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3 <br /> Attachment 1 <br /> [Insert Month, Day] 2026 <br /> Ms. A. Shonta Dunston <br /> Chief Clerk <br /> North Carolina Utilities Commission <br /> 4325 Mail Service Center <br /> Raleigh, North Carolina 27699-4300 <br /> Re: Statement of Position of North Carolina Local Governments on Duke Energy's Carbon Biennial Carbon Plan <br /> and Integrated Resource Plan (CPIRP); Docket No. E-100 Sub 207 <br /> Dear Chair Brawley and Commissioners, <br /> The [insert towns, cities, and counties] (subsequently referred to as "the undersigned") respectfully submit the <br /> following comments and recommendations regarding the proposed Carbon Plan Integrated Resource Plan (CPIRP) <br /> filed by Duke Energy on October 1, 2025,to the North Carolina Utilities Commission (NCUC).These comments are <br /> the result of discussions with dozens of local governments across North Carolina as part of a collective effort to <br /> achieve an affordable and sustainable energy future for our residents. We welcome the opportunity to <br /> collaborate and further discuss any of the issues described herein. <br /> Introduction <br /> Local governments have a fundamental responsibility to protect the health and safety of residents and businesses, <br /> act as careful stewards of public funds, and represent community interests in state and regional decision making. <br /> Accordingly,the undersigned have a substantial interest in ensuring an electricity system that is affordable, <br /> reliable, resilient, and clean. Energy affordability directly affects housing stability and economic wellbeing across <br /> our communities,while reliable and resilient energy is essential for protecting public health and safety during <br /> extreme heat, extreme cold, and other climate related disruptions. Decisions made in the CPIRP will shape these <br /> outcomes for decades. <br /> Collectively,the undersigned local governments serve [insert#] million North Carolinians and are among Duke <br /> Energy's largest individual customers, consuming approximately [insert#] GWh annually for government <br /> operations. In their dual role as major energy consumers and community representatives,the undersigned have <br /> worked in partnership with Duke Energy to advance initiatives that improve energy efficiency, support distributed <br /> energy resources, and expand customer-driven clean energy procurement options. Many have also participated in <br /> prior NCUC proceedings to ensure that energy system planning reflects the needs and priorities of the <br /> communities they serve.'The undersigned appreciate Duke Energy's ongoing collaboration with local <br /> governments and value the opportunities to work together toward shared goals. <br /> At the same time, local governments are concerned about the significant energy cost increases facing North <br /> Carolinians. Between Q1 2022 and Q1 2025,the average residential electricity price in North Carolina rose by <br /> 14.6%on an inflation-adjusted basis.2 As of June 2025, nearly one in thirteen North Carolina households had past- <br /> due energy utility debt in collections. For governments committed to keeping housing affordable and <br /> ' Commission Dkt.No.E-100,Sub 165,165CS,190,190CS;Lacey Shaver et al.,Driving Climate Action through Utility Integrated Resource <br /> Plans:A North Carolina Case Study of Local Government Leadership,American Cities Climate Challenge(2022), <br /> https://cityrenewables.org/wp-content/uploads/2022/02/Driving-Climate-Action-Through-Utility-IRPs North-Carolina-Case-Study.pdf. <br /> 2 Energy Information Administration,Electricity Data Browser,https://www.eia.gov/electricity/data/browser/. <br /> 1 <br />