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7 <br /> scenario (Pathway 3) delays compliance with S.L. 2021-165/HB951 by 5 years and includes the <br /> highest levels of proposed new natural gas buildout. <br /> The undersigned local governments have a duty to responsibly and efficiently utilize taxpayer <br /> dollars to meet their sustainability, energy, and other community-driven goals. In addition to <br /> increased emissions in the near term, delays in SL2021-165/HB951 implementation result in <br /> increased costs for both local governments and utilities due to fuel price volatility, supply chain <br /> delays, inflation, and other factors. In addition to statewide carbon emissions reductions, <br /> meeting the 2030 goal would also have near-term co-benefits for public health and air quality as <br /> mentioned above. <br /> We appreciate that the 2024 CPIRP includes a pathway (Pathway 1) that would support the <br /> undersigned local governments' efforts to achieve our long-term renewable energy goals and <br /> GHG emission reduction goals, but the undersigned are concerned that Duke considers <br /> Pathway 1 to be unattainable even before the full CPIRP process has been presided over by the <br /> NCUC.' Local governments are also concerned that Pathway 1 has not been appropriately <br /> valued due to the inclusion of an arbitrary cost adder on market-tested resources like solar <br /> (without a similar analog in Pathway 2 or Pathway 3) that results in higher costs being attributed <br /> to Pathway 1. The undersigned local governments urge the Commission to adequately consider <br /> Pathway 1 without this cost increase, and hope to remain engaged partners as the NCUC <br /> determines the best ways to achieve a 70% emissions reduction by 2030 and carbon neutrality <br /> by 2050. Due to the urgency of the climate crisis and the implications to the health and well- <br /> being of the constituents we serve, it is imperative that the 2030 target be met in the timelines <br /> specified in S.L. 2021-165/HB951. <br /> 2. The biennial CPIRP should fully account for available incentives included in the <br /> Infrastructure Investment and Jobs Act (IIJA) and the Inflation Reduction Act (IRA) <br /> that have significant potential to promote the deployment of carbon free resources <br /> in a cost effective manner. <br /> Federal programs created and expanded by the Inflation Reduction Act (IRA) and the <br /> Infrastructure Investment and Jobs Act (IIJA) present significant funding opportunities that have <br /> the potential to directly benefit communities and influence utility resource assumptions and <br /> timing estimates. Duke should take advantage of these federal incentives and lower project <br /> costs, which will contribute to more affordable energy solutions for North Carolina's residents <br /> and businesses, and which will result in a more efficient and sustainable deployment of energy <br /> infrastructure. <br /> The undersigned acknowledge that Duke has integrated some of the IRA and the IIJA into their <br /> resource planning and the CPIRP. We recognize that Duke's CPIRP modeling made strategic <br /> use of the tax incentives provided by the IRA, adapting the CPIRP to include IRA criteria for <br /> base and bonus production and investment tax credits by updating the cost assumptions it <br /> 1 Duke Energy proposed CPIRP Portfolios <br /> 5 <br />