Agenda - 02-02-2021 Virtual Board Meeting; 8-h - Public Comment Submission to the NC Utilities Commission on Duke Energy's 2020 Integrated Resource Plan

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6 A financial tool like rate-payer backed securitization, when made available in North Carolina, can address the challenge of recovering undepreciated value of the coal plants through the low-cost refinancing of that value through the issuance of low-risk bonds backed by customers paying their utility bills. The undersigned strongly encourage Duke Energy to meet the coal retirement dates they have outlined in the "Earliest Practicable" scenario and replace any needed generation through all-source procurement with an aim towards a combination of renewables, efficiency, demand response, and storage that can provide the same services as fossil gas plants at lower costs. 2. Update analysis methods to fully value the contribution of energy efficiency programs that help local governments and customers address affordability and climate concerns. The undersigned are glad to see inclusion of energy efficiency in each of the IRP scenarios. Local governments work with Duke Energy on energy efficiency programs in our own facilities as well as promoting them in our communities. Energy burden is defined as the percentage of household income that goes toward paying electricity and/or natural gas bills. Households that spend 6%or more of their income on energy bills are considered to have a high energy burden. In 2018, 49% and 42% of household in DEP and DEC, respectively, had median energy burdens greater than 6%. When just looking at electricity bills, 31%of households in DEP territory and 26%of households in DEC territory had median electricity burden at or greater than 6%. Minority groups are disproportionately shouldering these high energy burdens.Recognizing that efficiency not only reduces emissions but also saves customers money, we see it as a very important component of meeting our climate and equity goals. In its IRP, Duke Energy uses an energy efficiency and demand side management Market Potential Study (MPS) to analyze how much energy efficiency is available as a resource in Duke's service territory. The MPS uses the 'total resource cost test' (TRC),which includes costs to participants, but not their attendant benefits, eliminating valuable energy efficiency that could provide value to the system as a whole. As part of that study,we recommend using the Utility Cost Test (UCT), which the Commission directed be used as the primary test.The TRC study also relies on historic program participation data from Duke's current suite of program delivery and marketing methods to determine customer participation levels.This limits potential by missing critical tools like on-bill financing, which Duke does not currently offer. Although the IRP details its income-qualified program offerings and the company describes it stakeholder engagement approach on the Duke website, it is not clear how or whether historically disadvantaged communities participated in decisonmaking about those programs,which may have led to underutilized/misprepresented assumptions about program use. Successful and durable low-income programs engage these communities so that programs benefit all. Going forward,we encourage Duke Energy to clearly articulate how it has engaged historically disadvantaged communities in developing its IRP, and which of their recommendations are incorporated into the plan. Our local governments encourage the Commission to review Duke Energy's assumptions in the Market Potential Study and request that Duke Energy submit updated scenarios that use a Utility Cost Test, use customer adoption models that include the full range of potential methods, including a range of financing tools. These changes would enable Duke Energy to prioritize energy efficiency as a least cost resource for the system that delivers health, comfort, and affordability benefits to our communities. 3