OTHER-2024-036-Draft CPIRP letter

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k' i4 E> Y= I inclusion will align with Duke ' s environmental goals and offer substantial economic benefits to its ratepayers , promoting a sustainable and community- centric approach to energy transition . 3 . Load forecasts should be adjusted to proactively and accurately account for the impact of demand side management ( DSM ) programs and technological advances that reduce load as well as increased load that may result from transportation and building electrification . In the context of increased load forecasts , the 2024 CPIRP should account for the potential impact of improved energy efficiency programs and up -to -date building codes on Duke ' s ability to more effectively manage system load . 1 Local governments are concerned that large load increases forecasted by Duke in its revised c filings3 from January 31 , 2024 will result in an overreliance on new natural gas infrastructure , c thus making it even harder to reduce carbon emissions . Duke ' s load forecasting should account for the reduced demand resulting from DSM programs and technological advances such as increased appliance and HVAC efficiencies . The rapid electrification of transportation and buildings represents a significant tool to aid North Carolina in achieving the decarbonization goals set by S . L 2021 - 165/HB951 . As the electric vehicle ( EV) market grows and building I electrification and efficiency increases , traditional load shapes will also change . Duke should accurately analyze the impacts of electrification on the electric system , implement best practices for managing load growth , and match increased demand with clean , affordable , and reliable f generation so that EVs and energy efficient appliances (such as heat pumps ) can act as flexible assets on the grid . The CPIRP should revise the EV penetration rate proposed by Duke in its draft Plan to better reflect changing market conditions and related federal and state policies , such as Governor Cooper' s Executive Order 246 , North Carolina ' s participation in the multistate Medium . and Heavy- Duty Zero Emission Vehicle Memorandum of Understanding , and the distribution of Volkswagen Settlement Funds . 411 Accurate load forecasting can improve utility planning and load management . EV loads can and should be well utilized to manage system peaks and integrate renewable energy . Matching EV charging demand with renewable energy supplies can offer greater grid and decarbonization benefits . Through the Charge Forward pilot program run by Pacific Gas & Electric and BMW , eligible EV drivers agree to delay charging to better align with available I° renewable energy in exchange for lower charging rates . Researchers also found that smart charging can reduce carbon emissions for EVs by 32 % on average , and enable EVs to accept an additional 1 , 200 kWh of renewable energy per vehicle per year . ' Accordingly , the 3 NCUC Docket No . & 100 Sub 190 , Duke Energy's Verified Amended Petition For Approval Of 2023 -2024 Carbon Plan and Integrated Resource Plans 4 On July 15 , 2020 , Gov. Cooper joined a bi -partisan group of 15 states and the District of Columbia in signing a Memorandum of Understanding (MOU ) committing to the electrification of medium - and heavy-duty vehicles . 1 5 NC Volkswagen Settlement Program , NC Division of Air Quality . Available at https ://deq . nc . gov/about/divisions/air-quality/motor- ' vehicles-and -air-quality/volkswagen -settlement ' UC Berkeley Transportation Sustainability Research Center (TSRC ) , New TSRC Report Shows Benefits of Optimizing EV Charging, August 23 , 2020 , available at : https : //its . berkeley . edu/news/new-tsrc-report-shows -benefits-optimizing -ev-charging � . 7