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they serve.'The undersigned appreciate Duke Energy's ongoing collaboration with local governments and value
<br /> the opportunities to work together toward shared goals.
<br /> At the same time, local governments are concerned about the significant increases in energy costs facing North
<br /> Carolinians. Between Q1 2022 and Q1 2025, the average residential electricity price in North Carolina rose by
<br /> 14.6%on an inflation-adjusted basis.'As of June 2025, nearly one in thirteen North Carolina households had
<br /> past-due energy utility debt in collections. For governments committed to keeping housing affordable and
<br /> safeguarding public welfare,these trends underscore the urgent need for proactive measures that limit cost
<br /> burdens on residents, small businesses, and public institutions.
<br /> Local governments are also committed to accelerating an affordable transition to clean energy. Many have
<br /> adopted near-term climate, clean energy, and resilience goals (see Appendix A), and decisions in this
<br /> IRP—particularly around generation,transmission, demand side resources, and procurement options—will directly
<br /> affect local governments' ability to meet climate, clean energy, and sustainability commitments, as well as the cost
<br /> associated with meeting these goals. Local governments view the clean energy transition as integral to improving
<br /> community resilience, reducing long-term risks, and ensuring safer and more livable conditions for residents.
<br /> Given these responsibilities, local governments have carefully reviewed Duke Energy's load forecast assumptions,
<br /> economic development load adjustments, and generation choices in the 2025 CPIRR The accuracy of demand
<br /> projections has significant implications for infrastructure needs that drive system costs and impact rates. Local
<br /> governments appreciate Duke Energy's efforts to prepare for load growth and economic development, but remain
<br /> concerned that forecast uncertainty and an overreliance on capital-intensive new fossil generation could impose
<br /> unnecessary costs on existing customers. Ensuring transparency, methodological clarity, and prudent resource
<br /> selection are essential to protecting ratepayers and maintaining an affordable and reliable grid.
<br /> The undersigned view this CPIRP process as a pivotal opportunity to collaborate with Duke Energy,the NCUC,
<br /> and other stakeholders to shape an energy future that remains affordable, reliable, resilient, and clean for all
<br /> North Carolinians. Local governments stand ready to continue working constructively with Duke Energy to
<br /> evaluate solutions, share on-the-ground insights, and ensure that planning decisions reflect both statewide
<br /> objectives and the lived experiences of the communities we serve.
<br /> Below is a summary of key recommendations for the NCUC, which are further elaborated throughout this letter.
<br /> The undersigned recommend that the NCUC:
<br /> • Call for greater transparency and explanation of Duke Energy's economic development load forecasting
<br /> methodology. Duke Energy's methodology for projecting new load drives major investment decisions and
<br /> long-term rate impacts. Clearer assumptions and documentation will help stakeholders evaluate system
<br /> needs and protect customers from unnecessary costs.
<br /> • Require Duke Energy to plan for an affordable, reliable, and resilient energy system by optimizing the
<br /> existing grid and investing in cost-effective, least-risk electricity generation resources. Fossil fuel
<br /> generation exposes customers to unpredictable fuel costs, while renewable resources have no fuel costs
<br /> and provide long-term price stability. Strengthening the existing grid and competitively acquiring resources
<br /> through all-source procurement will reduce reliance on more costly new generation and limit exposure to
<br /> volatile fuel markets, supporting a least-risk system and helping maintain affordability for residents,
<br /> businesses, and local governments.
<br /> • Encourage Duke Energy to create viable, cost-effective clean energy procurement pathways for large
<br /> customers.The resource mix proposed in the CPIRP will not enable local governments to meet their
<br /> 1 Commission Dkt.No.E-100,Sub 165,165CS,190,190CS;Lacey Shaver et al.,Driving Climate Action through Utility Integrated Resource
<br /> Plans:A North Carolina Case Study of Local Government Leadership,American Cities Climate Challenge(2022),
<br /> htt srJ .//cityrenewables.org/wl2-content/uploads/2022/02/Driving-Climate-Action-Through-Utility-IRPs_North-Carolina-Case-Study,IZ.
<br /> z Energy Information Administration,Electricity Data Browser,httl2s://www.eia.goy/electricity/data/bincreases in energy costsrowser/.
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