The testimony presents an analysis of Duke Energy’s 2025 Carbon Plan and Integrated Resource Plan as well as the North Carolina Attorney General’s Office’s position on the 2025 Near-Term Action Plan, Recommended Portfolio, and related recommendations.
The analysis focuses on several areas in which the underlying planning assumptions are found to be unreasonable: load forecasting, coal retirement schedules, supply-side resource selection, and the pending merger of Duke Energy Carolinas and Duke Energy Progress. The testimony raises concerns that Duke’s load forecast incorporates a substantial volume of large-load demand, including data center customers, that is not yet supported by executed long-term contracts, and that this forecast is driving proposed investments in new natural gas generation that may expose existing ratepayers to unnecessary cost risk. The testimony also identifies modeling assumptions that may disadvantage solar, wind, and battery storage resources relative to natural gas in Duke’s resource optimization process.
The testimony recommends that the Commission defer certain proposed gas resources until large-load growth is supported by binding contracts, adjust the Recommended Portfolio to include additional solar, storage, and wind resources, require updated modeling assumptions that align with industry norms, and establish ratepayer protections that clarify how costs attributable to new large-load customers will be allocated.
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