In comments to utilities commission, Appalachian Voices explains how and where Duke’s carbon plan misses the mark

July 15, 2022

Dan Radmacher, (540) 798-6683),
Adrienne Underwood, (530) 919-2164,

BOONE, NC — Today, Appalachian Voices submitted comments to the North Carolina Utilities Commission evaluating the draft plan submitted by Duke Energy to reduce its carbon emissions. With the 2021 passage of House Bill 951, the North Carolina General Assembly mandated that the commission approve a plan by the end of 2022 to reduce power sector emissions by 70% by 2030.

Appalachian Voices has been heavily involved in the effort to clean up North Carolina’s energy system, engaging with Gov. Roy Cooper in the development of his Clean Energy Plan and actively participating in the North Carolina Energy Regulatory Process that helped set the guidelines for H.B. 951 and the carbon plan. We’ve also served as co-lead on the Low-Income Affordability Collaborative, which has identified programs and investments to increase affordability for low-income customers while helping achieve interim and long-term emissions goals.

“Our filing at the North Carolina Utilities Commission today is a synthesis of years of work to help the state reach necessary emissions goals while creating a grid that is affordable and reliable for all North Carolinians — especially those facing the greatest challenges to afford their electric bills,” said Rory McIlmoil, senior energy analyst with Appalachian Voices. “We encourage the commission to put forth a final carbon plan that incorporates clean energy investments that meet our state’s carbon goals in a more affordable and equitable manner.”

In its comments, Appalachian Voices notes the many shortcomings of Duke’s draft plan, including its false assumptions that North Carolina needs to expand the availability of methane gas to meet interim emissions targets and its failure to accurately capture the full financial risks — stranded assets, volatile fuel costs and others — associated with that expansion.

The plan is criticized for failing to consider a combined portfolio of energy efficiency, energy storage, offshore wind, demand response, and distributed solar and storage.

The comments also include analysis from a report by PSE Healthy Energy, a nonprofit research institute dedicated to supplying evidence-based scientific and technical information on the public health, environmental, and climate dimensions of energy production and use. PSE Healthy Energy examined how energy efficiency, renewables and energy storage options left out of Duke’s plan could help meet the state’s goals affordably and reliably.

“Upon review of the Duke Carolinas Carbon Plan, we found that multiple clean energy resources were significantly underutilized,” said Yunus Kinkhabwala, clean energy scientist for PSE Healthy Energy. “Our analysis shows that increasing renewables is not only feasible, but can drastically reduce financial burdens, public health damages, and carbon emissions from the proposed scenarios in Duke’s plan.”

This analysis shows that a more aggressive target of 2% savings per year through energy efficiency could provide 14,300 gigawatt-hours of energy savings and 2,300 megawatts of demand reduction beyond Duke’s current plans — about the amount of capacity that would be provided by Duke’s proposed gas combined cycle plant expansion.

Appalachian Voices asked the commission to investigate several questions in an evidentiary hearing, among them:

  • Will Duke’s failure to address energy affordability through investments in targeted energy efficiency, distributed energy and demand response increase total energy costs and the energy burden for all customers?
  • Does the draft plan underestimate the risks and costs of new natural gas-dependent energy generation, including fuel cost volatility and the impacts of methane emissions?
  • Does the plan fail to sufficiently utilize solar, offshore wind and demand-side resources to reduce or eliminate the need for additional gas generation?