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Parties Filed Comments On The Solar Procurement Proposal For Use Of Resource Solicitation Cluster And Elimination Of Red Zone Expansion Plan Cost Adder
Reply comments on solar procurement proposal were due by May 23, 2024. An overview of some of the comments filed are presented below.
Southern Alliance for Clean Energy, Sierra Club, and Natural Resources Defense Council – notes that “further adjustments to reduce attrition would be wise,” recommending: (i) a further increase in the procurement amount; (ii) “requiring Duke to offer provisional interconnection service… and relatedly, allow projects to connect first with energy-only interconnection service (ERIS) with the opportunity to connect as network resources (NRIS) later on”; (iii) “requiring Duke proactively to consider and show that it has maximized the use of ‘grid-enhancing technologies’ (GETs) to improve transmission capacity”; and (iv) “requiring Duke to prioritize bids for projects with earlier in-service dates to the extent it does not already do so, possibly through an explicit scoring mechanism”.
Carolinas Clean Energy Business Association (CCEBA) proposed a number of procedural changes to the RFP process, including: (i) “Increase PPA payments to mitigate increased carrying costs for upgrade delays that extend beyond initial upgrade estimate”; (ii) “Reduce the DEP curtailment cap from 10% to 5%, to be equal in DEC and the curtailment forecast in CPIRP Portfolio 3”; (iii) “Offer provisional interconnection service”; (iv) adopting interconnection on an energy, rather than network, resource interconnection service basis; (iv) allowing transmission-level projects “to bid a price with an understanding that the project would be subject to limited curtailment during specific contingencies identified in advance by Duke”; (v) “Prioritize projects with earlier in-service dates in bid scoring”; (vi) “Duke should be required to actively pursue and use “no regrets” technological improvements for grid enhancement, particularly in areas where network upgrades are delaying project dates; (vii) “Allow interconnection customers to pay acceleration charges” while CCEBA recommended enlarging outage windows.
CCEBA also recommended increasing transparency and frequency of reporting and CCEBA identified several continuing issues from the 2023 procurement. See docket link below to review all comments filed.
As background, this docket is for Duke Energy’s filings regarding its solar energy procurement to comply with the Initial Carbon Plan adopted by the NCUC, which requires Duke Energy to target the procurement of 2,350 MW of new solar during the 2023-2024 period.
E-2 SUB 1340 (Opened 02/06/2024)
(Duke Energy Progress, LLC 2024 Solar Procurement Pursuant to Initial Carbon Plan)
