OTHER-2021-004 NC Local Gov Joint Comment Letter on Duke IRP - Final

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2. Update analysis methods to fully value the contribution of energy efficiency programs that help local governments and customers address affordability and J 4 climate concerns. 75 LL The undersigned are glad to see inclusion of energy efficiency in each of the IRP scenarios. Local LIL governments work with Duke Energy on energy efficiency programs in our own facilities as well as 0 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 households 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 CD had median electricity burden at or greater than 6%. Minority groups are disproportionately shouldering c14 these high energy burdens. Recognizing that efficiency not only reduces emissions but also saves 04 customers money,we see it as a very important component of meeting our climate and equity goals. -0 0) lL 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 decision-making about those programs, which may have led to underutilized/misrepresented 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 and 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. Expand the distributed generation and utility-scale renewable energy solutions offered to help directly address our local government renewable energy, climate, and equity goals. As currently proposed in the IRP, renewable energy plays varying roles across the six IRP scenarios. The undersigned applaud scenarios C-F where both solar and wind play a more substantial role. The undersigned also note that depending on the scenario selected, additional renewable energy will be needed to meet our collective governmental and community-wide renewable energy targets, either 4