% increase.

Portfolio 2: Achieves the 70% carbon emissions reductions by 2032 with two 800 MW blocks of offshore wind — the first in 2029 and the second in 2031 — and 5800 MW of solar and less battery storage. The average annual bill impact estimated by Duke’s analysis is a 2.4% increase.

Portfolio 3: Achieves the 70% carbon emissions reductions by 2034 with new nuclear, 7700 MW of solar, 2200 MW of battery storage, and no offshore wind. The average annual bill impact estimated by Duke’s analysis is a 1.9% increase.

Portfolio 4: Achieves the 70% carbon emissions reductions by 2034 with both offshore wind and new nuclear, 6800 MW of solar, and 1800 MW of storage. The average annual bill impact estimated by Duke’s analysis is a 2.0% increase.

“Duke Energy’s draft Carbon Plan makes significant advances in the development of solar and wind energy resources and battery storage. However,” explains MountainTrue’s Gray Jernigan, “Duke’s draft plan falls short because it relies too heavily on unproven technologies like small modular nuclear reactors. Additionally, it proposes new natural gas plants and fails to use cost assumptions that reflect market realities of the affordability of renewable energy generation compared to gas.” Click here to review Duke Energy’s entire draft Carbon Plan and its summaries.

HB 951 places the responsibility of developing our state’s final Carbon Plan on NCUC rather than Duke Energy, requiring NCUC to incorporate public input into the planning process. NCUC should carry out its public input process in a way that meaningfully involves and seeks input from historically marginalized communities, including communities of color.

NCUC has the ultimate authority to adopt the best Carbon Plan for the state — not necessarily one of the portfolios proposed by Duke Energy. We believe that NCUC should develop a carbon plan that centers the well-being of NC communities, prioritizes a climate justice-based legislative approach, and reduces our state’s dependency on fossil fuels to mitigate the effects of climate change. Therefore, MountainTrue is encouraging NCUC to exercise its authority to the fullest extent to achieve the goals of HB 951 and protect the people and environment of North Carolina.

We at MountainTrue urge NCUC to consider the following points to improve the Carbon Plan:

1) No New Gas. All four of Duke’s draft Carbon Plan scenarios rely on large quantities of new gas-fired generation. The Carbon Plan should avoid committing to new natural gas facility construction.

2) If Duke is going to miss the 2030 goal, miss it because of wind investments and not nuclear. Only Portfolio 1 meets the 70% reduction by 2030 goal, while the other three portfolios miss the  2030 target date. If that deadline is going to be missed, Portfolio 2 is the only other acceptable starting point with its expanded investments in offshore wind, although it will not meet the interim goal until 2032. Portfolios 3 and 4, which include new nuclear generation and miss the 2030 deadline, should be scrapped. 

“While we understand these are the costliest options to meet decarbonization goals, the additional investment in green renewable energy sources rather than unproven small nuclear energy sources and the faster timeline justify the increased cost when we are racing against the clock to mitigate the impacts of global climate change,” says Gray Jernigan. “Additionally, we will be joining others in advocating for rate structures that protect the most vulnerable populations and low to moderate income households who bear disproportionate impacts from environmental and financial standpoints.”

3) No Reliance on Commercially Unproven Technology. NCUC’s Carbon Plan must not rely on commercially unproven technologies like nuclear small modular reactors or gas plants that could theoretically be converted to hydrogen.

4) Use Energy Efficiency and Demand Side Management Before Building New Fossil Generation.* Energy Efficiency and Demand Response proposals are consistent across scenarios, at levels that were rejected by stakeholders in the Energy Efficiency and Demand Side Management Programs (EE/DSM) collaborative as insufficient. Essentially, NCUC should focus on maximizing energy efficiency and reducing demand instead of generating more power. EE/DSM Programs can be used to reduce the need for new generation, and NCUC should follow the example of utilities in other states in dramatically expanding these programs rather than proposing goals that fall below energy efficiency gains achieved by the utility in recent years.

*New generation: refers to Duke Energy-owned versus third-party-owned energy generation such as wind, solar, etc. 

5) Don’t Rely on the Utility’s Inflated Cost Assumptions. Utility ownership of generation increases the cost of new generation. NCUC must ensure that the Carbon Plan mandates the least cost, proven clean technology and does not rely on inflated utility cost assumptions for new generation and transmission.

6) Protect Historically Marginalized Communities. Prioritize the retirement of fossil fuel plants near communities that have been disproportionately burdened by the negative impacts of fossil fuels. Don’t let the utility site a new fossil fuel plant or pipelines in already burdened NC coal plant communities.  

7) Transmission. Transmission is the bottleneck limiting NC’s access to renewables. The Carbon Plan must order Duke to build sufficient transmission capacity to access the full potential of offshore wind, onshore wind, and solar power in a timely manner. 

8) Securitization. The Carbon Plan must clarify that Duke Energy will use securitization in a timely fashion to retire coal facilities and to lower costs for customers. The sooner coal plants are retired the more customers will benefit from savings from securitization.

9) The Carbon Plan should increase the resiliency of the state’s energy system. Energy systems are vulnerable to the impacts of climate change and resource availability, and the Carbon Plan that is ultimately approved should increase the system’s resilience in the face of these threats. 

10) Alternative Plans Achieve the Carbon Plan Goals Without Reliance on New Gas and Should be Accorded Equal Weight with Duke Energy’s Draft Plan. Through the process, alternative plans may be submitted, and those should be given equal consideration by the NCUC.