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3 . Load forecasts should be adjusted to proactively and accurately account for the impact <br /> of demand side management ( DSM ) programs and technological advances that reduce <br /> load as well as increased load that may result from transportation and building <br /> electrification . In the context of increased load forecasts , the 2024 CPIRP should <br /> account for the potential impact of improved energy efficiency programs and up -to - date <br /> building codes on the ability of Duke to more effectively manage system load . <br /> 4 . Energy efficiency and demand -side management ( DSM ) programs should be improved <br /> to help local governments and other ratepayers address affordability and climate <br /> concerns and mitigate impacts related to increased load forecasts . <br /> 5 . Duke should adopt commercially proven resource generation technologies , including <br /> low- cost renewables , and phase out fossil fuels as soon as possible using the following <br /> strategies : <br /> 5 . 1 . Retire and replace coal power plants with clean energy portfolios to improve <br /> public health outcomes and reduce ratepayer costs . <br /> 5 . 2 . Run an all -source , competitive solicitation to procure all new generation sources <br /> and determine the best replacement resources . <br /> 5 . 3 . Increase the renewable energy procurement opportunities available to all <br /> customers , including a more efficient and predictable interconnection process . <br /> 5 . 4 . Value and encourage the development of distributed energy resources ( DERs ) <br /> and build community resilience through the use of DERs . <br /> 5 . 5 . Prioritize and maximize tested technologies that are commercially viable before <br /> relying on unproven technologies that carry high risks for ratepayer dollars . <br /> 6 . Transmission planning should be conducted proactively and in conjunction with capacity <br /> expansion and jointly with neighboring grids . <br /> 7 . NCUC and Duke should ensure that the Carbon Plan builds upon the years of work <br /> stakeholders have invested into processes that led to the creation and passage of S . L . <br /> 2021 - 165/ HB951 , and that there continues to be a robust and inclusive stakeholder <br /> engagement process throughout the implementation and evaluation of this and future <br /> versions of the CPIRP . <br /> The following letter provides further detail on each of our recommendations . <br /> Recommendations <br /> 1 . All pathways in NCUC ' s final CPIRP should prioritize meeting the 2030 deadline of <br /> reducing carbon emissions by 70 % compared to 2005 levels . <br /> Local governments remain concerned that only one of the three pathways proposed by Duke in <br /> their draft CPIRP achieves the 2030 emission reduction target of 70 % below 2005 levels as <br /> legislatively mandated by the NC General Assembly ( NCGA) in S . L . 2021 - 165/HB951 . Given <br /> that local governments are constrained by the available energy generation mix at the utility <br /> level , a CPIRP that allows Duke to push the compliance date by 3 -5 years ( as proposed in <br /> Pathways 2 and 3 , respectively) would drastically reduce the ability of local governments to <br /> meet their own climate targets , many of which include milestones similar to the state ' s 70 % <br /> reduction by 2030 goal . Local governments are particularly concerned that Duke ' s preferred <br /> 4 <br />