Does the Tar Heel State’s Carbon Plan Make the Grade?
This iteration of the Carbon Plan is the third time People Power North Carolina has scored the efforts of Duke Energy to meet its carbon reduction mandates and the enforcement work of the North Carolina Utilities Commission (“NCUC”). In 2021, the NC General Assembly passed HB 951, which directed the NCUC to adopt a “Carbon Plan” that would reduce carbon dioxide (CO2) emissions from electricity generation to 70% below 2005 levels by 2030 and achieve “net zero” CO2 emissions by 2050. Shortly thereafter, People Power NC, a coalition of environmental justice, climate, and clean energy advocacy nonprofits, published 12 Principles for a Carbon Plan in the Public Interest. The NCUC instructed Duke Energy to draft a plan, which it published in May 2022. We published a second scorecard that graded the Duke draft against our 12 principles. Duke’s draft plan received an F.
The NCUC issued an order containing the state’s first Carbon Plan on Dec. 30, 2022, and our second scorecard grades that plan. Unfortunately, the NCUC gave Duke Energy almost everything it wanted, virtually ignoring much more ambitious and achievable plans submitted by intervenors. The plan makes achieving NC’s 70% decarbonization goal nearly impossible by 2030. We returned a grade of D-.
Finally, in August of 2023, Duke Energy submitted its first full update of the Carbon Plan. However, Duke then submitted an overhaul of this update (“Supplemental Planning Analysis”) on January 31st, 2024, stating that the load growth of the system was projected to increase eight times more than its previous calculations. After reviewing both the Carbon Plan and the Supplemental Planning Analysis, we must return a grade of F.
A carbon plan in the public interest should...
Be an independent, transparent, dynamic, and objective process that holds Duke accountable to meeting and exceeding North Carolina’s carbon reduction goals
Grade:
Incomplete
Comments
Duke’s proposed plan does not meet the state’s policy goals or NCUC’s carbon plan requirements. The NCUC must consider a third-party analysis of the Carbon Plan, as Duke’s proposed plan contains biases and assumptions in modeling that allow the plan to trend towards methane gas and small modular reactors (SMRs).
Center stakeholder feedback
Grade:
D-
Comments
Duke’s proposed gas buildout, in conjunction with the activities of other utilities, directly overburdens communities already dealing with the legacy of coal. .
Address historic harm from fossil fuels and dirty energy
Grade:
F
Comments
Duke’s proposed gas buildout, in conjunction with the activities of other utilities, directly overburdens communities already dealing with the legacy of coal.
Lead to fair and affordable electricity bills
Grade:
F
Comments
Duke’s plan implies significant costs and risks for electricity customers while minimizing the benefits of energy efficiency and other demand side investments in reducing customers’ electricity bills. In Duke’s proposed portfolio, electricity bills are projected to increase by $80 per month by 2038. Duke’s demand growth is driven by large industrial, manufacturing and data center loads, but residential customers are exposed to rising costs.
Maximize near-term deployment of renewable resources and storage
Grade:
D-
Comments
Duke’s modeling limits wind, solar, and energy storage to unreasonably low levels, overstates the cost of these resources, and places arbitrary 20% cost adders for renewables on the portfolio that meets the carbon goals.
Set an ambitious timeline for closing coal
Grade:
F
Comments
Duke has estimated all coal plants will be closed by 2036. However, Duke’s overall assumptions favor new gas plants, rather than relying on a transition to renewable energy, which would negate any positive impact created by the retirement of the coal plants.
Allow no new gas
Grade:
F
Comments
Duke has limited renewable resources and storage to encourage gas buildout, inflates the reliability of gas, and ignores the large risks of potentially stranded assets if the proposed gas plants cannot reach their full lifespan.
Capture maximum benefits of customer-owned resources
Grade:
F
Comments
Duke’s modeling assumes significant increases in electricity demand and minimizes the amount of new utility-scale renewable resources that can be installed. By ignoring the full weight of customer-side potential and imposing other constraints, Duke falsely models significant gas as the only way to meet electricity demand.
Ensure reliable and resilient electricity service for all customers
Grade:
D
Comments
Duke takes a narrow view of reliability in its analysis, focused entirely on having excess electricity in times of crisis, as opposed to alleviating the impact of reliability issues on consumers.
Avoid risky bets on unproven future technologies
Grade:
F
Comments
Much of Duke’s proposed Carbon Plan relies on technologies (SMRs and hydrogen) that are not yet commercially available and have unknown future costs and timelines.