Thank you for the opportunity to participate in the planning process for the Electric Grid Resilience State and Tribal Formula Grant Program 40101(d). Dominion Energy Virginia (DEV) has spent the year, and continues, analyzing opportunities for funding from the Infrastructure Investment and Jobs Act (IIJA). DEV would like to emphasize the importance of workforce development as a consistent theme outlined in Virginia Energy's proposal for state-wide efforts. Below we have provided a perspective on additional areas of emphasis, potential metrics, and opportunities based on what Virginia Energy has proposed:

• Resilience, including reducing the frequency and duration of outages (system, circuit and/or targeted individuals).

40101(d) presents an opportunity for the state to achieve the resiliency and reliability goals outlined in the IIJA. To maximize the state's allocated investment, it may consider a targeted approach that prioritizes a specific grid resiliency need for successful implementation of the program. No matter the scale of the selected projects, standard distribution metrics that measure resilient infrastructure include System Average Interruption Duration Index (SAIDI), System Average Interruption Frequency Index (SAIFI), and Customer Minutes of Interruption (CMI) and could be considered to demonstrate measurable improvements in energy resilience. For transmission-related projects, Sustained Outages per Hundred Miles, Transmission Unavailability Rate, System Protection Mis-Operation Rate, and Upstream Generation MWhrs Lost are standard metrics to considered. 

• Energy Justice concerns in disadvantaged communities.

Virginia Energy's objective related to energy justice is critical to achieving the goals of the IIJA that funding be used to achieve the greatest positive community benefit, in terms of enhancing grid resiliency and investment in job creation and training, while minimizing negative impacts to the environment and communities.

Energy justice efforts should focus on ensuring historically disadvantaged communities (as defined in the MPDG 2022 NOFO and consistent with OMB's Interim Guidance for the Justice40 Initiative) are neither disproportionately harmed by infrastructure development nor excluded from project benefits. Efforts may also focus on advancing purposeful inclusion of these communities during the infrastructure development planning process, with a commitment to build partnerships and provide the opportunity for meaningful engagement to ensure understanding and involvement; concerns are heard and appropriately responded to and addressed. 

To encourage sustained engagement with communities, Virginia Energy can consider working with existing programs and organizations within historically disadvantaged communities and ensuring there are adaptive and inclusive governance practices with the roll out of any pilot or program. 

• Plans use strong labor standards and protections (including for direct employees, contractors, and subcontractors), such as through the use of project labor agreements, local hire agreements.

Virginia's 40101(d) program can serve as a catalyst for attracting and training of local workers. Developing a strong local workforce may be challenging, given the scope and magnitude of projects funded by IIJA. However, special consideration may be given to the workforce development efforts that would enable the use of these types of labor standards and protections throughout Virginia in the future. 

• Outline of a plan to attract, train, and retain an appropriately skilled workforce (i.e., through registered apprenticeships and other joint labor management training programs that serve all workers, particularly those underrepresented or historically excluded).

When developing plans to attract, train, and retain skilled workers, a holistic view across industries operating in the state will help amplify private-sector efforts. A long-term, state-wide approach to workforce development may be rooted in shifting industry standards that will continue to evolve rapidly over the next decade. As a result, Virginia workers will need to regularly update and refresh their skills to continue enabling resiliency initiatives throughout the state. Metrics aligned to this goal should be aligned with energy justice metrics. 

• Plans to partner with a training provider (labor, community college, etc.); and the use of an appropriately credentialed workforce (i.e., requirements for appropriate and relevant professional training, certification, and licensure).

Partnership will be essential to the success of training and workforce development programs. To address this, Virginia may consider concepts such as new infrastructure academies with both public and private funding. 

DEV appreciates the opportunity to comment on Virginia Energy's 40101(d) program. 

Virginia Polytechnic Institute and State University (Virginia Tech) has taken the initiative to significantly reduce the carbon footprint and efficiently integrate DERs into Virginia Tech Electric Service (VTES) utility. This will require a significant transformation of our system by including equipment capable of enhanced awareness and coordinated, instantaneous and intelligent response to ever-changing conditions. We must be able to accommodate the proposed renewables and distributed energy; have a stainable system that is resilient to natural disasters and man-made attacks; be efficient in meeting increased demand without infrastructure upgrades; provide a safe environment for the public and utility workers; provide improved power quality for complex digital consumption (IEDs, TVs, smartphones, EVCs, etc.) and most importantly, be cost effective.

Funds from the 40101(d) grant could potentially be used to meet these requirements. We could improve monitoring and control technologies by replacing overhead manual switches and infrastructure with padmounted switchgear and underground conductor. We have a desire to remove 31 wood structures and guys from the system; alleviate multiple overhead spans and low-hanging service drops to promote natural growth of vegetation without interfering with the utility; add new switchgrear to accommodate dual-primary service feeds for increased reliability; 1960s equipment will be replaced - new transformers will meet the newly proposed DOE Energy Efficiency Standards for Distribution Transformers (TP-1). Also, we have a desire to improve system reliability by adding intelligent and coordinated field protection equipment with reclosing and one-shot capability.

VTES currently has less than 40 employees. On average, we serve 6,700 members of predominantly rural community as well as University operations that manage approximately 36,000 students. The VTES system has no large corporate load, industrials nor data centers. Our low-density loads are seasonal; much of the area is vacant during summer peaks and partially present during the winter peaking season. However, we must continue to support increasing operational & maintenance costs for the aging infrastructure.

Because we are not an investor owned utility (IOU) and receive no state or University funding, we have been unable to implement the above improvements and measures due to financial limitations. As a good steward, VTES has a fiduciary responsibility to not unfairly burden our customers with infrastructure costs. GRIPS funding received via the 40101(d) would help our small-scale utility and public University implement necessary resiliency and quality-of-life upgrades.

The Virginia, Maryland, and Delaware Association of Electric Cooperatives (“VMDAEC”) submits the following comments on behalf of Virginia’s Electric Cooperatives  (the “Cooperatives”) in response to the Virginia Department of Energy’s (“Virginia Energy”) open public comment forum on the Electric Grid Resilience State and Tribal Formula Grant Program (the “Grant Program”).  As Virginia Energy is aware, the Cooperatives are utility consumer services cooperatives organized under the laws of the Commonwealth of Virginia, and VMDAEC is their statewide service organization.  Virginia’s Electric Cooperatives are owned by and operated for the benefit of their member-consumers, and their operations are conducted on a not-for-profit basis.

We appreciate the opportunity to comment on the program objectives, metrics, and evaluation criteria as part of Virginia Energy’s planning process for the Grant Program.  These comments address two specific areas of program design and implementation as it affects Virginia’s Electric Cooperatives.  We stand ready to provide Virginia Energy with any support necessary in its pursuit of these federal funds.

Design the program to not pass through the cost of the 15% state match to not-for-profits.

Virginia Energy is required to match 15% of the amount of each grant provided to the State under the Grant Program.  The Grant Program design allows Virginia Energy to pass the required match through to any of the sub-awardees under the program.  However, Virginia Energy should not pass through the cost of the additional 15% match to not-for-profit sub-awardees.

Virginia’s Electric Cooperatives provide electricity to their members on a cost-neutral basis.  Any expense incurred by a cooperative is passed through to its members and is consequently critical to minimize the costs borne by members.  Under the program design, a cooperative is already required to match 1/3 of a grant award.  A 1/3 match will be strenuous enough for most cooperatives, so passing through the additional 15% match will only create an additional barrier for cooperatives considering pursuing this grant program. Therefore, if a cooperative participates in this Grant Program to benefit its members in the long term, then any required match may financially affect its members in the short term or in future rate design.

A large portion of this Grant Program is intended to focus on disadvantaged communities that are marginalized, underserved, and overburdened by pollution.  As later discussed, Virginia’s Electric Cooperatives serve a vast majority of that population.  Please help Virginia’s Electric Cooperatives improve the resilience of their electric grids of communities in the Commonwealth that need it the most while minimizing potential rate impacts.

Awards to Virginia’s Electric Cooperatives will help satisfy the Justice40 requirement.

The Climate and Economic Justice Screening Tool (CEJST) is a geospatial mapping tool to identify disadvantaged communities that are marginalized, underserved, and overburdened by pollution.  CEJST identifies Justice40 communities.  The CEJST map shows a vast majority of the Justice40 identified communities coincide with Virginia’s Electric Cooperative’s service territories.  If Virginia Energy is required to award 40% of the benefits of the overall investments provided through the Grant Program to disadvantaged communities in accordance with the Justice40 Initiative, then Virginia Energy should emphasize working with Virginia’s Electric Cooperatives to achieve that goal.

In conclusion, Virginians deserve and need improvements to the resiliency of the Commonwealth’s electric grid regardless of where they live.  We genuinely value Virginia Energy as a long-term partner in improving the resiliency of the Commonwealth’s electric grid.  Virginia’s Electric Cooperatives stand ready to provide Virginia Energy with any support necessary in its pursuit of these federal funds.  Should you have any questions, please do not hesitate to contact me.