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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15 Additionally, a more efficient and predictable interconnection process is critical for North Carolina to unlock the potential of renewables and meet decarbonization goals. Currently, the substantial delays in interconnection requests and unpredictable interconnection study processes result in stalled projects and create challenges for local governments to meet our renewable energy and decarbonization goals. We urge Duke to reduce interconnection timelines, accelerate interconnection studies, and improve the transparency of the queue. 5.4. Value and encourage the development of distributed energy resources (DERs) and build community resilience through the use of DERs. Distributed energy resources (DERs)—such as on-site solar, battery energy storage, and microgrids—are of significant interest to local governments as methods for supporting energy resilience, improving grid reliability in the face of natural disasters, and reducing probabilities of outages. Microgrids powered by distributed renewables and storage that can island during grid disruption and provide emergency backup power are critical for local responses to outages, and can replace fossil fuel generators, which have historically been the default solution for backup power. Local governments provide essential services and act as the first responders when climate disasters strike, and increased DER deployment would aid our efforts to bolster local resilience and enable us to respond better during emergency situations. Although the undersigned local governments commend Duke for its pursuit of customer-sited resources and efforts to create rates that support customer-sited clean resources, the 2024 CPIRP should fully value and capture the benefits of renewables plus storage and microgrids in the plan's modeling. Nationwide, utilities are increasingly deploying microgrids to improve community resilience. For example, Pacific Gas and Electric (PG&E) commissioned its first hybrid renewable microgrid to protect high fire-threat areas.19 Green Mountain Power (GMP) plans to create new microgrids and community resilience zones as outlined in its latest Integrated Resource Plan (IRP).20 ComEd and the U.S. Department of Energy completed the final tests on ComEd's Bronzeville Community Microgrid, a neighborhood-scale microgrid. The undersigned local governments recommend Duke incorporate the resilience and GHG reduction benefits of renewably powered microgrids and other cost-effective DERs into the CPIRP and create energy resiliency programs that help local governments and communities better prepare for unexpected events. One example of such a partnership is the Pepco Resiliency Center in Washington, D.C. The project deployed community solar paired with storage, microgrid, and generator capabilities, and can provide up to three days of backup power to critical loads.21 The undersigned local governments would like to support the deployment of renewable energy plus storage, microgrids and other DER projects within our 19 Pacific Gas and Electric Company(PG&E),More Communities Now Eligible to Pursue Microgrids as a Part of PG&E's Efforts to Build a Stronger, More Resilient Electric Grid, November 2021,available at: https://www.pge.com/en_US/about-pge/media- newsroom/news-details.page?page I D=bf70f039-7f80-4e31-957d-03a4d 8e 1283c&ts=1638294656832. 20 Green Mountain Power(GMP), Green Mountain Power(GMP)2021 Integrated Resource Plan,available at https://greenmountainpower.com/wp-content/uploads/2021/1 2/2021-I ntegrated-Resource-Plan.pdf 21 Matthew Popkin,Madeline Tyson, Introducing Community Solar+:the Next Generation of Community Solar,available at https://rmi.org/i ntroducing-commun ity-solar-the-next-generation-of-comm unity-solar/ 13