OTHER-2026-018-Comment Letter Addressing Duke Energy’s Proposed CPIRP

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near-term clean energy and climate targets, making alternative procurement pathways essential. Current Green Source Advantage (GSA) and GSA Choice structures remain too complex, restrictive, and costly, thereby suppressing customer uptake and underscoring the need for accessible, affordable programs to fill the near-term gap. • Direct Duke Energy to fully value energy efficiency and demand-side resources in planning.These resources reduce peak demand, defer costly infrastructure, and enhance resilience at a lower cost than new generation.Treating them as selectable planning resources will improve system affordability and reliability. • Protect existing ratepayers from disproportionate cost burdens associated with new large loads. Rapid growth should not result in higher bills for residents, small businesses, or public agencies already struggling with rising energy costs. Fair cost allocation—consistent with models used in other states—will help maintain affordability as the grid expands. Recommendations This letter outlines the undersigned's comments on key elements of the CPIRP filings,their impacts on local government actions and community members, and recommendations for the NCUC as it prepares its final Order in the 2025-26 CPIRP proceeding.The undersigned ask the NCUC to: 1. Ensure Duke Energy provides greater transparency and explanation of its load forecasting methodology to guide cost-effective infrastructure planning. Accurate energy demand forecasts are critical, as all resource planning decisions found in the CPIRP process rely on these projections as foundational inputs. Underestimating future demand risks reliability shortfalls, while overestimating it could leave ratepayers paying for unneeded infrastructure. North Carolina is experiencing rapid growth and is expected to become the seventh most populous state by the early 2030s.3 Its expanding economy brings new industries, investment, and jobs—benefits local governments recognize and support. Local governments also recognize that as population and productivity grow, statewide energy demand is likely to follow. However, even accounting for this growth, Duke Energy's demand projections appear to significantly overestimate the magnitude and pace of new economic development load. The Advancing Development load forecast scenario, which serves as Duke Energy's base planning assumption, projects more than 51 TWh of new economic development load by 2040, roughly equivalent to adding the current electricity consumption of Arkansas to the existing system in under 15 years.4 More than 60 percent of this projected load is expected to materialize by 2031.5 Duke Energy's recent presentation at an NCUC technical conference indicates that much of this projected growth is attributed to data centers.'While data center expansion is affecting load forecasts nationwide, there are 3 Michael Cline,NC to become 7`'most populated state in early 203Os,Office of State Budget and Management(Feb.2025), https://www.osbm.nc.gov/blog/2025/02/03/nc-become-7th-most-popu lated-state-early-2030s. 4 U.S.Energy Information Administration,Electric Power Annual(Oct.2025),https://www.eia.gov/electricity/annual/(For further comparison,in its October 2025 Integrated Resource Plan Update,Dominion Energy forecasted that its net load would increase by 67 TWh by 2040 across its Virginia and North Carolina footprint.Dominion Energy serves the largest data center market in the world in Northern Virginia and is considered a utility industry leader in data center practice). 6 Appendix D—Load Forecast,Commission Dkt.No.E-100,Sub 207(2025), httl2s://sta rw1.ncuc.gov/NCU C/ViewFi le.asl2x?ld=da8c7ac9-b 1c1-4624-8fc9-2d4a8ba2febf. 6 Duke Energy's Technical Conference Presentation Materials,Commission Dkt.No.E-100,Sub 208(2025), https://starwi.ncuc.gov/NCUC/ViewFile.aspx?Id=86ae7250-53a6-4b81-ad84-a7Oed8b5c6f4(On slide 4,the rightmost chart shows that there are 39.8 GW of data center projects in Duke Energy's Carolinas Economic Development Pipeline out of a total 47 GW,representing 84.6%of projected demand from all entries in the pipeline). 3