AUTHOR:Robert Walton@TeamWetDog
PUBLISHED: Aug. 25, 2017

Dive Brief:

Duke Energy has joined the lobbying effort against potential tariffs on imported chrystalline silicon photovoltaic solar modules, warning in a letter that higher prices could lead to a slowdown in the development of solar projects — just as the resource is approaching price parity with other forms of energy.
In May, the United States notified the World Trade Organization that it was considering imposing emergency tariffs on imported solar cells, following a request by manufacturers SolarWorld Americas and Suniva (which has filed for bankruptcy).
Duke’s warning to the U.S. International Trade Commission joins more than two dozen other companies opposed to the possible tariff. A decision on whether to proceed investigating the proposed tariff and floor-price is expected next month.
August 21, 2017

Diane V. Denton
Managing Director
Federal Policy
526 S. Church Street
Charlotte, NC 28202

Lisa R. Barton
Secretary to the Commission
U.S. International Trade Commission
500 E Street SW.
Washington, DC 20436

Re: Statement of Duke Energy Corporation to the United States International Trade Commission Investigation No.TA-201-75

Dear Secretary Barton:

Pursuant to 19 CFR § 207.26, on behalf of Duke Energy Corporation, I submit the following letter to the U.S. International Trade Commission and request the Commission consider this information in making its determinations in the above-referenced investigation.

With respect to this investigation, Duke Energy respectfully requests the Commission consider the potential adverse effects of a finding of injury for the petitioner in this investigation, and any recommendation for an associated remedy of import relief, on the delivered prices of imported Crystalline Silicon Photovoltaic (“CSPV”) modules for those industries responsible for powering the nation’s electricity sector. Duke Energy urges the Commission to
evaluate such potential impacts and avoid making a determination that will negatively disrupt the growing
and developing clean energy marketplace within our service territories and throughout the country. Such a
disruption potentially harms our customers, our company, our employees and the larger power sector as a

As the Managing Director, Federal Policy for Duke Energy, I am responsible for policy
development of all federal government actions impacting our regulated and commercial renewable energy
operations. Duke Energy is one of the largest energy providers and electricity-sector employers in the
nation, serving approximately 7.5 million retail electric customers in seven states in the Southeastern and
Midwestern regions of the country. Duke Energy has approximately 30,000 employees and operates
50,000 megawatts of electricity generation, one of the largest fleets in the nation. Additionally, our
commercial operations acquires, develops, builds and operates renewable generation throughout the
country, which includes nonregulated renewable energy and storage assets.

As a company, we have invested more than $5 billion in renewable energy, and just within the
last five years have procured and invested in approximately 800 megawatts (“MWs”) of solar generating
facilities, with more than 250 MWs located within our regulated footprint. As prices for solar have
declined, more of our large business customers like the military, larger universities and data centers are seeking to incorporate more solar energy as part of their sustainability or energy security goals.

These customers are particularly vital to the economic growth of our communities and identifying economic
solutions for them is important to enable them to focus on their core mission. Additionally, over the next
five years, we have plans to procure at least 2,500 MW of solar within our regulated jurisdictions,
including significant investments in the Carolinas and Florida particularly, where the continued growth of
renewable generation is a key tenant of state policy.

As an active market participant in this sector, Duke Energy relies on access to solar CSPV
modules at globally-competitive prices to provide cost-competitive solar power to our customers.
Competitive module pricing is critical to justify future investment to our regulators and is directly
correlated to our ability to grow our renewable portfolio for the benefit of customers and shareholders.
Over the next five years, Duke Energy plans to invest more than $1 billion in additional solar generation

Competitive module pricing has driven the robust growth of solar generation across the country,
both for our company and the power sector at large. Historically, demand for solar modules has
responded directly to its relative market price and modules typically represent 25% to 30% in the overall
installed cost of solar generating capacity. In the event that imported CSPV modules are subject to an
artificial floor price or significant import tariff as requested by the petitioners in this case, the module
market, and therefore Duke Energy’s plans to procure modules, will likely be significantly disrupted. If
such a remedial floor price or tariff is imposed, we expect that the installed cost of solar projects will
increase 30% or more and that demand for modules would contract, perhaps even precipitously. As solar
energy is just approaching parity with the traditional grid resources in a number of states, a significant
reduction in demand for new solar projects could deliver a serious blow to continuing development and
evolution of this market.

For utilities situated similarly to Duke Energy’s operating companies, which must select costcompetitive
resources (whether they be fuel-based or renewable) when determining new generation to
meet customer demand requirements, such cost increases may eliminate solar generation from its
evaluation processes entirely. In this way, the cascading impact of decreases in demand for modules and
solar facilities would ultimately harm the very domestic solar manufacturing industry the petitioner is
attempting to protect.

Duke Energy urges the Commission to consider the potential adverse effects of a mandate and
disruptive change in imported CSPV module price on the power sector. Solar power has become an
increasing important part of our generating portfolio and it is an integral element to our future plans to
serve our customers. The delivery of reliable, affordable, and increasingly clean energy relies upon
international trade policies that increase supply chain stability, not policies that destabilize it.

Respectfully submitted,
Diane V. Denton