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i <br /> i <br /> E <br /> k' <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 /> r <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 c <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 . 1 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 1 <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 /> r <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) f <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 /> c <br /> Duke Energy proposed CPIRP Portfolios E <br /> 5 <br />