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

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In conclusion,the undersigned local governments have a commitment to the health, economic wellbeing, 0 and resiliency of our communities. While our specific goals vary, we are all committed to an equitable J clean energy transition. The long-range plans proposed by Duke Energy will have a profound impact on our ability to meet these goals. Continuing to rely on fossil fuel-based electricity generation runs LL counter to our goals, is economically risky, and has adverse health impacts, especially for 1L historically disadvantaged communities. 0 In summary,the undersigned request: • Duke Energy retire coal plants as soon as possible via the "Earliest Practicable" IRP scenario to improve health and public benefits of NC communities, and to use all-source procurement for c14 CD replacement and future generation expansion. • Duke Energy submit updated scenarios that use a Utility Cost Test and use customer adoption models c14 that include the full range of potential methods, including a range of financing tools to fully value the contribution of energy efficiency programs that help local governments and customers address Li affordability and climate concerns. • The Commission consider our collective goals when reviewing the proposed IRP scenarios, and as needed, request Duke Energy expand the distributed generation and utility-scale renewable energy solutions offered to help directly address our local government renewable energy, climate, and equity goals. • Duke Energy conduct a robust technological and economic analysis of the transmission investments needed to enable more renewables in future portfolios. • Duke Energy reassess EV penetration rates and take a proactive approach to growing electrical load through transportation electrification offerings. • Duke Energy clearly articulate how it has engaged historically disadvantaged communities in developing its IRP and which of their recommendations are incorporated into the plan. The undersigned local governments have a history of partnering with Duke Energy on energy programs that benefit our residents, businesses, and local government operations. We look forward to and are committed to working with Duke Energy to enable the above solutions that we believe will accelerate a more affordable, clean, equitable, resilient, and reliable energy system. Through continued partnership, we can demonstrate to both North Carolinians and the nation what collaborative clean energy leadership looks like. Thank you for the opportunity to provide comments. If you need additional information, please contact Tobin Freid with Durham County (tfreid@dconc.gov or 919-748-1467) and she will direct your inquiry to the appropriate local government representative. 6