Infrastructure Resilience Briefing — January 17, 2024
DOE’s $366 million transmission siting and economic development grants demand rigorous grant governance, community benefits delivery, labour compliance, and coordinated permitting across multi-state corridors.
On 17 January 2024, the U.S. Department of Energy (DOE) awarded $366 million in Transmission Siting and Economic Development (TSED) grants to nine state and regional entities to accelerate long-distance transmission projects and deliver tangible community benefits along the proposed routes. The program—created by Section 50152 of the Inflation Reduction Act—provides cost-shared funding for planning, permitting, and community investment activities tied to specific transmission corridors. While the grants supply much-needed capital, they also impose rigorous compliance obligations covering grant administration, labour standards, environmental justice, and ongoing community engagement. Recipients must now operationalise governance structures capable of delivering high-voltage projects on compressed timelines while demonstrating equitable outcomes to DOE, state regulators, and local stakeholders.
Establishing governance and financial controls
Each TSED awardee must finalise a cooperative agreement with DOE that details milestones, budget categories, and performance metrics. Program management offices should build grant governance frameworks that define executive sponsors, project controls, procurement authorities, and escalation pathways. Finance teams must segregate TSED funds within enterprise resource planning systems, track expenditures against authorised budget lines, and document cost-share contributions in accordance with 2 CFR Part 200. Internal controls should address procurement integrity, timekeeping, cost allocation, and subrecipient monitoring. Because many awards flow through state energy offices or regional transmission organisations, coordination with partner utilities, tribes, or community development organisations is essential to avoid duplicative claims and maintain audit readiness.
Recipients should schedule quarterly risk reviews that examine cash flow, permitting progress, and stakeholder commitments. DOE requires periodic SF-425 Federal Financial Reports and detailed project narratives; compliance teams must implement review and approval workflows to ensure submissions are accurate, timely, and supported by source documentation. Internal audit or an independent compliance function should conduct readiness assessments before the first drawdown and again prior to DOE monitoring visits.
Integrating permitting and environmental review obligations
TSED funds can cover planning, environmental review, and pre-construction activities for transmission lines that often span multiple jurisdictions. Project teams must align funding schedules with the National Environmental Policy Act (NEPA) process, state siting statutes, and federal land-management requirements. Environmental managers should prepare master permitting matrices that catalogue federal, state, tribal, and local permits; responsible agencies; expected timelines; and data dependencies. Where projects cross federal lands or waters, recipients should coordinate with DOE’s Rapid Response Team for Transmission to sequence NEPA reviews and leverage programmatic agreements.
The grants prioritise projects that reduce environmental burdens on disadvantaged communities. Compliance officers must embed the Justice40 Initiative’s requirements into environmental review documents, ensuring that cumulative impact analyses, mitigation strategies, and community benefit plans address historical pollution, land use, and public health concerns. Recipients should maintain auditable records of outreach to tribal governments and Indigenous communities, including consultation logs, meeting notes, and agreements on cultural resource protection.
Delivering community and economic development commitments
A distinctive feature of the TSED program is the requirement to invest in host communities. Awardees must deliver Community Benefits Plans (CBPs) that outline good-paying jobs, supplier diversity targets, workforce development pathways, and strategies to prevent displacement. Program teams should establish key performance indicators (KPIs) for each CBP pillar—job creation, equitable access, environmental justice, and community engagement—and track progress through dashboards shared with DOE and local stakeholders. Agreements with labour unions, community colleges, and workforce boards should specify apprenticeship utilisation goals, credentialing programs for lineworkers and electricians, and wraparound services such as childcare and transportation assistance.
Community investment spending may include site-specific improvements like broadband access, resilience hubs, or business incubators. Recipients must develop criteria for evaluating these projects, ensuring alignment with local planning priorities and documented community input. Contracts or grant agreements with local partners should include reporting obligations, performance milestones, and clawback provisions if deliverables are not met.
Labour standards and supply chain compliance
TSED funding carries Davis-Bacon prevailing wage requirements for construction activities, as well as expectations for project labour agreements on large-scale builds. Procurement teams need to vet contractors’ payroll systems, certified payroll reporting capabilities, and track records with apprenticeship programs. Compliance officers should design labour standards monitoring plans that include on-site inspections, worker interviews, and corrective action protocols. Where projects leverage the Inflation Reduction Act’s tax credits in parallel, recipients must coordinate documentation to demonstrate that prevailing wage and apprenticeship requirements are met across funding streams.
Transmission projects rely on specialised equipment—conductors, towers, transformers—that face global supply constraints. DOE expects recipients to align sourcing with Build America, Buy America (BABA) preferences or obtain waivers where domestic suppliers are unavailable. Supply chain managers should inventory critical components, assess domestic manufacturing capacity, and document waiver justifications well before procurement deadlines. Contracts must include clauses requiring suppliers to provide origin documentation and notify recipients of any changes in manufacturing location.
Stakeholder engagement and transparency
Successful transmission siting hinges on transparent, inclusive engagement. TSED awardees committed to developing public-facing engagement plans that provide multilingual information, regular project updates, and feedback loops for residents, local governments, and tribal nations. Communications teams should maintain project websites, host recurring town halls, and publish plain-language summaries of environmental studies and route alternatives. They must also establish grievance mechanisms that allow stakeholders to submit concerns anonymously, track responses, and escalate unresolved issues to senior leadership.
DOE requires recipients to report progress on stakeholder engagement and community benefits. Program teams should standardise data collection across partners, ensuring that metrics such as meeting attendance, community investments delivered, workforce demographics, and small-business participation are captured consistently. Transparency builds trust and can mitigate litigation risk during siting proceedings.
Coordinating with regulators and interregional partners
Transmission corridors supported by TSED grants often cross multiple regulatory jurisdictions. Recipients must synchronise planning with state utility commissions, FERC, and—where applicable—Canadian or tribal regulatory bodies. Legal teams should map filing obligations, hearing schedules, and evidentiary requirements, ensuring that grant-funded studies feed directly into certificate applications and cost recovery cases. Collaboration with regional transmission organisations and balancing authorities is critical to integrate new lines into regional planning, interconnection queues, and reliability assessments.
Where grants support interregional projects, recipients should establish memoranda of understanding (MOUs) that define roles, cost-sharing arrangements, and dispute resolution processes among participating states or utilities. These agreements should address data sharing, confidentiality, and governance over joint outreach initiatives. Early consensus on project benefits, rate allocation, and contingency planning reduces the likelihood of regulatory delays.
Monitoring, evaluation, and reporting
DOE will conduct ongoing monitoring through desk reviews, site visits, and performance evaluations. Recipients must prepare compliance binders containing cooperative agreements, budget justifications, procurement files, environmental documentation, stakeholder engagement records, and labour compliance reports. They should perform periodic self-assessments to confirm adherence to grant terms and implement corrective actions promptly when issues arise.
Evaluation frameworks should extend beyond DOE requirements to support long-term accountability. Program teams can establish balanced scorecards that track permitting milestones, capital leverage ratios, community benefit delivery, workforce metrics, and stakeholder satisfaction. Lessons learned should feed into continuous improvement plans, informing future transmission proposals and strengthening relationships with impacted communities.
By treating TSED grants as catalysts for robust governance, equitable community investment, and disciplined project execution, recipients can accelerate critical transmission infrastructure while meeting DOE’s heightened expectations for transparency and accountability. Success will not be measured solely by miles of line constructed but by demonstrable progress in delivering economic opportunity and reliability improvements to the communities that host the nation’s grid expansion.
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