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14 <br /> example, Xcel Energy Colorado's record-low costs secured by its 2016-2017 all-source <br /> competitive solicitation highlights the economic benefits of this approach.17 <br /> While we recognize that the CPIRP process is not the venue for amending S.L. 2021- <br /> 165/HB951, the undersigned want to emphasize the importance of revisiting this law and the <br /> percentages allocated for utility ownership versus competitive procurement. This reassessment <br /> should be through the lens of ratepayer affordability, climate benefits outlined in the CPIRP, and <br /> grid reliability and resilience. <br /> 5.3. Increase the renewable energy procurement opportunities available to all <br /> customers, including a more efficient and predictable interconnection process. <br /> In addition, the undersigned local governments ask Duke to improve current voluntary customer <br /> programs and develop new customer solutions to meet the growing demand for renewables in a <br /> manner that meets the intent of regulatory surplus. This is essential for local governments to <br /> reach our renewable energy, climate, and equity goals. Ideally, new programs would reflect the <br /> decreasing cost of renewables by ensuring long-term savings and allowing for increased <br /> flexibility, for example, by providing various contract length options. Additionally, new customer <br /> program limits should include those based on energy consumption rather than peak demand in <br /> order to be most effective and workable for local governments and other customers that have <br /> worked hard to reduce their demand, including commercial customers, so that they can be sized <br /> to cover actual use. In addition, generating resources should be located within Duke's utility <br /> territories in North Carolina to ensure that the economic and environmental benefits of <br /> renewables flow to North Carolinians. <br /> It is critical that local governments and other customers have access to customer programs that <br /> are flexible, easy to use, and available in a timely, cost-effective manner. It is also critical to <br /> ensure that participation results in the procurement of additional zero-carbon resources above <br /> and beyond the amount set by the Carbon Plan that would have been implemented otherwise <br /> (i.e., result in additionality or regulatory surplus). Local governments have expressed interest in <br /> such programs in relevant dockets at the Commission, and are eager to partner with the utility to <br /> develop such programs that are workable for customers of multiple kinds." <br /> The undersigned local governments would like to work with and support Duke in the design and <br /> implementation of renewables programs for large energy customers to help us meet local <br /> government demand. We are also interested in collaborating to shape new legislation that would <br /> extend the benefits of these programs to others in our communities to simultaneously support <br /> our GHG reduction and equity goals, such as community solar offerings with a carve-out for LMI <br /> customers. We welcome efforts to collaborate with Duke and the Commission, including during <br /> future update cycles of the CPIRP and future dockets related to customer facing programs. <br /> 17 Xcel's ASCS returned a$0.0107/kWh bid for wind,a$0.023/kWh bid for solar,and a$0.03/kWh bid for solar-plus-storage, <br /> according to a February 2021 Xcel presentation to Michigan regulators. <br /> 18 NCUC Docket No.s E-2 Sub 1314, E-7 Sub 1289, E-2 Sub 1315,and E-7 Sub 1288;SSDN Local Government Comments on <br /> Customer Programs. <br /> 12 <br />