HomeMy WebLinkAboutOTHER-2026-018-Comment Letter Addressing Duke Energy’s Proposed CPIRP n
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March 27, 2026
Ms. A. Shonta Dunston
Chief Clerk
North Carolina Utilities Commission
4325 Mail Service Center
Raleigh, North Carolina 27699-4300
Re:Statement of Position of North Carolina Local Governments on Duke Energy's Carbon Biennial Carbon Plan
and Integrated Resource Plan (CPIRP); Docket No. E-100 Sub 207
Dear Chair Brawley and Commissioners,
The Town of Boone,Town of Carrboro,Town of Cary,Town of Chapel Hill, Chatham County,Town of Davidson, City
of Durham, Durham County,Town of Hillsborough, Mecklenburg County, Orange County, City of Raleigh, and City
of Wilmington (subsequently referred to as "the undersigned") respectfully submit the following comments and
recommendations regarding the proposed Carbon Plan Integrated Resource Plan (CPIRP)filed by Duke Energy on
October 1, 2025,to the North Carolina Utilities Commission (NCUC).These comments are the result of discussions
with dozens of local governments across North Carolina as part of a collective effort to achieve an affordable and
sustainable energy future for our residents. We welcome the opportunity to collaborate and further discuss any of
the issues described herein.
Introduction
Local governments have a fundamental responsibility to protect the health and safety of residents and businesses,
act as careful stewards of public funds, and represent community interests in state and regional decision-making.
Accordingly, the undersigned have a substantial interest in ensuring an electricity system that is affordable,
reliable, resilient, and clean. Energy affordability directly affects housing stability and economic well-being across
our communities, while reliable and resilient energy is essential for protecting public health and safety during
extreme heat, extreme cold, and other climate related disruptions. Decisions made in the CPIRP will shape these
outcomes for decades.
Collectively,the undersigned local governments serve over 2.5 million North Carolinians and are among Duke
Energy's largest individual customers, consuming approximately 650 GWh annually for government operations. In
their dual role as major energy consumers and community representatives,the undersigned have worked in
partnership with Duke Energy to advance initiatives that improve energy efficiency, support distributed energy
resources, and expand customer-driven clean energy procurement options. Many have also participated in prior
NCUC proceedings to ensure that energy system planning reflects the needs and priorities of the communities
1
they serve.'The undersigned appreciate Duke Energy's ongoing collaboration with local governments and value
the opportunities to work together toward shared goals.
At the same time, local governments are concerned about the significant increases in energy costs facing North
Carolinians. Between Q1 2022 and Q1 2025, the average residential electricity price in North Carolina rose by
14.6%on an inflation-adjusted basis.'As of June 2025, nearly one in thirteen North Carolina households had
past-due energy utility debt in collections. For governments committed to keeping housing affordable and
safeguarding public welfare,these trends underscore the urgent need for proactive measures that limit cost
burdens on residents, small businesses, and public institutions.
Local governments are also committed to accelerating an affordable transition to clean energy. Many have
adopted near-term climate, clean energy, and resilience goals (see Appendix A), and decisions in this
IRP—particularly around generation,transmission, demand side resources, and procurement options—will directly
affect local governments' ability to meet climate, clean energy, and sustainability commitments, as well as the cost
associated with meeting these goals. Local governments view the clean energy transition as integral to improving
community resilience, reducing long-term risks, and ensuring safer and more livable conditions for residents.
Given these responsibilities, local governments have carefully reviewed Duke Energy's load forecast assumptions,
economic development load adjustments, and generation choices in the 2025 CPIRR The accuracy of demand
projections has significant implications for infrastructure needs that drive system costs and impact rates. Local
governments appreciate Duke Energy's efforts to prepare for load growth and economic development, but remain
concerned that forecast uncertainty and an overreliance on capital-intensive new fossil generation could impose
unnecessary costs on existing customers. Ensuring transparency, methodological clarity, and prudent resource
selection are essential to protecting ratepayers and maintaining an affordable and reliable grid.
The undersigned view this CPIRP process as a pivotal opportunity to collaborate with Duke Energy,the NCUC,
and other stakeholders to shape an energy future that remains affordable, reliable, resilient, and clean for all
North Carolinians. Local governments stand ready to continue working constructively with Duke Energy to
evaluate solutions, share on-the-ground insights, and ensure that planning decisions reflect both statewide
objectives and the lived experiences of the communities we serve.
Below is a summary of key recommendations for the NCUC, which are further elaborated throughout this letter.
The undersigned recommend that the NCUC:
• Call for greater transparency and explanation of Duke Energy's economic development load forecasting
methodology. Duke Energy's methodology for projecting new load drives major investment decisions and
long-term rate impacts. Clearer assumptions and documentation will help stakeholders evaluate system
needs and protect customers from unnecessary costs.
• Require Duke Energy to plan for an affordable, reliable, and resilient energy system by optimizing the
existing grid and investing in cost-effective, least-risk electricity generation resources. Fossil fuel
generation exposes customers to unpredictable fuel costs, while renewable resources have no fuel costs
and provide long-term price stability. Strengthening the existing grid and competitively acquiring resources
through all-source procurement will reduce reliance on more costly new generation and limit exposure to
volatile fuel markets, supporting a least-risk system and helping maintain affordability for residents,
businesses, and local governments.
• Encourage Duke Energy to create viable, cost-effective clean energy procurement pathways for large
customers.The resource mix proposed in the CPIRP will not enable local governments to meet their
1 Commission Dkt.No.E-100,Sub 165,165CS,190,190CS;Lacey Shaver et al.,Driving Climate Action through Utility Integrated Resource
Plans:A North Carolina Case Study of Local Government Leadership,American Cities Climate Challenge(2022),
htt srJ .//cityrenewables.org/wl2-content/uploads/2022/02/Driving-Climate-Action-Through-Utility-IRPs_North-Carolina-Case-Study,IZ.
z Energy Information Administration,Electricity Data Browser,httl2s://www.eia.goy/electricity/data/bincreases in energy costsrowser/.
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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).
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well-documented reasons for skepticism about the scale and timing of associated load growth, including efficiency
gains, supply chain constraints, market shifts, and the prevalence of speculative and duplicative requests.' In
recent months, large load queues in other states like Georgia#and Ohio# have decreased by multiple gigawatts as
data center plans changed.
Given the scale and pace of projected economic development load additions,the undersigned urge the NCUC to
have Duke Energy provide greater transparency and explanation of its methodology for economic development
load adjustments within the CPIRP proceeding. Duke Energy should explain the basis for its chosen discount
factors, the rationale for selecting certain project stages in its scenarios, and the justification for adding
approximately 2,000 MW of demand to the Advancing Development scenario beyond the Moderate Development
case.'The 2,000 MW adjustment warrants particular scrutiny, as it lacks significant supportive evidence and
modeling and could be speculative.'
To ensure sound planning,the NCUC can draw on emerging best practices from other jurisdictions and expert
groups. For example, the Texas market operator ERCOT has developed a methodology for adjusting large load
forecasts provided by utilities using observed data center demand and operational data.10 Other utilities have
adopted advanced modeling techniques to better account for uncertainty.11 The Energy Systems Integration Group
has also recently published recommendations for forecasting emerging large loads, informed by research and
stakeholder engagement through its Large Load Task Force.12
The undersigned also request that Duke Energy be required to provide more frequent and detailed updates on
its economic development pipeline and resulting load impacts.The NCUC's 2024 Order requiring semi-annual
reporting was an important step toward transparency.13 However, given the pace of change in large load
development, particularly data centers,the undersigned believe that the initial reporting requirements are no
longer sufficient to capture and respond to changes in the large load market. Following approaches in Georgia14
and TexaS15—states also experiencing significant data center growth—the undersigned request that update reports
be filed more frequently(e.g., quarterly or monthly) and that individual large load requests be reported in a
structured dataset, including project load, queue status, and load ramp timing.
These measures will help ensure that planning decisions affecting millions of North Carolinians are evidence-based
and responsive to rapidly evolving market conditions.
'Ian Goldsmith and Zach Byrum,Powering the US Data Center Boom:Why Forecasting Can Be So Tricky,World Resources Institute(Sep.
2025),httr)s://www.wri.or /g insights/us-data-centers-electricity-demand;Brian Martucci,A fraction of proposed data centers will get built.
Utilities are wising up, Utility Drive(May 2025),
https://www.util itydive.com/news/a-fraction-of-proposed-data-centers-will-get-bui It-utilities-are-wising-up/748214/.
8 2025 Carolinas Resource Plan,Chapter 2—Methodology&Key Assumptions,Commission Dkt.No.E-100(Oct.2025),
https://starwl.ncuc.gov/NCUC/ViewFile.aspx?Id=3368d947-071 c-4ed c-8414-d5006648be8d.
9 Direct Testimony and Exhibits in Support of 2025 Carbon Plan Integrated Resource Plan,Direct Testimony Of Phillip O.Stillman,Andrew
Tate,and Benjamin Passty on behalf Of Duke Energy Carolinas,LLC and Duke Energy Progress,LLC,Commission Dkt.No. E-100,Sub 207
(2025),https://starwl.ncuc.gov/NCUC/ViewFile.aspx?Id=4386559b-8991-4e60-b693-ec4b9e689038.
"Pablo Vegas et al.,Item 8.1:Long-Term Load Forecast Update(2025-2031)and Methodology Changes,ERCOT(Apr.2025),
https://www.ercot.com/files/docs/2025/04/07/8.1-Long-Term-Load-Forecast-Update-2025-2031-a nd-Methodology-Changes.pdf.
" ViewFile.aspx
1z John Wilson and Sophie Meyer,Forecasting for Large Loads:Current Practices and Recommendation, Energy Systems Integration Group
(Dec.2025),https://www.esig.energy/wp-content/uploads/2025/12/ESIG-Large-Loads-Forecasting-report-2025.pdf.
13 Carolinas Resource Plan,Order Accepting Stipulation,Granting Partial Waiver of Commission Rule R8-60A(d)(4),and Providing Further
Direction for Future Planning,Commission Dkt. No. E-100,Sub 190,(November 1,2024).
14 Order Adopting Stipulated Agreement,Attachment A,Georgia Public Service Commission Dkt. No.55378,(April 26,2024),
htti2s://psc.2a.gov/search/facts-document/?documentld=218484;see also Pablo Vegas et al.,Item 8.1:Long-Term Load Forecast Update
(2025-2031)and Methodology Changes,ERCOT(Apr.2025),
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.
"ERCOT,Questions and Answers About the Large Load Interconnection Process(2025),
https://www.ercot.com/files/docs/2025/12/24/Large-Load-Interconnection-Process-O-A.1df.
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2. Require Duke Energy to plan for an affordable, reliable, and resilient energy system by optimizing
the existing grid and investing in cost-effective, least-risk electricity generation resources.
Duke Energy's Recommended Portfolio reflects North Carolina's projected economic growth by adding new
resources to maintain reliable service.The undersigned commend Duke Energy's commitment to procure
thousands of additional megawatts of solar, energy storage, and hybrid projects, recognizing these technologies as
essential components of a low-cost, reliable energy system. Investments in clean energy generation also create
jobs and support customer choices for electricity generation; in 2025, North Carolina ranked ninth in the country
for clean energy employment, supporting over 113,000 workers.16
However, Duke Energy's plans to meet near-term needs by adding natural gas generation, delaying coal
retirements, and relying on indeterminate plans for nuclear, while minimizing proven technologies like wind, pose
significant economic and resilience risks for both the utility and consumers. Natural gas prices are highly volatile,
leaving consumers vulnerable to rate increases as fuel costs fluctuate. Greater reliance on natural gas, as reflected
in the Recommended Portfolios', exposes substantial price risk.This risk is validated by historical data:from 2017
to Q12024, approximately 46-68%of the increase in the residential retail volumetric rate stemmed from fuel
costs,which coincided with high natural gas prices.18
Additionally, delaying coal plant retirements prolongs negative impacts to air quality and public health and
introduces further economic volatility for consumers.19 Duke Energy's CPIRP analysis acknowledges that coal
generation faces growing uncertainty due to declining domestic coal production,transportation challenges, aging
units, and an unclear regulatory outlook.These risks raise concerns about both grid reliability and long-term
system costs, and local governments are concerned that prolonging coal operations could shift these financial
burdens onto North Carolina ratepayers. Near-term investments in natural gas, paired with delayed coal
retirements,further heighten exposure to fuel price volatility and system risk, making energy prices more
unpredictable and potentially increasing bills for residents, small businesses, and low-income households.
To support planning for a least-cost, least-risk system,the undersigned recommend that the NCUC pursue two
strategies: 1) adopting all-source procurement processes that expand and streamline opportunities to procure
renewable energy,and 2)evaluating targeted transmission and distribution upgrades that optimize existing grid
assets and reduce the need for costlier new generation.
There are precedents for these approaches.The Northern Indiana Public Service Company(NIPSCO)20 has
incorporated all-source procurement into its resource planning, and states such as Indiana21 and Utah" now
require utilities to study grid-enhancing technologies (GETs) in their integrated resource plans. Similar strategies in
North Carolina could improve system efficiency and reduce costs.The NCUC could require Duke Energy to conduct
an all-source procurement as part of the next CPIRP to gather real-world data to inform planning assumptions and
16 E2,Clean Jobs North Carolina 2025,(Nov.2025),
httl2s://www.energync.org/wp-content/uploads/2025/11/E2-Clean-Jobs-North-Carolina-2025.1df.
"The Recommended Portfolio over the Base Planning Period(through 2040)includes a net added 3,083 MW of nameplate capacity from
combustion turbines and 7,900 MW of nameplate capacity from combined cycles.
18 EQ Research LLC,Issue Brief:The Role of Fuel Costs in Duke Energy's North Carolina's Retail Rates from 2017 through March 2024,(Apr.
2024),https://www.edf.org/sites/default/files/documents/Issue Brief Narrative 4 22 24.pdf.
19 The Optimal Coal Unit Retirements in the 2025 CPIRP(Table F-2)suggest delaying retirements of Belews Creek 1, Belews Creek 2, Marshall
3,Marshall 4,and Roxboro 2 plants.
20 For its 2018 IRP,The Northern Indiana Public Service Company(NIPSCO)released an all-source procurement to gather information about
the lowest cost means to meet system needs.This process gave NIPSCO critical information that brought the reduced system forecast costs
down$1.1 billion in its 2018 IRP relative to the 2016 IRP,which did not include an all-source procurement practice.The lowered forecasted
costs were due to earlier coal plant retirements and investments in solar,storage,wind,capacity market purchases,and demand side
management as these demonstrated lower cost options relative to natural gas investments.
21 Indiana law now requires all IRPs filed to study the use of at least one GET to meet demand starting in 2026 and include a description of
transmission and distribution systems starting in 2030(Ind.Code Ann.§8-1-8.5-3.4).
22 As of 2025,Utah requires that utilities analyze GETs as a part of resource planning processes as well as general rate cases and
transmission system addition or expansion proceedings(Utah Code Ann.§54-17-11-1101).
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sensitivities. Following the 2025 CPIRP,the NCUC could have Duke Energy utilize an all-source procurement with
an independently run and transparent evaluation process to meet forecasted demand with least-cost solutions.
For the 2025 CPIRP,the NCUC ordered Duke Energy to include a report on how GETS can be leveraged for an
efficient, cost-effective system.23 Local governments commend this step but encourage the NCUC to pursue
additional actions to support least-cost, least-risk planning.These could include establishing a utility working
group to study advanced transmission technologies (ATTs)24, identify which solutions are best suited to the system,
and evaluate how they can enable new load interconnections.The NCUC could also request that Duke Energy
publish a report on transmission system efficiency and points of congestion, assessing where ATTs could
cost-effectively relieve constraints. Finally,the undersigned encourage the NCUC to consider hiring an independent
engineering firm to work with the utility and/or system operator to identify near-term, cost-effective ATT
deployments and long-term strategies.
3. Encourage Duke Energy to create viable, cost-effective clean energy procurement pathways for large
customers, including local governments, to achieve established climate and clean energy goals.
The Near-Term Action Plan (NTAP) and Recommended Portfolio create significant challenges for local governments
and other large customers with near-term climate and clean energy obligations.The continued operation of coal
plants, coupled with the addition of new natural gas resources, increases the share of fossil fuels in North
Carolina's electricity mix over the next decade. While the Recommended Portfolio is projected to meet the
statutory requirement of carbon neutrality by 2050, Figure 3-14 of the CPIRP shows that meaningful, sustained
emissions reductions do not begin until the late 2030s. In the meantime, annual emissions across Duke Energy's
Combined Carolinas system are expected to remain flat or even rise, peaking above 55 million tons of CO2 in 2036.
Many North Carolina local governments have set clean energy or carbon reduction targets for 2030 or 2035—well
before the emissions reductions anticipated in the CPIRP (Appendix A). Relying solely on Duke Energy's standard
generation mix makes meeting these near-term public commitments effectively impossible.To comply with targets
(some of which are legally binding) and public climate obligations, local governments need access to viable,
cost-effective clean energy procurement options that deliver real additionality without excessive premiums or
administrative burdens.
Given the NTAP and Recommended Portfolio,the need for robust, scalable, and accessible clean energy
procurement options for large customers is more urgent than ever. Programs such as Green Source Advantage
(GSA) and GSA Choice have been essential tools for large customers seeking to directly support new renewable
generation, demonstrating strong demand and attracting significant economic investment. However,these
programs remain difficult for local governments to use due to complex processes, restrictive requirements, long
timelines, and cost structures that can make participation financially or administratively prohibitive.These barriers
directly suppress program uptake—an outcome misaligned with both customer demand and the Carbon Plan's
intent.
Accordingly,the undersigned recommend that the NCUC direct Duke Energy to establish a transparent,
well-structured stakeholder engagement process dedicated to North Carolina local governments' procurement
of clean energy. Local governments respectfully request that this dedicated process include clearly defined
objectives,timelines, and milestones; a shared understanding of what specific program fixes or redesigns will be
evaluated; greater transparency around program cost drivers; and a focus on creating procurement options that
are easier, simpler, and as low-cost as possible for public entities and the residents they serve.
A successful model already exists: the PowerPair stakeholder process, which local governments found valuable for
its good faith collaboration,transparency, and opportunities to jointly explore technical and operational
23 Duke Energy Carolinas LLC and Duke Energy Progress,LLC 2023 Biennial CPIRP,Commission Dkt.No.E-100,Sub 190.
14 GETs include hardware and software technologies that improve functionality of the transmission system.ATTs encompass GETS and
additional technologies,such as high-performance conductors.
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constraints. Local governments recognize they do not have full visibility into all utility and system limitations;
transparent processes help all parties build mutual understanding and identify win-win solutions.
4. Direct Duke Energy to fully value the benefits of energy efficiency and demand-side resources in its
resource planning.
Duke Energy is a recognized leader in advancing innovative energy efficiency and grid-edge resource programs. In
2023, both Duke Energy Carolinas and Duke Energy Progress exceeded the national average for energy efficiency
savings as a percentage of sales, making North Carolina the leading state in the Southeast for such savings.25 Duke
Energy has also successfully implemented a suite of programs, including demand response and PowerShare for
businesses, EV charging solutions through Charger Solution, on-bill financing via Improve&Save, and residential
solar and battery incentives under PowerPair. Local governments have partnered with Duke Energy to develop,
promote, and learn from these initiatives.The undersigned commend Duke Energy's leadership and continued
efforts to integrate energy efficiency and grid-edge resources into the CPIRP consistent with prior
recommendationS.26
The undersigned local governments also recognize the significant grid benefits that energy efficiency and grid-edge
resources already provide to North Carolina's electric system. We believe Duke Energy can and should do more to
fully capture these benefits in its resource planning and accelerate deployment of these least cost, customer
focused resources.These resources reduce peak demand, defer or avoid costly infrastructure investments,
enhance system resilience, and help customers directly manage their bills. Greater reliance on energy efficiency
and grid-edge technologies would materially affect Duke Energy's modeling outcomes, including system
affordability, climate impacts, and reliability. Duke Energy's own Portfolio Sensitivity Analysis shows that a "high"
energy efficiency scenario—assuming annual minimum energy efficiency savings equal to 1.5%of eligible
load—would eliminate the need for 1,365 MW of combined cycle natural gas capacity and 428 MW of combustion
turbine capacity relative to the preliminary base portfolio.
Utilities are increasingly evaluating energy efficiency and grid-edge resources as modeled, selectable resources
available for capacity expansion planning. For example, Duke Energy Indiana considered energy efficiency, demand
response, and integrated vol-var control collectively as selectable generation assets to meet system demand in its
2024 CPIRP.27 The undersigned therefore recommended that the NCUC direct Duke Energy to model energy
efficiency and certain grid-edge energy resources as selectable resources in its capacity expansion and resource
adequacy modeling in future CPIRP proceedings.
Grid-edge programs, including distributed energy resources, also provide critical community-level resiliency
benefits as demonstrated in the aftermath of Hurricane Helene in 2024. For example,the Hot Springs
microgrid—placed in service in 2023 as a more resilient and less expensive alternative to traditional grid
expansion—continued providing power through solar and battery storage after the town's substation was washed
away during the storm.28
25 Heather Pohnan,Energy Efficiency in the Southeast:Sixth Edition Report,Southern Alliance for Clean Energy(Jan.2025),
https://cleanenergy.org/wp-content/uploads/Energy-Efficiency-in-the-Southeast-Sixth-Edition-January-2025.pdf(In 2023,North Carolina
achieved 0.59%of retail electricity sales in energy efficiency savings,ranking first in the Southeast and placing it above the national average
of 0.50%.The report notes,however,that energy efficiency programs at this point had not achieved savings seen in 2017-2019).
"In the 2024 CPIRP proceeding,local governments advocated for Duke Energy to adjust its load forecast methodology to proactively and
accurately account for impact of demand side management,improved energy efficiency programs,and transit and building electrification.
Therefore,we believe Duke Energy's addition of EV adoption and behind-the-meter solar as key assumptions for its load forecast scenarios,
as well as the creation and evaluation of Demand-Side Management Sensitivity Analysis Portfolios,is a positive step.
Z'Duke Energy,Duke Energy Indiana Integrated Resource Plan,(2024),
https://www.duke-energy.com/home/products/indiana-integrated-resource-pla n.
"Jared Leader,Hurricane Helene:Hot Springs Microgrid,Smart Electric Power Alliance(Mar.2025),
htt sp .//sepapower.org/resource/case-study-hurricane-helene-hot-s rings-microgrid/.
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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/.
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The undersigned local governments have a long history of partnering with Duke Energy on energy programs that
benefit our residents, businesses, and local government operations. We remain committed to working
collaboratively with Duke Energy to advance the solutions outlined above — lowering costs, reducing risk, and
improving system efficiency for the benefit of our communities.
Thank you for the opportunity to provide comments. If you need additional information, please contact Tobin
Freid with Durham County (tfreid@dconc.gov or 919-560-7999), and she will direct your inquiry to the appropriate
local government representative.
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CPIRP North Carolina Local Governments Joint Comment Letter Signature Page
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Dale Presnell,Interim Town Manager Barbara M.Foushee,Mayor
Town of Boone Town of Carrboro
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Harold Weinbrecht,Mayor Jessica Anderson,Mayor
Town of Cary Town of Chapel Hill
Amanda Robertson,Chair James E.Justice,Town Manager
Chatham County Board of Commissioners Town of Davidson
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Eeonardo Williams,Mayor Dr.Mike Lee,Chair
City of Durham Durham County Board of Commissioners
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Mark Bell,Mayor Michael Bryant,County Manager
Town of Hillsborough Mecklenburg County
Jean Hamilton,Chair Janet Cowell,Mayor
Orange County Board of Commissioners City of Raleigh
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Bill Saffo,Mayor
City of Wilmington
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Appendix A: Clean Energy and GHG Reduction Targets of North Carolina Local Governments
The clean energy and GHG reduction targets of the undersigned local governments include:
Local Clean energy and GHG reduction targets
Government
Town of Boone In the spring of 2023, Boone passed a Community Climate Action Plan (CCAP).
The CCAP goals include reducing Boone's municipal GHG emissions by 74%and
reducing the community's GHG emissions by 54% by 2030. As of February
2022, Boone has reduced its municipal GHG emissions by 50% by purchasing all
the electricity for municipal operations from 100% renewable sources.
Town of Adopted its Community Climate Action Plan in 2017, aiming to reduce
Carrboro community-wide greenhouse gas emissions by 80%from a 2010 baseline by
2030.
Town of Cary Adopted in spring 2025, Cary's Sustainability and Climate Action Strategy
outlines visions, goals, strategies, and actions across six focus areas of everyday
sustainability: Energy, Community, Natural Resources,Transportation &
Mobility, Solid Waste, and Water Infrastructure.Tracking actions through an
online strategy dashboard includes a target of near net-zero emissions across
Cary by 2050.This document builds on and expands Cary's 2012 Strategic
Energy Action Plan to include a comprehensive approach to emissions
reduction goals and targets.
Town of Chapel Adopted a resolution in 2019 to create a Climate Action Plan and
Hill achieve 80% clean, renewable energy in the community by 2030, and
100% by 2050. The Town also has a goal of reducing community GHGs
26-28% by 2025, 59% by 2030, and reaching net-zero emissions by
2050.
Chatham Adopted a resolution in 2017 to achieve 100%clean energy by 2050 and
County crafted a Comprehensive Plan focused on sustainable development, quality of
life, and resiliency.The Comprehensive Plan's Resiliency section sets a goal to
become a carbon-negative county. Electrification of transportation, energy
efficiency, and cleaning the power supply will play a huge role in achieving and
maintaining this goal.
Town of Adopted a municipal operations goal of achieving carbon neutrality by 2037
Davidson and a community-wide carbon neutrality goal by 2050.The Town adopted a
Climate Action Plan on April 9, 2024, which sets forth goals, strategies, and
actions to reduce emissions based on a 2019 greenhouse gas inventory, in
order to meet its carbon neutrality goals.
City of Durham Adopted its Carbon Neutrality and Renewable Energy Action Plan in 2021.This
plan commits the City to powering City buildings and operations with 80%
renewable energy sources by 2030 and 100% by 2050, and reducing
greenhouse gas emissions from City operations by 50% by 2030 and achieving
carbon neutrality by 2040.
Durham County Adopted a greenhouse gas emissions reduction goal in 2007 of reducing
government emissions by 50%and community emissions by 30%from 2005
levels by 2030.The County also adopted a goal of transitioning operations to
80% renewable energy by 2030 and 100% by 2050. In addition,the newly
adopted Durham City-County Comprehensive Plan includes a goal for all of
Durham to be carbon-neutral by 2050.
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Town of Adopted a resolution in 2017 establishing a transition from fossil fuel-powered
Hillsborough operations to 100%clean and renewable energy by December 31, 2050, or
sooner, and 80%clean and renewable energy by 2030.
Mecklenburg Adopted its Environmental Leadership Action Plan (ELAP) in 2021, aiming to
County achieve carbon neutrality for County operations by 2035.
Orange County Adopted a resolution in 2017 to transition to 100% renewable energy by 2050
and a resolution to reduce greenhouse gas emissions between 26 and 28
percent by 2025 from 2005 levels. Orange County's Climate Action Plan,
adopted in November 2023,further committed to reducing greenhouse gas
emissions by 50% by 2030 and 100% by 2050.
City of Raleigh Adopted a goal in 2019 of reducing community GHG emissions by 80% by 2050.
In 2021,the City released Raleigh's Community Climate Action Plan (CCAP),
which prioritized strategies in the areas of buildings and energy,transportation
and land use, and resilience and cross-cutting to meet GHG reduction, social
advancement, and resilience goals.The Office of Sustainability has since
reported on climate action progress to the Raleigh City Council and in its CCAP
implementation report and online CCAP data dashboard. In addition,the City's
Comprehensive Plan and Strategic Plan include policies and goals that focus on
GHG reductions,the use of alternative and renewable energy, improved energy
efficiency, community benefits and resilience, and energy security.
Town of Adopted a resolution in 2009 to reduce GHG emissions from municipal
Wilmington operations 58% by 2050, and in 2021 adopted a Clean Energy resolution to
transition from fossil-fueled municipal operations to 50%clean energy by 2035
and 100% by 2050.
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