Energy costs are driven by a number of factors, but first and foremost by utility spending. Utilities submit proposals to increase rates to regulatory agencies for review and approval, and the regulators review the ways, many of which are path-dependent, in which the utilities have already spent money.
That’s why states have a regulated planning process upstream from utility spending decisions, typically called Integrated Resource Plans, or IRPs. In North Carolina, for example, Duke has to submit an IRP to the North Carolina Utilities Commission (NCUC) every two years. The latest of these was submitted in October of 2025 and is being considered by the NCUC right now.
IRPs are usually billed as super technical, wonky, and difficult to understand. In fact, utilities benefit if customers are under that impression, because then they can more easily move their agendas forward without our input, leaving us assuming that they know best while they propose whatever they want. But public input is actually really important in these procedures, because IRPs are one of the primary ways that utilities make important decisions, such as:
- Whether to spend money on affordable, reliable options or expensive, risky options to provide customers with electricity.
- How much money to spend in the future to provide customers with electricity. Too much and bills go up even more; too little risks the lights not staying on.
This balance is why IRPs center affordability, and why it is important that the process is transparent, the regulators making the final decision are well-informed by the utility and experts, and the public has ample opportunity to make its voice heard.
One way regulators get expert assessment on Duke’s IRP is through the expert testimony filed by intervenors like SACE. We worked with co-intervenors Sierra Club and Vote Solar and attorneys at the Southern Environmental Law Center to file testimonies by three experts, including nationally recognized grid planning expert Maria Roumpani of the Current Energy Group. Here, I’ll bring in some key points and quotes from Roumpani’s testimony for anyone who doesn’t have the time to read through the full document (but if you do, please read it!).
Former DOE official, energy entrepreneur and investor, and long-time energy podcaster Jigar Shah has also weighed in on Duke’s proposal, as well as on multiple podcasts. His assessments of Duke’s plans align with Roumpani’s. Overall, the experts agree (I’m paraphrasing): most of Duke’s plan is stuck in the past, too expensive, and risks further increasing ratepayer bills.
If the NCUC approves Duke’s plan without carefully considering the critiques and alternatives presented in Roumpani’s testimony and other expert testimony, it risks the long-term affordability of electricity in North Carolina.
Experts Call Out Duke for Gas Plants
Roumpani is critical of Duke’s decision to invest in several large gas power plants despite frequently claiming that it will always “check and adjust” its strategy when developing an IRP. Roumpani points out that the opposite is happening: as the gas plants made less and less sense, Duke adjusted its decision-making process so that it could continue justifying more gas plants, instead of reducing its investments in new gas plants altogether.
“The addition of large, capital-intensive gas units, whose costs have risen significantly in recent years, increases costs for ratepayers. The need for substantial fuel security investments further amplifies this risk.” -Roumpani Testimony, pg. 14
“Duke has repeatedly selected strategies that prove inferior, while reframing its decision-making to justify those choices.” -Roumpani Testimony, pg 4
“In effect, Duke is neither meaningfully checking recent trends nor adjusting its strategy.” -Roumpani Testimony, pg. 12
Jigar Shah is also critical of Duke’s plan to double down on gas plants, instead of focusing on solutions that make more sense, like adding batteries to existing solar in the state.
“Look at Duke Energy. They had a very robust plan to invest in their grid to meet load growth, and they just increased that plan by another 18 percent — building new central natural gas generation, upgrading transmission and distribution. They separately have 7,200 megawatts of utility-scale solar in North Carolina that they already have contracts with. None of those projects have batteries. The hyperscalers have already offered to install batteries at all of those locations, which would dramatically reduce rates for everyone in the state. Duke finds that weird — I get it, they haven’t done that before. But Lord Almighty, they’re asking for a 15 percent rate increase right now to implement their current plan.”
~Jigar Shah, Energy Empire podcast from March 12, 2026, “The Cheapest Grid is the One We Already Paid For.”
Duke’s IRP = Higher Bills
The likely outcome of Duke continuing to build all these gas plants, no matter the cost? Roumpani and Shah agree: higher bills for customers.
“Finally, the cumulative scale of these investments drives bill increases that Duke’s own workpapers confirm are large and persistent. At the level of a single facility, a cost overrun or a wrong resource choice would be an unfortunate but manageable outcome. However, a build-out of this magnitude, premised on the same flawed assumptions, becomes an irreversible error that cannot be corrected once the capital is committed, with impacts compounding over decades for ratepayers, not shareholders, to bear.” -Roumpani Testimony, pg. 116
“If we accommodate load growth in a way that uses these modern technologies, rates might go down. Everyone is weirdly obsessed with making sure rates don’t go up as fast — I don’t think they realize that if you follow this report, rates could actually go down. That’s pretty awesome.”
~Jigar Shah, Energy Empire podcast from March 12, 2026, “The Cheapest Grid is the One We Already Paid For.”
What Should Duke Do Instead of Gas?
We wouldn’t present critiques of the IRP without actionable steps the NCUC can take to make it better. Roumpauni is clear that clean energy — like solar, batteries, and energy efficiency — can help. Jigar Shah presents a case for using the existing grid more efficiently.
“Demand-side resources, including energy efficiency, are generally insulated from the manufacturing constraints and supply chain pressures affecting large generation equipment, and can typically be deployed faster and with greater cost certainty than any supply-side resource.” -Roumpani Testimony, pg. 118
(About dynamic line rating) “Duke just shrugged their shoulders and was like, we make a lot of money on fifty-fifty equity debt ratios. Why would we do this? What’s going on? We don’t want to lead in any way, shape or form… Duke was actively badmouthing dynamic line ratings at the conference, right? And so I don’t know where this goes, but I do know that it’s not going to go well for Duke.”
~Jigar Shah, Open Circuit podcast from March 13, 2026, “Iran, energy shocks, and the case for distributed power.”
Decision by NCUC This Year
SACE’s testimony, along with the testimony of our co-intervenors and other intervenors, is a step toward informing the Commission’s decision on Duke’s IRP by the end of the year. The next major step is a hearing that starts June 9. At that hearing, Duke employees and intervenor experts will present their information and findings and Commissioners will be able to ask questions. We will continue to report out on this process as it moves toward a final decision before the end of the year.
