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

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To maximize the value and uptake of these resources,the undersigned further request that the NCUC direct Duke Energy to consult with community groups,community-based organizations,and nonprofit energy affordability groups to support the creation of new grid-edge programs and increase participation in existing ones. Community engagement in program design and implementation is essential to program success, and local governments can be valuable partners to Duke Energy in this effort. Such collaboration can enhance the efficacy, reach, and scale of existing and future projects, ultimately improving outcomes for customers and supporting the goals of the Carbon Plan. 5. Protect North Carolina communities from disproportionate cost burdens associated with new large loads through financial safeguards for existing ratepayers. Local governments share the concerns of advocates and community organizations that, if not properly allocated, infrastructure costs needed to serve new large loads could be subsidized by other customers. As discussed earlier, Duke Energy's projections of substantial near-term load growth—driven primarily by economic development projects such as data centers—form the basis of its Recommended Portfolio and subsequent action plans. Balancing this economic development with the affordability concerns of existing ratepayers is a critical priority as electricity demand increases across the state. The undersigned therefore ask that the NCUC take measures to ensure that residential and other commercial ratepayers are protected from unfairly bearing the costs of infrastructure built to support new large economic development loads. While direct ratemaking decisions fall outside the scope of CPIRP proceedings,the significant influence of new economic development load on Duke Energy's resource planning decisions makes it essential for NCUC to evaluate long-term resource decisions with fair and reasonable cost allocation in mind. Consistent with longstanding ratemaking principles, residential and other commercial customers should not be expected to pay for infrastructure that they did not cause and from which they do not benefit. The NCUC can look to other jurisdictions for approaches that promote fair cost allocation in response to rapid large-load growth. In Virginia,for example, the State Corporation Commission directed Dominion Energy to develop proposals for new cost allocation methodologies for generation and transmission costs associated with new data center construction.29 Many utilities have also adopted large load tariff structures that include consumer protections such as large exit fees, minimum contract lengths, minimum demand charges, and options for co-located generation.30 These approaches can address the unique demands of large load customers while minimizing financial risk to other ratepayers. As North Carolina faces record growth in electricity demand from data centers and other large loads, it is critical that the state's approach evolves to continue protecting ratepayers from unfair cost-shifting by incorporating industry best practices and using accurate demand forecasting. Conclusion The undersigned local governments are committed to the economic well-being, health, and resilience of our communities. Although our specific goals vary, we share a common commitment to an affordable, reliable, and clean energy system that supports the needs of all North Carolinians.The plans and actions proposed by Duke Energy have a profound influence on local governments' ability to meet our goals and targets. In particular, the significant amount of projected energy demand,the proposed short-term investments in natural gas, and the delayed retirement of coal units to meet this demand create an economically risky environment with adverse health and financial impacts on residents and businesses. Some of these risks may be mitigated through refinements to Duke Energy's planning processes and expansion of customer choice programs. 29 Virginia State Corporation Commission,Docket PUR-2025-00058(Nov.2025),HTTPS://WWW.SCC.VIRGINIA.GOV/DOCKETSEARCH/DOCS/89G601!.PDF. 30 Alyssa Perez et al.,Large energy users want power. Here's how to protect other ratepayers from the costs, RM I(Nov.2025), https://rm i.org/la rge-energy-users-wa nt-power-heres-how-to-protect-other-ratel2a)rers-from-the-costs/. 8