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<br /> gains, supply chain constraints, market shifts, and the prevalence of speculative and duplicative requests.' Recent
<br /> months have seen large load queues in other states like Georgia'and Ohio'decrease by multiple gigawatts as
<br /> data center plans changed.
<br /> Given the scale and pace of projected economic development load additions,the undersigned urge the NCUC to
<br /> have Duke Energy provide greater transparency and explanation of its methodology for economic development
<br /> load adjustments within the CPIRP proceeding. Duke Energy should explain the basis for its chosen discount
<br /> factors,the rationale for selecting certain project stages in its scenarios, and the justification for adding
<br /> approximately 2,000 MW of demand to the Advancing Development scenario beyond the Moderate Development
<br /> case.10 The 2,000 MW adjustment warrants particular scrutiny, as it lacks significant supportive evidence and
<br /> modeling and could be speculative.11
<br /> To ensure sound planning, the NCUC can draw on emerging best practices from other jurisdictions and expert
<br /> groups. For example,the Texas market operator ERCOT has developed a methodology for adjusting large load
<br /> forecasts provided by utilities using observed data center demand and operational data.12 Other utilities have
<br /> adopted advanced modeling techniques to better account for uncertainty.13 The Energy Systems Integration
<br /> Group has also recently published recommendations for forecasting emerging large loads, informed by research
<br /> and stakeholder engagement through its Large Load Task Force.14
<br /> The undersigned also requests that Duke Energy be required to provide more frequent and detailed updates on
<br /> its economic development pipeline and resulting load impacts.The NCUC's 2024 Order requiring semi-annual
<br /> reporting was an important step toward transparency.15 However,given the pace of change in large load
<br /> development, particularly data centers,the undersigned believe that the initial reporting requirements are no
<br /> 'Ian Goldsmith and Zach Byrum,Powering the US Data Center Boom:Why Forecasting Can Be So Tricky,World Resources Institute(Sep.
<br /> 2025),https://www.wri.org/insights/us-data-centers-electricity-demand;Brian Martucci,A fraction of proposed data centers will get built.
<br /> Utilities are wising up, Utility Drive(May 2025),https://www.utilitvdive.com/news/a-fraction-of-proposed-data-centers-will-get-built-
<br /> utilities-are-wising-up/748214/.
<br /> 8 Large Load Economic Development Report for Q3 2025 PD,Georgia Public Service Commission Dkt. No.55378(2025),
<br /> https://Psc.ga.gov/search/facts-document/?documentld=224615(In November 2025,Georgia Power'Q3 2025 Large Load Economic
<br /> Development Report showed a net 6 GW decrease in Georgia Power large load pipeline from the previous quarter,with 14.3 GW of
<br /> projects exiting in total).
<br /> 9 Correspondence Status of Process for Signing Up New Schedule DCT(Data Center Tariff)Customers, Public Utilities Commission of Ohio
<br /> Case No.24-0508-EL-ATA(2024),https://dis.puc.state.oh.us/CaseRecord.aspx?CaseNo=24-0508(In October 2025,it was reported that AEP
<br /> Ohio'data center pipeline had shrunk from 30 GW to 13 GW after the introduction of a new large load tariff requiring customers to pay at
<br /> least 85%of contracted demand per month);see also Skidmore,Zachary.AEP Ohio slashes data center pipeline by more than half—report.
<br /> Data Center Dynamics(Oct.2025),https://www.datacenterdynamics.com/en/news/aeP-ohio-slashes-data-center-pipeline-by-more-than-
<br /> half-report/.
<br /> 10 2025 Carolinas Resource Plan,Chapter 2—Methodology&Key Assumptions,Commission Dkt. No. E-100(Oct.2025),
<br /> https://starwl.ncuc.aov/NCUC/ViewFile.aspx?Id=3368d947-071c-4edc-8414-d500664Bbe8d.
<br /> 11 Direct Testimony and Exhibits in Support of 2025 Carbon Plan Integrated Resource Plan,Direct Testimony Of Phillip O.Stillman,Andrew
<br /> Tate,and Benjamin Passty on behalf Of Duke Energy Carolinas,LLC and Duke Energy Progress,LLC,Commission Dkt.No.E-100,Sub 207
<br /> (2025),https://starwl.ncuc.gov/NCUC/ViewFile.aspx?Id=4386559b-8991-4e60-b693-ec4b9e689038.
<br /> 12 Pablo Vegas et al.,Item 8.1:Long-Term Load Forecast Update(2025-2031)and Methodology Changes,ERCOT(Apr.2025),
<br /> https://www.ercot.com/files/docs/2025/04/07/8.1-Long-Term-Load-Forecast-U pdate-2025-2031-and-Methodology-Changes.pdf.
<br /> 13 ViewFile.aspx
<br /> 14 John Wilson and Sophie Meyer,Forecasting for Large Loads:Current Practices and Recommendation, Energy Systems Integration Group
<br /> (Dec.2025),https://www.esig.energy/wp-content/uploads/2025/12/ESIG-Large-Loads-Forecasting-report-2025.pdf.
<br /> 15 Carolinas Resource Plan,Order Accepting Stipulation,Granting Partial Waiver of Commission Rule R8-60A(d)(4),and Providing Further
<br /> Direction for Future Planning,Commission Dkt. No.E-100,Sub 190,(November 1,2024).
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