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.