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6 <br /> 3. Load forecasts should be adjusted to proactively and accurately account for the impact <br /> of demand side management (DSM) programs and technological advances that reduce <br /> load as well as increased load that may result from transportation and building <br /> electrification. In the context of increased load forecasts, the 2024 CPIRP should <br /> account for the potential impact of improved energy efficiency programs and up-to-date <br /> building codes on the ability of Duke to more effectively manage system load. <br /> 4. Energy efficiency and demand-side management (DSM) programs should be improved <br /> to help local governments and other ratepayers address affordability and climate <br /> concerns and mitigate impacts related to increased load forecasts. <br /> 5. Duke should adopt commercially proven resource generation technologies, including <br /> low-cost renewables, and phase out fossil fuels as soon as possible using the following <br /> strategies: <br /> 5.1. Retire and replace coal power plants with clean energy portfolios to improve <br /> public health outcomes and reduce ratepayer costs. <br /> 5.2. Run an all-source, competitive solicitation to procure all new generation sources <br /> and determine the best replacement resources. <br /> 5.3. Increase the renewable energy procurement opportunities available to all <br /> customers, including a more efficient and predictable interconnection process. <br /> 5.4. Value and encourage the development of distributed energy resources (DERs) <br /> and build community resilience through the use of DERs. <br /> 5.5. Prioritize and maximize tested technologies that are commercially viable before <br /> relying on unproven technologies that carry high risks for ratepayer dollars. <br /> 6. Transmission planning should be conducted proactively and in conjunction with capacity <br /> expansion and jointly with neighboring grids. <br /> 7. NCUC and Duke should ensure that the Carbon Plan builds upon the years of work <br /> stakeholders have invested into processes that led to the creation and passage of S.L. <br /> 2021-165/HB951, and that there continues to be a robust and inclusive stakeholder <br /> engagement process throughout the implementation and evaluation of this and future <br /> versions of the CPIRP. <br /> The following letter provides further detail on each of our recommendations. <br /> Recommendations <br /> 1. All pathways in NCUC's final CPIRP should prioritize meeting the 2030 deadline of <br /> reducing carbon emissions by 70% compared to 2005 levels. <br /> Local governments remain concerned that only one of the three pathways proposed by Duke in <br /> their draft CPIRP achieves the 2030 emission reduction target of 70% below 2005 levels as <br /> legislatively mandated by the NC General Assembly (NCGA) in S.L. 2021-165/HB951. Given <br /> that local governments are constrained by the available energy generation mix at the utility <br /> level, a CPIRP that allows Duke to push the compliance date by 3-5 years (as proposed in <br /> Pathways 2 and 3, respectively) would drastically reduce the ability of local governments to <br /> meet their own climate targets, many of which include milestones similar to the state's 70% <br /> reduction by 2030 goal. Local governments are particularly concerned that Duke's preferred <br /> 4 <br />