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4 <br /> safeguarding public welfare,these trends underscore the urgent need for proactive measures that limit cost <br /> burdens on residents, small businesses, and public institutions. <br /> Local governments are also committed to accelerating an affordable transition to clean energy. Many have <br /> adopted near-term climate, clean energy, and resilience goals (see Appendix A), and decisions in this IRP— <br /> particularly around generation, transmission, demand side resources, and procurement options—will directly <br /> affect local governments' ability to meet climate, clean energy, and sustainability commitments, as well as the <br /> cost associated with meeting these goals. Local governments view the clean energy transition as integral to <br /> improving community resilience, reducing long-term risks, and ensuring safer and more livable conditions for <br /> residents. <br /> Given these responsibilities, local governments have carefully reviewed Duke Energy's load forecast assumptions, <br /> economic development load adjustments, and generation choices in the 2025 CPIRP.The accuracy of demand <br /> projections has significant implications for infrastructure needs that drive system costs and impact rates. Local <br /> governments appreciate Duke Energy's efforts to prepare for load growth and economic development but remain <br /> concerned that uncertainty in the forecasts and an overreliance on capital-intensive new fossil generation could <br /> lead to unnecessary cost burdens for existing customers. Ensuring transparency, methodological clarity, and <br /> prudent resource selection are essential to protecting ratepayers and maintaining an affordable and reliable grid. <br /> The undersigned view this CPIRP process as a pivotal opportunity to collaborate with Duke Energy,the NCUC, <br /> and other stakeholders to shape an energy future that remains affordable, reliable, resilient,and clean for all <br /> North Carolinians. Local governments stand ready to continue working constructively with Duke Energy to <br /> evaluate solutions, share on-the-ground insights, and ensure that planning decisions reflect both statewide <br /> objectives and the lived experiences of the communities we serve. <br /> Below is a summary of key recommendations for the NCUC, which are further elaborated throughout this letter. <br /> The undersigned recommend that the NCUC: <br /> • Call for greater transparency and explanation of Duke Energy's economic development load forecasting <br /> methodology. Duke Energy's methodology for projecting new load drives major investment decisions and <br /> long-term rate impacts. Clearer assumptions and documentation will help stakeholders evaluate system <br /> needs and protect customers from unnecessary costs. <br /> • Require Duke Energy to plan for an affordable, reliable,and resilient energy system by optimizing the <br /> existing grid and investing in cost-effective, least-risk electricity generation resources. Fossil fuel <br /> generation exposes customers to unpredictable fuel costs,while renewable resources have no fuel costs <br /> and provide long-term price stability. Strengthening the existing grid and competitively acquiring <br /> resources through all-source procurement will reduce reliance on more costly new generation and limit <br /> exposure to volatile fuel markets, supporting a least-risk system and helping maintain affordability for <br /> residents, businesses, and local governments. <br /> • Encourage Duke Energy to create viable,cost-effective clean energy procurement pathways for large <br /> customers.The resource mix proposed in the CPIRP will not enable local governments to meet their near- <br /> term clean energy and climate targets, making alternative procurement pathways essential. Current <br /> Green Source Advantage (GSA) and GSA Choice structures remain too complex, restrictive, and costly, <br /> suppressing customer uptake and underscoring the need for accessible, affordable programs that can fill <br /> the near-term gap. <br /> • Direct Duke Energy to fully value energy efficiency and demand-side resources in planning.These <br /> resources reduce peak demand, defer costly infrastructure, and enhance resilience at a lower cost than <br /> 2 <br />