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10 <br /> undersigned local governments recommend Duke further optimize charging behaviors and thus <br /> manage load and integrate more renewable energy sources on the grid through rate design that <br /> incentivizes off-peak charging, and explore the potential of Vehicle-to-Grid (V2G) to tap the <br /> synergies between EV charging and the operational needs of the grid in ways that maximize the <br /> benefits for all customers. <br /> Similarly, the CPIRP should better forecast and incorporate the long-term load impacts of <br /> building code improvements and the growing trend toward beneficial electrification. Updating <br /> building codes in North Carolina is a cost effective way to reduce overall energy consumption, <br /> and thus lower the overall load on the grid. The North Carolina Building Code Council found that <br /> the commercial and residential provisions of the proposed 2024 NC Energy Conservation Code <br /> (NCECC) are expected to be cost effective.' Adoption of the 2024 NCECC has the potential to <br /> realize annual energy savings of$0.23 per square foot for commercial buildings, and save the <br /> average NC household roughly $400 a year in utility bill savings.$As widespread electrification <br /> adds loads, effective demand management will mitigate system costs and aid renewables <br /> integration within a power system that increasingly relies on variable renewable energy. <br /> Accordingly, the undersigned recommend that Duke proactively enable growth of building <br /> electrification and support the integration of renewable energy, thereby addressing grid and <br /> peak load impacts. Such consideration of beneficial electrification could have a positive impact <br /> on the cost of implementing the CPIRP. <br /> 4. Energy efficiency and demand-side management (DSM) programs should be <br /> improved to help local governments and other ratepayers address affordability and <br /> climate concerns. <br /> Energy Efficiency (EE) and DSM programs are not only highly effective and cost-competitive <br /> grid resources, but can also tangibly benefit North Carolinians by lowering customer energy bills <br /> and decreasing energy burden. Many of the undersigned local governments participated in <br /> Duke's 2020 IRP docket proceedings and the 2022 Carbon Plan process, both as stakeholders <br /> in utility-led conversations, and as interveners and commenters in the dockets themselves. <br /> Local governments want to reinforce and expand upon those earlier comments in the context of <br /> the 2024 CPIRP proposed by Duke. <br /> The undersigned are concerned that Duke is not appropriately valuing the potential benefits of <br /> deeper investments in EE, especially in light of the large increase in system-wide electricity load <br /> that the utility forecasted in January.9 Implementing EE and DSM measures is a key lever that <br /> local governments can utilize to make progress towards their emissions targets, and local <br /> governments and other non-residential customers have significant opportunities to reduce <br /> electrical consumption and peak demand. Doing so provides both environmental and economic <br /> benefits to communities, including residents and businesses, and reduces system-wide <br /> generation needs. Greater EE and DSM programming should be evaluated and implemented as <br /> 'Fiscal Note for 2024 Energy Conservation Code, NC Building Code Council.December 12,2023. hftps://www.ncosfm.gov/b-21- <br /> 2024-ncecc-fiscal-note/open <br /> 8 Ibid. <br /> 9 NCUC Docket No. E-100 Sub 190, Duke Energy's Verified Amended Petition For Approval Of 2023-2024 Carbon Plan and <br /> Integrated Resource Plans <br /> 8 <br />