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used . The inclusion of these tax credits in resource plan modeling is crucial for maximizing <br /> affordability for consumers and helping the utility meet its environmental , equity , and operational <br /> goals . <br /> However , while Duke ' s CPIRP acknowledges the significance of the IRA and IIJA with some <br /> updated cost assumptions , there is further opportunity for Duke to integrate the potential IRA <br /> savings opportunities into its resource planning . The failure to integrate the Energy <br /> Infrastructure Reinvestment ( EIR) program2 is a significant omission that is worthy of scrutiny in <br /> the CPIRP . <br /> The EIR program , established by the Inflation Reduction Act , offers up to $ 250 billion in federal <br /> loans for projects aimed at lowering the cost of the energy transition . This program provides <br /> loans at favorable rates , slightly above the Treasury rate , for terms up to 30 years , offering a <br /> financially viable route for Duke to finance its decarbonization efforts at even lower costs . The <br /> EIR can enable acceleration in the retirement of fossil infrastructure and investment in clean and <br /> low-emission resources , substantially easing the economic burden on ratepayers compared to <br /> traditional financing methods . Utilities are statutorily required to pass the savings from EIR to <br /> their customers and fossil communities impacted by the transition , making it a likely integral <br /> component for achieving North Carolina carbon reduction goals at least cost . This could take <br /> the form of community benefits plans that ensure job training and replacement with highly <br /> skilled , high paying job opportunities for workers and communities displaced by the shift away <br /> from fossil resources . Local governments have a vital role in ensuring that communities in North <br /> Carolina that have historically relied on fossil fuel - related industries benefit from the <br /> decarbonization of the power sector, but they will be stymied in those efforts if Duke misses this <br /> financing opportunity. <br /> Duke ' s current omission of EIR from the resource planning scenarios raises concerns among <br /> the undersigned local governments . In addition to the economic impact concern , this oversight <br /> has potentially hidden a more aggressive and cost- effective portfolio that meets the states <br /> emission reduction targets in a timely manner . Integration of EIR is likely a crucial component in <br /> capacity expansion modeling given that not all investments would be eligible for EIR financing . <br /> As such , the supply curve for certain technology costs is likely altered by the potential for EIR <br /> applicability , offering a lower cost of clean generation and grid investments , vital for North <br /> Carolina ' s affordable decarbonization transition . <br /> Moreover , the EIR loan authority is set to expire in September 2026 , making the 2024 CPIRP <br /> the primary planning opportunity for the Commission to evaluate the potential savings this <br /> federal funding could offer the state . The incorporation of EIR into Duke ' s carbon plan is not just <br /> beneficial but essential . It will capitalize on low- cost federal funding to foster a more cost- <br /> effective and efficient transition to cleaner energy infrastructure . We urge Duke to reassess its <br /> carbon plan and include EIR as a central component of its capacity expansion modeling . This <br /> 2 Title 17 Clean Energy Financing — Energy Infrastructure Reinvestment, see https : //www . energy. gov/lpo/energy-infrastructure- <br /> reinvestment <br /> 6 <br />