OTHER-2024-036-Draft CPIRP letter

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appropriate , including utility performance incentives intended to help reduce overall consumption , peak demand , or both . Recognizing that efficiency not only reduces emissions but also saves customers money , we believe EE and DSM programs in North Carolina can provide a particularly significant benefit for low- and moderate - income ( LMI ) residents . High energy burdens are disproportionately shouldered by low- income , Black , and Hispanic households , and are often due to factors like insufficient insulation , poor weatherization , older appliances , and an inability to access newer energy- efficient upgrades . 10 Accordingly , the development of EE programs could —and should — have significant equity impacts . The CPIRP should enable increased access to EE for low- income residents through both qualification criteria and collaboration with local governments around the state , including leveraging relationships with existing community- based organizations . Additionally , the undersigned believe that Duke Energy should achieve energy savings above and beyond 1 . 0 % of the full annual retail load . Despite the relatively high per capita energy i consumption of North Carolinians , the plan ' s target is significantly below the performance of many states and just barely meets the national average of states that have energy efficiency resource standards ( EERS ) . 11 I' The undersigned commend Duke and the NCUC ' s efforts to modify the cost- effectiveness test for DSM programs , develop an on -tariff financing pilot , and engage stakeholders to improve EE measures and programs through the EE/ DSM Collaborative and the Low- Income Affordability Collaborative . However , Duke ' s Market Potential Study ( MPS ) underestimated cost - effective EE and DSM strategies as it failed to consider rapidly changing technologies or modified program implementations . Instead , program potential inputs are based on historical program participation data . As a result , the MPS does not find cost-effective savings available for heating , ventilation , and air conditioning ( HVAC ) measures , although research shows that heat pumps and heat pump water heater ( HPWH ) are two of the highest potential efficiency opportunities in North Carolina . 12 For this reason , the undersigned local governments recommend that Duke update its analysis methods to fully value the contribution of EE programs and factor in technology advancement , critical tools like on - bill financing , enhanced marketing , and program targeting to accurately evaluate program cost- effectiveness and potential based on suggestions included in the NC Energy Regulatory Process ( NERP ) report and the NC Energy Efficiency Roadmap . We suggest that Duke consider new or enhanced customer engagement strategies , including increased collaboration with local governments . The undersigned believe local governments can be important partners in designing , developing , and delivering EE and DSM programs to North Carolina residents and businesses in multiple ways , such as improving local ordinances , increasing the uptake and success of utility programs through local networks and targeted outreach , and supporting low- income weatherization and urgent repair efforts . Accordingly , we 10 Drehobl , Ariel , Lauren Ross , and Roxana Ayala . 2020 . How High Are Household Energy Burdens ? Washington , D . C . : American Council for an Energy- Efficient Economy. https : //www. aceee . org/research-report/u2006 . 11 According to ACEEE , North Carolina' s 2021 net incremental savings (MWh ) is 0 . 64 % of 2021 retail sales , compared to a national average of 0 . 68 % . 12 Electricity EE supply curve for single -family detached housing stock in North Carolina . Source : Wilson et al . 2017 . 9