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17 <br /> prove safe operations of any new technologies, including SMR, before investing in them at <br /> scale. In addition, to be a compelling decarbonization solution, SMRs should also demonstrate a <br /> history of reliably serving load and reliably ramping to meet peaks. <br /> Duke should prioritize and maximize investment in currently deployable solutions, such as <br /> energy efficiency, renewables, and storage, while other innovative strategies are under <br /> development and testing. The undersigned local governments encourage NCUC to include at <br /> least one pathway that doesn't rely on SMRs in the 2024 CPIRP. <br /> 6. Transmission planning should be conducted proactively and in conjunction with <br /> capacity expansion and jointly with neighboring grids. <br /> The undersigned commend Duke for their expansion and enhancement of its transmission <br /> infrastructure to facilitate interconnection of solar, which reflects a forward-thinking approach to <br /> upgrading their transmission network. Their strategy to identify and develop transmission <br /> capabilities in these 'Red Zones' is a notable effort in facilitating the integration of renewable <br /> energy. <br /> The undersigned applaud that Duke has recognized the need for and is considering introducing <br /> a multi-value transmission planning process. However, it's crucial that Duke fully integrate this <br /> approach into resource planning to harness its full potential. A multi-value approach to <br /> transmission planning is essential as it encompasses a broader range of benefits, including <br /> reliability, economic efficiency, and alignment with renewable energy policies. This approach <br /> would not only enhance the transparency and coordination of Duke's transmission planning but <br /> also ensures more informed decision-making for the Commission. By adopting this method, <br /> Duke can better anticipate and meet the evolving demands of the energy landscape, particularly <br /> in integrating renewable resources like offshore wind. This forward-looking planning is also in <br /> line with regulatory expectations and stakeholder interests, as it provides a holistic view of the <br /> transmission system's needs. <br /> Duke should evaluate and, to the greatest extent possible, quantify a wide range of pertinent <br /> benefits proposed in the Notice of Proposed Rulemaking (NOPR) that the Federal Energy <br /> Regulatory Commission (FERC) issued in 2022 to select transmission projects. It is crucial that <br /> Duke's approach not only complies with the upcoming FERC rule but also considers this set of <br /> benefits as the minimum benchmark for its future multi-value transmission plan. This approach <br /> should entail assessing a broad spectrum of potential benefits, weighing both immediate and <br /> long-term effects, and aligning them with the project's specific objectives and requirements. <br /> Some potential benefits include reliability and resource adequacy benefits, generation capacity <br /> cost savings, and market benefits. <br /> We also encourage the Commission to require Duke to extend their focus from local planning to <br /> regional and inter-regional transmission planning. We suggest adopting the proactive, multi- <br /> value transmission planning approach regionally and inter-regionally in addition to just locally <br /> within Duke's territories. Specifically, we urge Duke to increase connections between its service <br /> 15 <br />