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11 <br /> development loads. While direct ratemaking decisions fall outside the scope of CPIRP proceedings,the significant <br /> influence of new economic development load on Duke Energy's resource planning decisions makes it essential for <br /> NCUC to evaluate long-term resource decisions with fair and reasonable cost allocation in mind. Consistent with <br /> longstanding ratemaking principles, residential and other commercial customers should not be expected to pay <br /> for infrastructure which they did not cause and from which they do not benefit. <br /> The NCUC can look to other jurisdictions for approaches that promote fair cost allocation in response to rapid <br /> large-load growth. In Virginia,for example,the State Corporation Commission directed Dominion Energy to <br /> develop proposals for new cost allocation methodologies for generation and transmission costs associated with <br /> new data center construction.31 Many utilities have also adopted large load tariff structures that include <br /> consumer protections such as large exit fees, minimum contract lengths, minimum demand charges, and options <br /> for co-located generation.32 These approaches can address the unique demands of large load customers while <br /> minimizing financial risk to other ratepayers. <br /> As North Carolina faces record growth in electricity demand from data centers and other large loads, it is critical <br /> that the state's approach evolves to continue protecting ratepayers from unfair cost-shifting by incorporating <br /> industry best practices and using accurate demand forecasting. <br /> Conclusion <br /> The undersigned local governments are committed to the economic wellbeing, health, and resilience of our <br /> communities. Although our specific goals vary, we share a common commitment to an affordable, reliable, and <br /> clean energy system that supports the needs of all North Carolinians.The plans and actions proposed by Duke <br /> Energy have a profound influence on local governments' ability to meet our goals and targets. In particular,the <br /> significant amount of projected energy demand,the proposed short-term investments in natural gas, and the <br /> delayed retirement of coal units to meet this demand create an economically risky environment with adverse <br /> health and financial impacts on residents and businesses. Some of these risks may be mitigated through <br /> refinements to Duke Energy's planning processes and expansion of customer choice programs. <br /> The undersigned local governments have a long history of partnering with Duke Energy on energy programs that <br /> benefit our residents, businesses, and local government operations. We remain committed to working <br /> collaboratively with Duke Energy to advance the solutions outlined above — lowering costs, reducing risk, and <br /> improving system efficiency for the benefit of our communities. <br /> Thank you for the opportunity to provide comments. If you need additional information, please contact NAME <br /> with CITY/COUNTY(email or XXX-XXX-XXXX) and HE/SHE/THEY will direct your inquiry to the appropriate local <br /> government representative. <br /> 31 Virginia State Corporation Commission,Docket PUR-2025-00058(Nov.2025), <br /> HTTPs://W W W.SCC.ViRGINIA.GOV/DOCKETSEARCH/DOCS/89G601!.PDF. <br /> 32 Alyssa Perez et al.,Large energy users want power.Here's how to protect other ratepayers from the costs, RMI(Nov.2025), <br /> https://rmi.org/la rge-energy-users-want-power-heres-how-to-protect-other-ratepayers-from-the-costs/. <br /> 9 <br />