The testimony reviews and evaluates Duke Energy’s 2025 Carbon Plan and Integrated Resource Plan (CPIRP) on behalf of the Southern Alliance for Clean Energy, Sierra Club, and Vote Solar. The analysis examines Duke’s proposed Near-Term Action Plan (NTAP) and Recommended Portfolio, with a focus on resource planning assumptions, cost and risk exposure to ratepayers, and the evolution of Duke’s planning approach across successive planning cycles.
The testimony raises concerns in several areas:
- Methodology underlying Duke’s sensitivity and risk analysis
- Trajectory of Duke’s NTAP with respect to gas-fired generation, coal retirements, renewable energy, energy storage, and demand-side resources
- Long-term cost implications of the proposed portfolio for customer bills
- Assumptions underlying Duke’s load forecast.
The testimony also presents alternative portfolio analyses demonstrating that resource strategies with lower reliance on new gas-fired generation could reduce costs and risks for ratepayers across a range of future scenarios.
The testimony recommends that the Commission decline to approve certain proposed gas resources pending further analysis; approve near-term solar and energy storage additions; expand the deployment of demand-side resources; require Duke to pursue renewable energy, surplus interconnection, and pumped storage opportunities; and improve the analytical framework used in future resource planning proceedings.
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