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10 <br /> The undersigned local governments also recognize the significant grid benefits that energy efficiency and gride- <br /> edge resources already provide to North Carolina's electric system.We believe Duke Energy can and should do <br /> more to fully capture these benefits in its resource planning and accelerate deployment of these least cost, <br /> customer focused resources.These resources reduce peak demand, defer or avoid costly infrastructure <br /> investments, enhance system resilience, and help customers directly manage their bills. Greater reliance on <br /> energy efficiency and grid-edge technologies would materially affect Duke Energy's modeling outcomes, including <br /> system affordability, climate impacts, and reliability. Duke Energy's own Portfolio Sensitivity Analysis shows that a <br /> "high" energy efficiency scenario—assuming annual minimum energy efficiency savings equal to 1.5%of eligible <br /> load—would eliminate the need for 1,365 MW of combined cycle natural gas capacity and 428 MW of combustion <br /> turbine capacity relative to the preliminary base portfolio. <br /> Utilities are increasingly evaluating energy efficiency and grid-edge resources as modeled, selectable resources <br /> available for capacity expansion planning. For example, Duke Energy Indiana considered energy efficiency, <br /> demand response, and integrated vol-var control collectively as selectable generation assets to meet system <br /> demand in its 2024 CPIRP.29 The undersigned therefore recommended that the NCUC direct Duke Energy to <br /> model energy efficiency and certain grid-edge energy resources as selectable resources in its capacity expansion <br /> and resource adequacy modeling in future CPIRP proceedings. <br /> Grid-edge programs, including distributed energy resources, also provide critical community-level resiliency <br /> benefits as demonstrated in the aftermath of Hurricane Helene in 2024. For example,the Hot Springs microgrid— <br /> placed in service in 2023 as a more resilient and less expensive alternative to traditional grid expansion— <br /> continued providing power through solar and battery storage after the town's substation was washed away <br /> during the storm.31 <br /> To maximize the value and uptake of these resources,the undersigned further request that the NCUC direct <br /> Duke Energy to consult with community groups, community-based organizations, and nonprofit energy <br /> affordability groups to support the creation of new grid-edge programs and increase participation in existing <br /> ones. Community engagement in program design and implementation is essential to program success, and local <br /> governments can be valuable partners to Duke Energy in this effort. Such collaboration can enhance the efficacy, <br /> reach, and scale of existing and future projects, ultimately improving outcomes for customers and supporting the <br /> goals of the Carbon Plan. <br /> S. Protect North Carolina communities from disproportionate cost burdens associated with new large <br /> loads through financial safeguards for existing ratepayers. <br /> Local governments share the concerns of advocates and community organizations that, if not properly allocated, <br /> infrastructure costs needed to serve new large loads could be subsidized by other customers. As discussed earlier, <br /> Duke Energy's projections of substantial near-term load growth—driven primarily by economic development <br /> projects such as data centers—form the basis of its Recommended Portfolio and subsequent action plans. <br /> Balancing this economic development with the affordability concerns of existing ratepayers is a critical priority as <br /> electricity demand increases across the state. <br /> The undersigned therefore ask that the NCUC take measures to ensure that residential and other commercial <br /> ratepayers are protected from unfairly bearing the costs of infrastructure built to support new large economic <br /> 29 Duke Energy,Duke Energy Indiana Integrated Resource Plan,(2024),https://www.duke-energy.com/home/products/indiana-integrated- <br /> resource-plan. <br /> 30 Jared Leader,Hurricane Helene:Hot Springs Microgrid,Smart Electric Power Alliance(Mar.2025),https://se pa power.org/resource/case- <br /> study-hurricane-helene-hot-springs-microgrid/. <br /> 8 <br />