Agenda 05-21-24; 8-f - Comment Letter Addressing Duke Energy’s Proposed Carbon Plan Integrated Resource Plan Submitted to the North Carolina Utilities Commission

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7 scenario (Pathway 3) delays compliance with S.L. 2021-165/HB951 by 5 years and includes the highest levels of proposed new natural gas buildout. The undersigned local governments have a duty to responsibly and efficiently utilize taxpayer dollars to meet their sustainability, energy, and other community-driven goals. In addition to increased emissions in the near term, delays in SL2021-165/HB951 implementation result in increased costs for both local governments and utilities due to fuel price volatility, supply chain delays, inflation, and other factors. In addition to statewide carbon emissions reductions, meeting the 2030 goal would also have near-term co-benefits for public health and air quality as mentioned above. We appreciate that the 2024 CPIRP includes a pathway (Pathway 1) that would support the undersigned local governments' efforts to achieve our long-term renewable energy goals and GHG emission reduction goals, but the undersigned are concerned that Duke considers Pathway 1 to be unattainable even before the full CPIRP process has been presided over by the NCUC.' Local governments are also concerned that Pathway 1 has not been appropriately valued due to the inclusion of an arbitrary cost adder on market-tested resources like solar (without a similar analog in Pathway 2 or Pathway 3) that results in higher costs being attributed to Pathway 1. The undersigned local governments urge the Commission to adequately consider Pathway 1 without this cost increase, and hope to remain engaged partners as the NCUC determines the best ways to achieve a 70% emissions reduction by 2030 and carbon neutrality by 2050. Due to the urgency of the climate crisis and the implications to the health and well- being of the constituents we serve, it is imperative that the 2030 target be met in the timelines specified in S.L. 2021-165/HB951. 2. The biennial CPIRP should fully account for available incentives included in the Infrastructure Investment and Jobs Act (IIJA) and the Inflation Reduction Act (IRA) that have significant potential to promote the deployment of carbon free resources in a cost effective manner. Federal programs created and expanded by the Inflation Reduction Act (IRA) and the Infrastructure Investment and Jobs Act (IIJA) present significant funding opportunities that have the potential to directly benefit communities and influence utility resource assumptions and timing estimates. Duke should take advantage of these federal incentives and lower project costs, which will contribute to more affordable energy solutions for North Carolina's residents and businesses, and which will result in a more efficient and sustainable deployment of energy infrastructure. The undersigned acknowledge that Duke has integrated some of the IRA and the IIJA into their resource planning and the CPIRP. We recognize that Duke's CPIRP modeling made strategic use of the tax incentives provided by the IRA, adapting the CPIRP to include IRA criteria for base and bonus production and investment tax credits by updating the cost assumptions it 1 Duke Energy proposed CPIRP Portfolios 5