Virginia Regulatory Town Hall
Department of Energy
Department of Energy
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3/17/23  3:57 pm
Commenter: Susan King, Dominion Energy

IIJA State Formula Funding, Sec. 40101d

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. 

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