The Biden-Harris Administration have championed the full and fair participation of underserved communities through investments in clean energy, manufacturing and infrastructure as part of the President’s Investing in America agenda. The administration aims to deploy clean energy across the U.S. and ensure a just and equitable future by focusing on the impacts and benefits that projects, programs, and infrastructure have on local communities and stakeholders. To address gaps in data collection, the U.S. Department of Energy (DOE) implemented an agency wide Bipartisan Infrastructure Law (BIL) Funding Opportunity Announcements (FOA) template for BIL and Inflation Reduction Act actions to further the Administration’s goals to advance equity, provide support for disadvantaged communities, and leverage federal resources to achieve these objectives.
The FOA template now includes a new, extensive, lengthy and detailed Community Benefits Plan (CBP) requirement, which outlines and demonstrates how the project will create high-quality and long-term jobs, spur economic development, and provide other direct benefits to the community, including ownership participation and local electrification. CBPs promote broadly shared prosperity in the clean energy transition, reduce project risk and build public support and trust for first of a kind clean energy technologies and projects. The ultimate purpose of CBPs is to convey that the clean energy projects and work we are doing has engagement, equity, accessibility, diversity, inclusion, economic and workforce development efforts, positive impact and benefits on the communities, residents, and workers we represent and serve.
CBPs are scored at 20 percent of the overall technical merit review of proposals. CBPs have a 25-page maximum, and milestones and workplan should be incorporated into the overall project’s schedule, phases, budget, resource summary, metrics collections, and outcomes.
Applicants are required to comprehensively describe the approach to be taken with addressing four priority components that make the Community Benefits Plan and encouraged to complete each portion of the CBP to the greatest extent possible, covering every project site proposed:
- Engaging community and labor.
- Investing in America’s workforce.
- Advancing diversity, equity, inclusion, and accessibility (DEIA) through recruitment and training.
- Implementing Justice 40 Initiative, which directs 40% of the overall benefits of certain Federal investments to flow to disadvantaged communities (DAC)
Successful CBPs will incorporate the following important elements:
The community and labor engagement section should describe the applicant’s previous and ongoing plans to engage with community stakeholders in all impacted communities including Tribes, local governments, non-profit and community-based organizations, labor unions and workforce organizations. The objective of the engagement plan is to conduct meaningful community and labor engagement, incorporate input and priorities from stakeholders and impacted groups into the project and ensure that engagement will impact project decisions and support transparency and accountability.
Plans to negotiate either of the following community agreements: community benefits, good neighbor, project labor, community workforce or other collective bargaining agreements. Projects impacting multiple communities may develop agreements with each community. Two-way engagement statements discuss how the proposed project incorporates community input and the extent to which the host communities have already indicated support for the project. The statement should list the points in project phases where engagement can impact decisions or characteristics, and how community engagement results will impact project decisions and characteristics should be incorporated into the application.
The Justice 40 Initiative section should describe the applicants plan to advance energy and environmental justice through the project. It should include an assessment of project impacts and where they flow, and an implementation strategy describing actions to maximize benefits and minimize negative impacts and measure, track, and report impacts. Using the Climate and Economic Justice Screening Tool will easily help you identify if your project site is located within a disadvantaged community and give you analytics tools and information on overburdened and underserved census tracts with datasets including air quality, energy, health, housing costs to employment. Stress where and to whom project benefits are expected to flow and the extent to which they flow to disadvantaged communities, or overburdened, underserved groups. Elaborate on anticipated project benefits and metrics that will be used to track each benefit. Include all anticipated negative impacts and potential barriers to realizing benefits and plans to track, minimize and mitigate negative impacts and barriers. DOE prioritizes projects that directly flow benefits to former mining and manufacturing communities, especially where there are displaced local workers from the fossil fuel and manufacturing industry, as well as other economically distressed areas.
The Investing in the American Workforce section should include efforts to invest in the American local workforce and support quality jobs, workforce development and worker rights including how workers can form and join unions of their choosing and how they will have the opportunity to organize with the purpose of exercising collective voice in the workplace. Plans to attract, train and retain a skilled, local, and diverse workforce including workforce recruitment efforts and workforce partnerships, with an emphasis on creating high quality and high paying jobs and offering fair wages, benefits, progressive career paths, training and development opportunities, etc. Include how many jobs your proposed project will create. Workforce development plans include workforce education, accreditation, skills learning and training for local workers and support for workers’ skills acquisition and opportunities for advancement.
Detail how DEIA objectives, initiatives and partnerships with minority serving institutions, underrepresented businesses, educational institutions, and training organizations will be incorporated into the project and will serve and advance minority, underserved, underrepresented groups and workers facing barriers to quality jobs. Emphasize partnerships with Minority Business Enterprises, Minority-Women or Veteran Owned Businesses, Tribal Colleges and Universities, community or faith-based organizations or entities in underserved communities.
Community Benefits Plans are certainly a cumbersome undertaking, however GNA, a TRC company, has years of experience and knowledge with providing consulting services for pre-contract support and grant management and brings 30 years of collective experience with writing successful grant applications and administering grant awards for clean transportation and clean energy, including specific and significant grant experience with the U.S. Department of Energy. GNA is proud of our 90% grant application success rate, with 600 plus grant applications submitted and $1 billion in secured grants and funding for our clients. GNA offers clients tremendous expertise on how to successfully secure funding and incentives for clean transportation, low carbon fuels and energy projects. We provide clients with solid analyses, understanding, and strategy on how to write enticing community benefits plans and submit a winning application. Our applications not only meet the program criteria but are written in such a way as to garner recognition and earn the funding requested. To learn more about how GNA can support you please contact me at aamirkhanian@trccompanies.com.
