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11 <br /> appropriate, including utility performance incentives intended to help reduce overall <br /> consumption, peak demand, or both. <br /> Recognizing that efficiency not only reduces emissions but also saves customers money, we <br /> believe EE and DSM programs in North Carolina can provide a particularly significant benefit for <br /> low- and moderate-income (LMI) residents. High energy burdens are disproportionately <br /> shouldered by low-income, Black, and Hispanic households, and are often due to factors like <br /> insufficient insulation, poor weatherization, older appliances, and an inability to access newer <br /> energy-efficient upgrades.10 Accordingly, the development of EE programs could—and should— <br /> have significant equity impacts. The CPIRP should enable increased access to EE for low- <br /> income residents through both qualification criteria and collaboration with local governments <br /> around the state, including leveraging relationships with existing community-based <br /> organizations. <br /> Additionally, the undersigned believe that Duke Energy should achieve energy savings above <br /> and beyond 1.0% of the full annual retail load. Despite the relatively high per capita energy <br /> consumption of North Carolinians, the plan's target is significantly below the performance of <br /> many states and just barely meets the national average of states that have energy efficiency <br /> resource standards (EERS).11 <br /> The undersigned commend Duke and the NCUC's efforts to modify the cost-effectiveness test <br /> for DSM programs, develop an on-tariff financing pilot, and engage stakeholders to improve EE <br /> measures and programs through the EE/DSM Collaborative and the Low-Income Affordability <br /> Collaborative. However, Duke's Market Potential Study (MPS) underestimated cost-effective EE <br /> and DSM strategies as it failed to consider rapidly changing technologies or modified program <br /> implementations. Instead, program potential inputs are based on historical program participation <br /> data. As a result, the MPS does not find cost-effective savings available for heating, ventilation, <br /> and air conditioning (HVAC) measures, although research shows that heat pumps and heat <br /> pump water heater (HPWH) are two of the highest potential efficiency opportunities in North <br /> Carolina.12 For this reason, the undersigned local governments recommend that Duke update its <br /> analysis methods to fully value the contribution of EE programs and factor in technology <br /> advancement, critical tools like on-bill financing, enhanced marketing, and program targeting to <br /> accurately evaluate program cost-effectiveness and potential based on suggestions included in <br /> the NC Energy Regulatory Process (NERP) report and the NC Energy Efficiency Roadmap. <br /> We suggest that Duke consider new or enhanced customer engagement strategies, including <br /> increased collaboration with local governments. The undersigned believe local governments can <br /> be important partners in designing, developing, and delivering EE and DSM programs to North <br /> Carolina residents and businesses in multiple ways, such as improving local ordinances, <br /> increasing the uptake and success of utility programs through local networks and targeted <br /> outreach, and supporting low-income weatherization and urgent repair efforts. Accordingly, we <br /> 10 Drehobl,Ariel,Lauren Ross,and Roxana Ayala.2020. How High Are Household Energy Burdens?Washington, D.C.:American <br /> Council for an Energy-Efficient Economy.https://www.aceee.org/research-report/u2006. <br /> 11 According to ACEEE,North Carolina's 2021 net incremental savings(MWh)is 0.64%of 2021 retail sales,compared to a national <br /> average of 0.68%. <br /> 12 Electricity EE supply curve for single-family detached housing stock in North Carolina.Source:Wilson et al.2017. <br /> 9 <br />