North Carolina must reject Duke’s misguided carbon plan relying on non-existent nuclear

Duke’s plan fails to meet state’s ‘reasonable and prudent’ and ‘least cost’ thresholds

WASHINGTON – North Carolina regulators must reject Duke Energy’s ill-conceived carbon reduction plan, a coalition of advocacy groups argued this week. The plan will fail to achieve emissions cuts, because it relies on costly and unproven nuclear technology, the group said.

Instead of wasting millions on non-existent nuclear reactors, Duke should embrace clean, safe and available renewable energy sources like wind and residential solar, the groups said in a formal filing with the North Carolina Utilities Commission, which has final say on the utility’s plan. The filing is signed by the Environmental Working Group, 350 Triangle and North Carolina Alliance to Protect Our People and the Places We Live.

The filing repeatedly highlights Duke’s failure to provide any details about cost, construction timing, location and the economic and operational risks of adding nuclear small modular reactors, or SMRs, to achieve its goal of net-zero carbon emissions by 2050. The plan is doomed to failure because it throws money at a technology that isn’t viable.

“Given that Duke Energy’s proposal does not select a specific SMR technology, does not present any information on candidate sites, or present information concerning the operational and economic risks associated with new nuclear technology, the Commission cannot undertake an adequate review in this proceeding sufficient to comply with the statutory requirements” of a state law requiring review of a utility’s decision to incur project development costs associated with a potential nuclear electric generating facility, the groups wrote.

It's no shock that Duke is essentially avoiding customer-owned solar, because it is separately also asking the commission to approve a plan that would decimate the state’s popular rooftop solar program – the only viable power supply competition the monopoly utility faces.

Duke carbon plan fails state’s ‘least cost’ threshold statute

Under state law HB 951, Duke is required to put forth a 2050 net-zero carbon plan that is the “least cost” to ratepayers. But the plan the utility submitted to state regulators lacks any details about how much it will cost to design, build and operate the SMRs on which it relies.

There is no more expensive, uneconomic form of electricity generation than nuclear power. Virtually every plant in operation, including those owned or canceled by Duke, came in behind schedule and far more expensive than initial utility estimates.

If North Carolina regulators approve Duke’s plan, ratepayers will be on the hook to cover millions in development costs, whether the SMRs are ever built or not.

“Duke utterly failed to provide the necessary information in its plan about how sinking millions into untested nuclear plants is the least-cost approach for ratepayers,” said EWG Senior Energy Policy Advisor Grant Smith. “The company’s own executives admitted as much during the proceeding before the commission.”

During cross-examination by EWG’s North Carolina counsel before the state utility commission, Duke executive Chris Nolan cited the 50-megawatt SMR being developed by NuScale, based in Portland, Ore., as the model nuclear technology described in its carbon plan that received a design certification approval.

NuScale’s project is the only one certified by the U.S. Nuclear Regulatory Commission, and it has already been delayed by about 14 years, with $3 billion in cost overruns. Duke failed to acknowledge any of these real-world problems in its pie-in-the-sky plan and is tying itself to the same fate if it wins approval for its SMR-focused strategy.

Duke’s plan relies on a 77-megawatt SMR from NuScale, not 50 megawatt. The NRC has not certified the design of a 77-megawatt SMR in the U.S. Under cross-examination by EWG counsel before the North Carolina Utilities Commission earlier this month, Nolan was forced to admit that detail.

Q.        . . . [W]ould you agree that, since this section of Table L-4 is referencing the NuScale 77-megawatt reactor design, stating that it received a design certification approval in August 2020 in that second bullet, is not entirely accurate?

A.         NuScale did receive a design certification approval. It is not for the 77-megawatt. So those two are not aligned. . . .

A Duke witness also admitted that the monopoly utility did not consider climate risks when assessing advanced nuclear power in the utility’s carbon plan. Nuclear thermo-electric power plants, which use huge amounts of water to generate steam to run the turbines that produce electricity, are becoming increasingly vulnerable because of increasing frequency of heat waves and drought. Power output can be greatly decreased during such episodes, threatening electric system reliability, just when power is most needed to meet high demand.

Duke plan fails to meet ‘reasonable and prudent’ burden requirement

Duke also failed to provide the information necessary “to support approval of the decision to incur proposed project development costs” regulators need to determine “if the public utility [Duke Energy] demonstrates by a preponderance of evidence that the decision to incur such costs is reasonable and prudent,” the groups wrote in their brief.

“Duke’s carbon plan only underscores that investing in cheap, safe and renewable power sources like wind and residential solar is an abstract concept for the company, which remains rigidly fixated on wasting millions on non-existent nuclear plants,” said EWG’s Smith.

“We urge the commission to reject Duke’s ill-conceived plan and require the company to submit a proposal grounded in reality that invests in cost-effective, renewable sources of electricity that prioritize customer-owned and community solar plus storage, energy efficiency, demand response and distributed wind resources,” Smith said.

In its joint post-hearing brief, EWG supports:

  • An analysis by Synapse Energy Economics, commissioned by the North Carolina Sustainable Energy Association, Southern Alliance for Clean Energy, Natural Resources Defense Council and Sierra Club, that showed SMRs would not be needed in the near-term to meet the state’s carbon goals.
  • Appalachian Voices’ proposed findings and conclusions in a recent brief on energy efficiency priorities for addressing electric bill affordability in Duke territory. 
  • NC WARN’s latest brief that shows Duke’s continued overreliance on natural gas,  marginalized solar plus storage and rooftop solar modeling results, and “unrealistic” assumptions regarding the timing of SMR deployment. 

The commission will make a final decision about whether to approve Duke’s carbon plan, along with its attack on rooftop solar, sometime later this year.

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The Environmental Working Group (EWG) is a nonprofit, non-partisan organization that empowers people to live healthier lives in a healthier environment. Through research, advocacy and unique education tools, EWG drives consumer choice and civic action.

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