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9 <br /> Many North Carolina local governments have set clean energy or carbon reduction targets for 2030 or 2035—well <br /> before the emissions reductions anticipated in the CPIRP (Appendix A). Relying solely on Duke Energy's standard <br /> generation mix makes meeting these near-term public commitments effectively impossible.To comply with <br /> targets (some of which are legally binding) and public climate obligations, local governments need access to <br /> viable, cost-effective clean energy procurement options that deliver real additionality without excessive <br /> premiums or administrative burdens. <br /> Given the NTAP and Recommended Portfolio,the need for robust, scalable, and accessible clean energy <br /> procurement options for large customers is more urgent than ever. Programs such as Green Source Advantage <br /> (GSA) and GSA Choice have been essential tools for large customers seeking to directly support new renewable <br /> generation, demonstrating strong demand and attracting significant economic investment. However,these <br /> programs remain difficult for local governments to use due to complex processes, restrictive requirements, long <br /> timelines, and cost structures that can make participation financially or administratively prohibitive.These <br /> barriers directly suppress program uptake—an outcome misaligned with both customer demand and the Carbon <br /> Plan's intent. <br /> Accordingly,the undersigned recommend that the NCUC direct Duke Energy to establish a transparent,well- <br /> structured stakeholder engagement process dedicated to North Carolina local governments' procurement of <br /> clean energy. Local governments respectfully request that this dedicated process include clearly defined <br /> objectives,timelines, and milestones; a shared understanding of what specific program fixes or redesigns will be <br /> evaluated; greater transparency around program cost drivers; and a focus on creating procurement options that <br /> are easier, simpler, and as low-cost as possible for public entities and the residents they serve. <br /> A successful model already exists: the PowerPair stakeholder process, which local governments found valuable for <br /> its good faith collaboration, transparency, and opportunities to jointly explore technical and operational <br /> constraints. Local governments recognize they do not have full visibility into all utility and system limitations; <br /> transparent processes help all parties build mutual understanding and identify win-win solutions. <br /> 4. Direct Duke Energy to fully value the benefits of energy efficiency and demand-side resources in its <br /> resource planning. <br /> Duke Energy is a recognized leader in advancing innovative energy efficiency and grid-edge resource programs. In <br /> 2023, both Duke Energy Carolinas and Duke Energy Progress exceeded the national average for energy efficiency <br /> savings as a percentage of sales, making North Carolina the leading state in the Southeast for such savings.27 Duke <br /> Energy has also successfully implemented a suite of programs, including demand response and PowerShare for <br /> businesses, EV charging solutions through Charger Solution, on-bill financing via Improve &Save, and residential <br /> solar and battery incentives under PowerPair. Local governments have partnered with Duke Energy to develop, <br /> promote, and learn from these initiatives.The undersigned commend Duke Energy's leadership and continued <br /> efforts to integrate energy efficiency and grid-edge resources into the CPIRP consistent with prior <br /> recommendations.28 <br /> 27 Heather Pohnan,Energy Efficiency in the Southeast:Sixth Edition Report,Southern Alliance for Clean Energy(Jan.2025), <br /> https://cleanenergy.org/wp-content/uploads/Energy-Efficiency-in-the-Southeast-Sixth-Edition-January-2025.pdf(In 2023,North Carolina <br /> achieved 0.59%of retail electricity sales in energy efficiency savings,ranking first in the Southeast and placing it above the national average <br /> of 0.50%.The report notes,however,that energy efficiency programs at this point had not achieved savings seen in 2017-2019). <br /> 28 In the 2024 CPIRP proceeding,local governments advocated for Duke Energy to adjust its load forecast methodology to proactively and <br /> accurately account for impact of demand side management,improved energy efficiency programs,and transit and building electrification. <br /> Therefore,we believe Duke Energy's addition of EV adoption and behind-the-meter solar as key assumptions for its load forecast scenarios, <br /> as well as the creation and evaluation of Demand-Side Management Sensitivity Analysis Portfolios,is a positive step. <br /> 7 <br />