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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.25 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.26 <br /> The undersigned local governments also recognize the significant grid benefits that energy efficiency and grid-edge <br /> resources already provide to North Carolina's electric system. We believe Duke Energy can and should do more to <br /> fully capture these benefits in its resource planning and accelerate deployment of these least cost, customer <br /> focused resources.These resources reduce peak demand, defer or avoid costly infrastructure investments, <br /> enhance system resilience, and help customers directly manage their bills. Greater reliance on energy efficiency <br /> and grid-edge technologies would materially affect Duke Energy's modeling outcomes, including system <br /> affordability, climate impacts, and reliability. Duke Energy's own Portfolio Sensitivity Analysis shows that a "high" <br /> energy efficiency scenario—assuming annual minimum energy efficiency savings equal to 1.5%of eligible <br /> load—would eliminate the need for 1,365 MW of combined cycle natural gas capacity and 428 MW of combustion <br /> turbine capacity relative to the preliminary base portfolio. <br /> Utilities are increasingly evaluating energy efficiency and grid-edge resources as modeled, selectable resources <br /> available for capacity expansion planning. For example, Duke Energy Indiana considered energy efficiency, demand <br /> response, and integrated vol-var control collectively as selectable generation assets to meet system demand in its <br /> 2024 CPIRP.27 The undersigned therefore recommended that the NCUC direct Duke Energy to model energy <br /> efficiency and certain grid-edge energy resources as selectable resources in its capacity expansion and resource <br /> adequacy modeling in future CPIRP proceedings. <br /> Grid-edge programs, including distributed energy resources, also provide critical community-level resiliency <br /> benefits as demonstrated in the aftermath of Hurricane Helene in 2024. For example,the Hot Springs <br /> microgrid—placed in service in 2023 as a more resilient and less expensive alternative to traditional grid <br /> expansion—continued providing power through solar and battery storage after the town's substation was washed <br /> away during the storm.28 <br /> 25 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 /> "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 /> Z'Duke Energy,Duke Energy Indiana Integrated Resource Plan,(2024), <br /> https://www.duke-energy.com/home/products/indiana-integrated-resource-pla n. <br /> "Jared Leader,Hurricane Helene:Hot Springs Microgrid,Smart Electric Power Alliance(Mar.2025), <br /> htt sp .//sepapower.org/resource/case-study-hurricane-helene-hot-s rings-microgrid/. <br /> 7 <br />