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I< <br /> prove safe operations of any new technologies , including SMR , before investing in them at <br /> r <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 /> G <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 I <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 I <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 In <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 /> !:.. <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 /> 1 <br /> 15 <br />