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well-documented reasons for skepticism about the scale and timing of associated load growth, including efficiency
<br /> gains, supply chain constraints, market shifts, and the prevalence of speculative and duplicative requests.' In
<br /> recent months, large load queues in other states like Georgia#and Ohio# have decreased by multiple gigawatts as
<br /> data center plans changed.
<br /> Given the scale and pace of projected economic development load additions,the undersigned urge the NCUC to
<br /> have Duke Energy provide greater transparency and explanation of its methodology for economic development
<br /> load adjustments within the CPIRP proceeding. Duke Energy should explain the basis for its chosen discount
<br /> factors, the rationale for selecting certain project stages in its scenarios, and the justification for adding
<br /> approximately 2,000 MW of demand to the Advancing Development scenario beyond the Moderate Development
<br /> case.'The 2,000 MW adjustment warrants particular scrutiny, as it lacks significant supportive evidence and
<br /> modeling and could be speculative.'
<br /> To ensure sound planning,the NCUC can draw on emerging best practices from other jurisdictions and expert
<br /> groups. For example, the Texas market operator ERCOT has developed a methodology for adjusting large load
<br /> forecasts provided by utilities using observed data center demand and operational data.10 Other utilities have
<br /> adopted advanced modeling techniques to better account for uncertainty.11 The Energy Systems Integration Group
<br /> has also recently published recommendations for forecasting emerging large loads, informed by research and
<br /> stakeholder engagement through its Large Load Task Force.12
<br /> The undersigned also request that Duke Energy be required to provide more frequent and detailed updates on
<br /> its economic development pipeline and resulting load impacts.The NCUC's 2024 Order requiring semi-annual
<br /> reporting was an important step toward transparency.13 However, given the pace of change in large load
<br /> development, particularly data centers,the undersigned believe that the initial reporting requirements are no
<br /> longer sufficient to capture and respond to changes in the large load market. Following approaches in Georgia14
<br /> and TexaS15—states also experiencing significant data center growth—the undersigned request that update reports
<br /> be filed more frequently(e.g., quarterly or monthly) and that individual large load requests be reported in a
<br /> structured dataset, including project load, queue status, and load ramp timing.
<br /> These measures will help ensure that planning decisions affecting millions of North Carolinians are evidence-based
<br /> and responsive to rapidly evolving market conditions.
<br /> 'Ian Goldsmith and Zach Byrum,Powering the US Data Center Boom:Why Forecasting Can Be So Tricky,World Resources Institute(Sep.
<br /> 2025),httr)s://www.wri.or /g insights/us-data-centers-electricity-demand;Brian Martucci,A fraction of proposed data centers will get built.
<br /> Utilities are wising up, Utility Drive(May 2025),
<br /> https://www.util itydive.com/news/a-fraction-of-proposed-data-centers-will-get-bui It-utilities-are-wising-up/748214/.
<br /> 8 2025 Carolinas Resource Plan,Chapter 2—Methodology&Key Assumptions,Commission Dkt.No.E-100(Oct.2025),
<br /> https://starwl.ncuc.gov/NCUC/ViewFile.aspx?Id=3368d947-071 c-4ed c-8414-d5006648be8d.
<br /> 9 Direct Testimony and Exhibits in Support of 2025 Carbon Plan Integrated Resource Plan,Direct Testimony Of Phillip O.Stillman,Andrew
<br /> Tate,and Benjamin Passty on behalf Of Duke Energy Carolinas,LLC and Duke Energy Progress,LLC,Commission Dkt.No. E-100,Sub 207
<br /> (2025),https://starwl.ncuc.gov/NCUC/ViewFile.aspx?Id=4386559b-8991-4e60-b693-ec4b9e689038.
<br /> "Pablo Vegas et al.,Item 8.1:Long-Term Load Forecast Update(2025-2031)and Methodology Changes,ERCOT(Apr.2025),
<br /> https://www.ercot.com/files/docs/2025/04/07/8.1-Long-Term-Load-Forecast-Update-2025-2031-a nd-Methodology-Changes.pdf.
<br /> " ViewFile.aspx
<br /> 1z John Wilson and Sophie Meyer,Forecasting for Large Loads:Current Practices and Recommendation, Energy Systems Integration Group
<br /> (Dec.2025),https://www.esig.energy/wp-content/uploads/2025/12/ESIG-Large-Loads-Forecasting-report-2025.pdf.
<br /> 13 Carolinas Resource Plan,Order Accepting Stipulation,Granting Partial Waiver of Commission Rule R8-60A(d)(4),and Providing Further
<br /> Direction for Future Planning,Commission Dkt. No. E-100,Sub 190,(November 1,2024).
<br /> 14 Order Adopting Stipulated Agreement,Attachment A,Georgia Public Service Commission Dkt. No.55378,(April 26,2024),
<br /> htti2s://psc.2a.gov/search/facts-document/?documentld=218484;see also Pablo Vegas et al.,Item 8.1:Long-Term Load Forecast Update
<br /> (2025-2031)and Methodology Changes,ERCOT(Apr.2025),
<br /> https://www.ercot.com/f'f'Jes/ cs/2025/04/07/8.1-Long-Term-Loa d-Fo recast-Update-2025-2031-and-Methodology-Changes.pdf.
<br /> "ERCOT,Questions and Answers About the Large Load Interconnection Process(2025),
<br /> https://www.ercot.com/files/docs/2025/12/24/Large-Load-Interconnection-Process-O-A.1df.
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