Environmental Defense Fund urges NC Utilities Commission to reject Duke Energy’s flawed Carbon Plan proposals

(Raleigh, NC – October 19, 2022) Environmental Defense Fund (EDF) today urged the North Carolina Utilities Commission (NCUC) to reject the proposals Duke Energy submitted in May 2022 to comply with House Bill 951’s directive to develop a Carbon Plan by the end of 2022. EDF encouraged the NCUC to instead develop its own plan that takes advantage of readily available, affordable renewables and energy efficiency, enabling all North Carolinians to have a cleaner, healthier, more equitable energy future. 

In comments filed today, EDF’s Director for Southeast Climate and Energy, Will Scott, said there is a better path forward than what Duke Energy proposed. 

“Overinvesting in new fossil fuel power plants and relying on commercially unavailable technologies risks committing North Carolina ratepayers to a more expensive energy future, while making it more difficult to reach critical climate goals. Investment in proven, reliable clean energy solutions, many of which provide cheaper electricity than fossil fuel counterparts, offer a “no regrets” pathway toward decarbonization.”

EDF’s comments convey the importance of meeting the state’s decarbonization goals on time, noting that “early and persistent pollution cuts are much more valuable than future reductions because those cuts mean less pollution for each year thereafter.” EDF's comments address major problems in Duke Energy's proposals, highlighting five key areas:

1. Gas: Duke Energy’s filed plans rely on multiple new methane-burning facilities, exposing North Carolina ratepayers to ongoing power bill increases due to high fuel costs. North Carolinians will pay the price if Duke Energy’s plans to lock ratepayers into decades of price increases and additional emissions are approved. 
2. Hydrogen: Green hydrogen is not a silver bullet and should be saved for hard-to-electrify use cases, not to power the grid. Duke Energy’s proposal seeks to justify investments in new and existing natural gas facilities by promising to retrofit them to run on hydrogen, which is a risky and expensive solution – particularly when the most efficient, cheapest, and safest way for North Carolina to decarbonize the electric power sector is by investing in renewable power, battery storage and energy efficiency. 
3. Transmission: Without a comprehensive transmission infrastructure plan, North Carolina’s energy transition could be stunted. Duke Energy’s current plans are not adequate. A proactive, long-term transmission planning approach is necessary to ensure a rapid and consistent transition to clean energy that yields the carbon emissions reductions needed and lowers costs for customers.
4. Electric Vehicles: Electric vehicles are a potential grid resource as well as a source of additional electrical demand. Duke Energy’s plan undervalues how many electric vehicles will come online, which in turn undervalues the importance they place on modifying the grid to charge those vehicles and to use them as a resource during times of peak demand.
5. Environmental Justice: Outreach and engagement with communities that are disproportionately impacted by fossil fuel infrastructure has been insufficient during the Carbon Plan development process. EDF is urging the NCUC to rectify that by incorporating the input from these communities that was lacking in Duke Energy’s proposals, affirming that this insight is critical to an inclusive and equitable outcome now and for future plans. Examining the impact of proposed and existing fossil fuel infrastructure on local communities and proactively soliciting and incorporating their input in a meaningful way is important for the viability of this process.

The environmental justice concerns are a critical element of EDF’s comments. As Scott wrote in his filed comments, “Overburdened communities cannot continue to bear the brunt of pollution from reliance on combustion technologies while utility-led stakeholder processes fail to provide the Commission with the information necessary to ensure “fair treatment and meaningful engagement.” The state of North Carolina, alongside its regulated utilities, has an opportunity in the transition to a cleaner grid to protect communities and produce a safer, healthier future for North Carolina families.” 

EDF also noted that, “Layering multiple policies that are complementary and mutually-reinforcing can be more effective in achieving state goals than when one is adopted alone. A recent report by EDF and Rural Beacon Initiative describes the interplay between HB 951 and joining the Regional Greenhouse Gas Initiative (RGGI), noting cost-savings, accelerated carbon emissions reductions, and additional economic development that would result from North Carolina’s participation in RGGI.”

In summary, Scott said, “Duke Energy’s plan to decarbonize the power sector through natural gas plants and increased hydrogen blending is not justified on a climate, cost, or social impact basis. The utilities’ proposal seeks to justify investments in existing natural gas facilities by trying to retrofit a risky and expensive solution – when the most efficient, cheapest, and safest way for North Carolina to decarbonize the electric power sector is by investing in renewable power, battery storage and energy efficiency.”