Agenda 03-17-2026; 8-g - Comment Letter Addressing Duke Energy’s Proposed Carbon Plan Integrated Resource Plan (CPIRP) Submitted to the North Carolina Utilities Commission

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8 To support planning for a least-cost, least-risk system,the undersigned recommend that the NCUC pursue two strategies: 1) adopting all-source procurement processes that expand and streamline opportunities to procure renewable energy, and 2)evaluating targeted transmission and distribution upgrades that optimize existing grid assets and reduce the need for costlier new generation. There are precedents for these approaches.The Northern Indiana Public Service Company(NIPSCO)22 has incorporated all-source procurement into its resource planning, and states such as Indiana23 and Utah" now require utilities to study grid-enhancing technologies (GETS) in their integrated resource plans. Similar strategies in North Carolina could improve system efficiency and reduce costs.The NCUC could require Duke Energy to conduct an all-source procurement as part of the next CPIRP to gather real-world data to inform planning assumptions and sensitivities. Following the 2025 CPIRP,the NCUC could have Duke Energy utilize an all-source procurement with an independently run and transparent evaluation process to meet forecasted demand with least-cost solutions. For the 2025 CPIRP,the NCUC ordered Duke Energy to include a report on how GETS can be leveraged for an efficient, cost-effective system.25 Local governments commend this step but encourage the NCUC to pursue additional actions to support least-cost, least-risk planning.These could include establishing a utility working group to study advanced transmission technologies (ATTs)26, identify which solutions are best suited to the system, and evaluate how they can enable new load interconnections.The NCUC could also request that Duke Energy publish a report on transmission system efficiency and points of congestion, assessing where ATTs could cost-effectively relieve constraints. Finally,the undersigned encourage the NCUC to consider hiring an independent engineering firm to work with the utility and/or system operator to identify near-term, cost-effective ATT deployments and long-term strategies. 3. Encourage Duke Energy to create viable, cost-effective clean energy procurement pathways for large customers, including local governments, to achieve established climate and clean energy goals. The Near-Term Action Plan (NTAP) and Recommended Portfolio create significant challenges for local governments and other large customers with near-term climate and clean energy obligations.The continued operation of coal plants, coupled with the addition of new natural gas resources, increases the share of fossil fuels in North Carolina's electricity mix over the next decade. While the Recommended Portfolio is projected to meet the statutory requirement of carbon neutrality by 2050, Figure 3-14 of the CPIRP shows that meaningful, sustained emissions reductions do not begin until the late 2030s. In the meantime, annual emissions across Duke Energy's Combined Carolinas system are expected to remain flat or even rise, peaking above 55 million tons of CO2 in 2036. 22 For its 2018 IRP,The Northern Indiana Public Service Company(NIPSCO)released an all-source procurement to gather information about the lowest cost means to meet system needs.This process gave NIPSCO critical information that brought the reduced system forecast costs down$1.1 billion in its 2018 IRP relative to the 2016 IRP,which did not include an all-source procurement practice.The lowered forecasted costs were due to earlier coal plant retirements and investments in solar,storage,wind,capacity market purchases,and demand side management as these demonstrated lower cost options relative to natural gas investments. 23 Indiana law now requires all IRPs filed to study the use of at least one GET to meet demand starting in 2026 and include a description of transmission and distribution systems starting in 2030(Ind.Code Ann.§8-1-8.5-3.4). 24 As of 2025, Utah requires that utilities analyze GETS as a part of resource planning processes as well as general rate cases and transmission system addition or expansion proceedings(Utah Code Ann.§54-17-11-1101). 25 Duke Energy Carolinas LLC and Duke Energy Progress,LLC 2023 Biennial CPIRP,Commission Dkt.No. E-100,Sub 190. 26 GETs include hardware and software technologies that improve functionality of the transmission system.ATTs encompass GETS and additional technologies,such as high-performance conductors. 6