NC Carbon Plan

Moving North Carolina Toward a Clean Energy Future

New legislation (HB 951) signed by Governor Cooper in 2021 requires the North Carolina Utilities Commission (NCUC) to develop a carbon plan for the state by the end of 2022 that would reduce carbon dioxide emissions to 70% below 2005 levels by 2030 and achieve carbon neutrality by 2050. Duke Energy is required to provide a draft Carbon Plan to state regulators and CleanAIRE is working with our partners to ensure the Carbon Plan is done with the public interest in mind.

A look at Duke Energy's Draft Carbon Plan

The Good, the Bad, and the Ugly

A special webinar to learn more about the draft Carbon Plan Duke Energy submitted to the NC Utilities Commission last month. Led by NC Climate Ambassadors, the webinar provides an overview of the plan, distinguishes between strategies that move us closer to a clean energy economy and those that don’t and discusses the best opportunities for us to engage collectively and individually in this important process.

How to Get Involved

Duke Energy claims that their climate strategy is their business strategy. Join us to push them to stand by their word, and help us make sure North Carolina does its part in the fight to curb climate change.

On May 16th, Duke Energy submitted a draft Carbon Plan to the NCUC. While their proposed plan is a good starting point, it ultimately falls short of our emission targets by delaying our move away from coal plants and fracked gas.

The good news? Duke Energy’s plan is only a proposal, one we still have an opportunity to shape. Clean energy advocates now have 60 days to review Duke’s draft plan and file their critiques, or to submit their own alternate plans. Let’s not give Duke Energy the last word.

There will be numerous opportunities to provide input and share your voice in the plan’s public process. We hope you will join us and make your voice heard. Sign up to get more information about the public witness testimony opportunities, how to engage in other ways, and receive reminders of key dates as the NC Carbon Plan is developed.

Frequently Asked Questions

What is the NC Carbon Plan?

Duke Energy says, “The Carolinas Carbon Plan will serve as a road map for reducing carbon emissions from power generation.”

  • In October 2021, the N.C. General Assembly passed, and Gov. Roy Cooper signed a bipartisan energy bill into law that requires the N.C. Utilities Commission (NCUC) to develop a plan by the end of 2022 that would reduce carbon dioxide emissions in the state to 70% below 2005 levels by 2030 and achieve carbon neutrality by 2050.

    Duke Energy is a monopoly utility company that provides electricity to more than two million North Carolina families. They inherently make choices based on profit motive, not ESG (Environmental, Social, and Governance) goals. They will always put profit ahead of people and the environment.

    The NCUC instructed Duke Energy to file a draft NC Carbon Plan by May 16, 2022. The plan will have far-reaching implications for the Tar Heel state’s economy, climate efforts, and public health.

Duke Energy says, “The Carolinas Carbon Plan will serve as a road map for reducing carbon emissions. Guided by stakeholder input, the plan will target 70% carbon reduction in the 2030 time frame, as compared to 2005 levels, and achieve net-zero carbon emissions by 2050.”

  • Giving a “2030 time frame,” instead of committing to hitting the 70% target by 2030, is like saying you’ll be fashionably late, except this time, being late comes with unknown increases in climate related costs. There is no room for being late to keep warming to 1.5 degrees Celsius. That is why it is imperative we hit the targets mandated under HB 951.

    Some utilities have disingenuous definitions of “net-zero carbon emissions” that do not actually mean carbon-free. For example, Dominion Energy’s 2019 Integrated Resource Plan explains on page 2 of the executive summary, “Net zero does not mean eliminating all emissions, but instead means that any remaining emissions are balanced by removing an equivalent amount from the atmosphere. For example, this can occur through carbon capture, reforestation, or negative-emissions technologies such as renewable natural gas.” Duke Energy has a number of renewable natural gas projects completed, underway, or planned. These are not carbon free (or negative-emission) projects, and as such, should not be considered in the NC Carbon Plan.

Duke Energy says, “We’ve already made incredible progress, retiring two-thirds of the coal plants in the Carolinas and reducing emissions by more than 40% since 2005. We are committed to bringing our customers and communities affordable, reliable and clean carbon-free energy as quickly as possible.”

  • Duke Energy should build out clean, non-emitting, generation sources like wind, solar, and battery storage as quickly as possible while preserving low rates and protecting those who can’t afford increased costs on their electric bill. As such, they should retire the remaining coal fleet and replace that generation capacity with carbon-free electricity.

Is the same Carbon Plan being filed in North Carolina and South Carolina?

No. South Carolina does not have a Carbon Plan. Duke Energy says they do not plan to move their emitting sources of energy generation south. However, studies like one compiled by The Brattle Group in slides 15, 16, 94, and 95 of their slide deck, indicate that Duke will likely claim that, to preserve energy reliability, it must replace coal with more methane gas.

It is entirely possible that Duke Energy will try to build out methane-fueled plants in South Carolina. Since solar generation is now generally cheaper than other sources of electricity generation, methane or other fossil fueled generation sources may not survive. However, once Duke builds a new methane-burning plant, customers will be on the hook to pay for it, even if it has to close early due to changing economics or carbon policies. Most large fossil fuel plants are financed with 30+ year long agreements, an Energy Innovation report estimated that cost of early closures at $4.8 billion.

Who decides on the final NC Carbon Plan?

Regulators. In fact, HB 951, the North Carolina law that requires this process, mandates that the Utilities Commission create the plan themselves. People Power NC and CleanAIRE NC affirms as its first key principle in 12 Principles for a Carbon Plan in the Public Interest that the plan is the sole responsibility of the Commission.

We believe in the event that Duke Energy’s plan does not hit the statutory emission reduction levels, the Commission must send Duke back to the drawing board.

Why does carbon reduction matter?

A 2021 report by Energy Innovation shows that a strong national clean electricity policy will avoid health and climate damages to the tune of $100-250 billion through 2030-35, and $1-3 trillion through 2050. It will also prevent between 85,000 to 300,000 premature deaths through 2050. The report demonstrates benefits to grid reliability, job growth, and energy affordability. While the NC Carbon Plan is specific to North Carolina, it positions our state to be a leader in the transition.

Additionally, a joint study by Duke University and UNC-Chapel Hill developed using extensive modeling and broad stakeholder input shows that if North Carolina joins the Regional Greenhouse Gas Initiative (RGGI), a campaign currently underway at the NC Department of Environmental Quality, and uses the resulting revenues to fund direct residential bill assistance, the state could see lower residential electricity bills (page 114). When revenues are used for bill assistance plus energy efficiency investments, it drives job creation (page 114).

Including policies like RGGI in the NC Carbon Plan can also “improve health outcomes in fenceline communities…[by making] relatively deep reductions in local air pollutants, including coal retirements,” and “is important when considering equity in policy design” (page 6).

How will the Carbon Plan affect customer rates, and when?

Duke Energy says, “It is too early to determine the potential cost.”

  • This answer is not sufficient; policy design does matter. If designed correctly from the start, the NC Carbon Plan can effectively reduce rates. It can also increase rates if designed improperly. The NC Carbon Plan will contain key decisions affecting Duke Energy’s upcoming rate filings that are anticipated to be filed late 2022/early 2023.

    The People Power NC Alliance has advocated in principle 9 that the NC Carbon Plan should “Lead to Fair and Affordable Rates.” There are numerous ways to keep rates affordable, such as including energy efficiency requirements in the NC Carbon Plan, or as some groups have suggested using RGGI revenues for efficiency projects and bill assistance programs.

How does methane gas fit into the Carbon Plan? Is gas compatible with a net-zero goal?

People Power NC’s 7th principle is “Allow No New Gas.” The Brattle study confirms on pages 20 and 99 that unless additional solar generation or additional wind is considered, it will be very difficult to meet the 2030 target of 70% carbon reduction.

The study states: “Duke’s proposed limits on annual solar installations is likely to increase compliance costs of H951 or prevent achieving the 2030 target” [sic].

Confirming this possibility, Duke’s latest Integrated Resource Plan on page 16 called for building as much as 9600 MW of new methane-burning power plants, so it is highly likely the NC Carbon Plan will likely include a significant investment in new gas plants.

Though methane gas emits less carbon dioxide than coal when burned, it still emits a lot. New methane-burning power plants built today will have a useful life of several decades, so ratepayers will either be paying to retire those units early, or still be emitting CO2 well past 2050. More importantly, methane is a climate pollutant up to 100 times more potent than CO2. A March 2022 study published in Environmental Science & Technology shows as much as 9.4% of the methane being extracted today may be leaking unburned into the atmosphere. Earlier research found that any leakage over 3% made methane gas worse for the climate than coal.

In announcing publication of the Sixth Assessment Report on Mitigation of Climate Change in April, UN Secretary General António Guterres called investments in new fossil fuel infrastructure “moral and economic madness.” Clearly, increased burning of methane gas is diametrically opposed to the climate-protective intent of HB 951.

Key Dates

Plan Submission Period
Public Comment Period

The following dates will be opportunities to voice your concerns about Duke Energy’s draft Carbon Plan. We need major public participation in all hearings – let’s pack the rooms!

Monday, July 11, 2022 | 7:00 pm
Durham County Courthouse, Courtroom D7, 510 S. Dillard St. Durham, North Carolina 27701

Tuesday, July 12, 2022 | 7:00 pm
New Hanover County Courthouse, Courtroom 317, 316 Princess Street Wilmington, North Carolina 28401

Wednesday, July 27, 2022 | 7:00 pm
Buncombe County Courthouse, Courtroom 1-A, 60 Court Plaza Asheville, North Carolina 28801

Thursday, July 28, 2022 | 7:00 pm
Mecklenburg County Courthouse, Courtroom 5350, 832 E. 4th Street Charlotte, North Carolina 28202

Tuesday, August 23, 2022 | 1:30 pm and 6:30 pm
Virtual hearings via WebEx – a link to view the hearing will be available at

Finalizing the Carbon Plan

July 15, 2022 | Deadline for intervening parties to file alternative plans or comments on Duke Energy’s draft plan. 

September 2, 2022 | Deadline for intervenors and the NCUC’s Public Staff to file expert testimony and relevant exhibits.

September 9, 2022 | Deadline for Duke Energy to file expert testimony and relevant exhibits.

September 19, 2022 | Expert witness testimony begins. Testimony and exhibits are to be filed by this date.

Sign up for Updates

Sign up to get more information about the public witness testimony opportunities, how to engage in other ways, and receive reminders of key dates as the NC Carbon Plan is developed.


Duke Energy’s FAQ with agendas, videos, and other resources from their three-day-long stakeholder meetings, and “technical subgroup meetings”.

Pulling back the Curtain: Who’s Charting our Energy Future: A six-part webinar series that details the NC Utility Commission’s role in energy policy, how other states are doing with renewable energy production, and how you can help chart a clean energy future.

CleanAIRE NC’s Review of Duke Energy’s 2020 Climate Report and associated Duke Energy climate strategies.

People Power NC’s 12 Principles for a NC Carbon Plan in the Public Interest:

Academic papers specific to North Carolina and the Southeast: