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19 <br /> resources and information to take part in the decision-making process related to the <br /> development of transmission projects. We encourage Duke to incorporate equity and <br /> environmental justice considerations in the transmission planning process and ensure <br /> historically underrepresented communities are included in this process. <br /> 7. NCUC and Duke should ensure that the 2024 CPIRP builds upon the years of work <br /> stakeholders have invested into processes that led to the creation and passage of <br /> S.L. 2021-165/HB951, and that there continues to be a robust and inclusive <br /> stakeholder engagement process throughout the implementation and evaluation of <br /> this and future versions of the Carbon Plan <br /> Over the last several years, NC local governments have been actively involved in utility planning <br /> processes at the NC Utilities Commission. The City of Asheville, Buncombe County, and the <br /> City of Charlotte formally intervened in the 2020 Integrated Resource Plan proceeding (Docket <br /> No. E-100, Sub 165), a first for local governments in the state. Twelve other North Carolina local <br /> governments and elected officials submitted written comments in this same integrated resource <br /> planning docket, including many of the undersigned. Local governments were also deeply <br /> engaged in the 2022 Carbon Plan proceeding, both as stakeholders in Duke's pre-filing <br /> stakeholder process, and as formal interveners and commenters - the City of Asheville, <br /> Buncombe County, and the City of Charlotte all formally intervened, and eight other local <br /> governments submitted written comments. <br /> Local governments have also been active participants in numerous energy policy development <br /> processes at the state level. The City of Asheville, Town of Cary, City of Charlotte, City of <br /> Durham, Durham County, City of Greensboro, and City of Raleigh actively participated in the <br /> Clean Energy Plan stakeholder process in 2019, with several local governments also <br /> contributing to the carbon reduction policy design and NC Energy Regulatory Process (NERP) <br /> stakeholder processes that followed. Involvement in current state initiatives, including EO 246 <br /> and IIJA funding implementation, remain priorities of the undersigned local governments. <br /> Despite this robust engagement and interest in collaborating with Duke, the undersigned are <br /> unclear how local government feedback is being received and are concerned that the comments <br /> we have provided to date have been underutilized in developing the CPIRP. The undersigned <br /> local governments urge the NCUC to adopt a Carbon Plan that builds upon these collaborative <br /> processes and includes recommendations that were the result of the above energy policy and <br /> utility planning processes. The undersigned request that there be better integration of existing <br /> feedback from stakeholders into the 2024 CPIRP, including a record of where and how Duke <br /> and the NCUC integrate that feedback. This is a common best practice of local governments <br /> facilitating complex stakeholder engagement and planning processes. <br /> We have a history of partnering with Duke on energy programs that benefit our residents, <br /> businesses, and local government operations. We look forward to and are committed to working <br /> with Duke and the NCUC to enable the solutions outlined in this letter that we believe will <br /> accelerate a more affordable, clean, equitable, resilient, and reliable energy system. Through <br /> continued partnership, we can demonstrate to both North Carolinians and the nation what <br /> collaborative clean energy leadership looks like. <br /> 17 <br />