The North Carolina Utilities Commission issued an order Monday combining Duke Energy’s integrated resource plan with its carbon plan. 

The regulator approved the firm’s first carbon plan late last year, separately from the IRP process. (See North Carolina Regulators Approve Duke’s 1st Carbon Plan.) 

For regulatory efficiency, the two are going to be rolled into one process, with Duke filing a proposal earlier this year after consulting with the NCUC’s public staff for weeks. 

The utility will have to file a consolidated carbon plan and integrated resource plan (CPIRP) every two years for approval, which will have Duke continuing to meet its obligation to serve load in its territory while making long-term plans for carbon neutrality. State law requires a 70% cut in carbon emissions by 2030 and carbon neutrality by 2050. 

The plans will have to include several different resource portfolios so that a range of demand-side, supply-side, energy storage and other technologies can be fairly evaluated in the process. Those plans are required to either maintain or improve upon the adequacy and reliability of the existing grid. 

The NCUC agreed with the North Carolina Attorney General’s Office that at least one of the plans Duke submits needs to meet the 2030 carbon target. Legislation gave the commission the authority to delay that target, and it needs the planning data to make that decision, it said. 

The CPIRPs will require near-term action plans that identify specific investments in the demand and supply sides, procurements and retirement activities, and upgrades to the transmission system needed to interconnect new resources. The attorney general suggested that Duke be required to identify whether those near-term plans can support the resource portfolios in the CPIRP and, if not, any additional activities that would bring the company on track to meet longer-term carbon goals. The commission agreed. 

The NCUC declined to include transmission planning into the CPIRPs directly, but it agreed with some intervenors that the carbon plans should inform it. Duke will have to discuss how the most recently approved CPIRP was incorporated into its transmission planning process, the regulator said. 

The CPIRP process includes some stakeholder meetings before it is filed with the NCUC and that is meant to produce a report on what was discussed during that time. The NCUC said that the report will have to include a list of which stakeholder ideas Duke decided to adopt in its initial plan, which will give the commission some clarity on how well the early stakeholder discussions are working. 

The Clean Energy Buyers Association asked the NCUC to require Duke to include information on the costs and benefits of participating in the Southeast Energy Exchange Market (SEEM) and whether participating in an RTO, especially PJM (which neighbors Duke’s territory), would be cheaper overall. 

Duke opposed CEBA’s request, saying nothing in the relevant statutes on carbon plans and IRPs discusses wholesale market participation. The utility also said it would join an RTO only if state or federal legislation required that, which is not the case now. 

IRP modeling also is not capable of capturing the 15-minute granularity of SEEM transactions over a long planning period, Duke said. 

The current rules already are enough for Duke to consider wholesale issues, and requiring the kind of study CEBA wants would only add unnecessary costs given the lack of legislation requiring RTO membership. 

Duke filed its initial CPIRP in August, and said it followed the proposal that was pending at the NCUC at the time. The commission deemed that August filing in compliance with the order issued Monday.