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5 <br /> new generation.Treating them as selectable planning resources will improve system affordability and <br /> reliability. <br /> • Protect existing ratepayers from disproportionate cost burdens associated with new large loads. Rapid <br /> growth should not result in higher bills for residents, small businesses, or public agencies already <br /> struggling with rising energy costs. Fair cost allocation—consistent with models used in other states—will <br /> help maintain affordability as the grid expands. <br /> Recommendations <br /> This letter outlines the undersigned's comments on key elements of the CPIRP filings,their impacts on local <br /> government actions and community members, and recommendations for the NCUC as it prepares its final Order <br /> in the 2025-26 CPIRP proceeding.The undersigned ask the NCUC to: <br /> 1. Ensure Duke Energy provides greater transparency and explanation of its load forecasting <br /> methodology to guide cost-effective infrastructure planning. <br /> Accurate energy demand forecasts are critical, as all resource planning decisions found in the CPIRP process rely <br /> on these projections as foundational inputs. Underestimating future demand risks reliability shortfalls,while <br /> overestimating it could leave ratepayers paying for unneeded infrastructure. <br /> North Carolina is experiencing rapid growth and is expected to become the seventh most populous state by the <br /> early 2030s.3 Its expanding economy brings new industries, investment, and jobs—benefits local governments <br /> recognize and support. Local governments also recognize that as population and productivity grow, statewide <br /> energy demand is likely to follow. <br /> However, even accounting for this growth, Duke Energy's demand projections appear to significantly <br /> overestimate the magnitude and pace of new economic development load.The Advancing Development load <br /> forecast scenario, which serves as Duke Energy's base planning assumption, projects more than 51 TWh of new <br /> economic development load by 2040, roughly equivalent to adding the current electricity consumption of <br /> Arkansas to the existing system in under 15 years.' More than 60 percent of this projected load is expected to <br /> materialize by 2031.E <br /> Duke Energy's recent presentation at an NCUC technical conference indicates that much of this projected growth <br /> is attributed to data centers.6 While data center expansion is affecting load forecasts nationwide,there are well- <br /> documented reasons for skepticism about the scale and timing of associated load growth, including efficiency <br /> 3 Michael Cline,NC to become 7tn most populated state in early 203Os,Office of State Budget and Management(Feb.2025), <br /> https://www.osbm.nc.gov/blog/2025/02/03/nc-become-7th-most-populated-state-early-2030s. <br /> 'U.S.Energy Information Administration,Electric Power Annual(Oct.2025),https://www.eia.gov/electricity/annual/(For further <br /> comparison,in its October 2025 Integrated Resource Plan Update, Dominion Energy forecasted that its net load would increase by 67 TWh <br /> by 2040 across its Virginia and North Carolina footprint. Dominion Energy serves the largest data center market in the world in Northern <br /> Virginia and is considered a utility industry leader in data center practice). <br /> 5 Appendix D—Load Forecast,Commission Dkt. No.E-100,Sub 207(2025),https://starwl.ncuc.gov/NCUC/ViewFile.aspx?ld=da8c7ac9- <br /> b1c1-4624-8fc9-2d4a8ba2febf. <br /> 6 Duke Energy's Technical Conference Presentation Materials,Commission Dkt. No.E-100,Sub 208(2025), <br /> https://starwl.ncuc.gov/NCUC/ViewFile.aspx?Id=86ae7250-53a6-4b81-ad84-a7Oed8b5c6f4(On slide 4,the rightmost chart shows that <br /> there are 39.8 GW of data center projects in Duke Energy's Carolinas Economic Development Pipeline out of a total 47 GW,representing <br /> 84.6%of projected demand from all entries in the pipeline). <br /> 3 <br />