Nelly Wogberg <[email protected]>
Re: DEAI and Sustainable Workforce Standards Request PUBLIC COMMENT FOR
ITEMS NOT ON THE AGENDA
1 message
Bart Pantoja San Mateo County BCTC <[email protected]> Thu, Mar 30, 2023 at 4:12 PM To: "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" dcol on@burlingame org , "kgonzalez@colma ca gov" kgonzalez@colma ca gov , "councilmemberRod@gmail com" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" BNa h@menlopark org , "afung@ci millbrae ca u " afung@ci millbrae ca u , "big tyckt@ci pacifica ca u " <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "jame coleman@ f net" jame coleman@ f net , "j wall@wood idetown org" j wall@wood idetown org , Rick DeGolia <[email protected]>
Cc: Jan Pepper <[email protected]>, Shawn Marshall <[email protected]>, Shayna Barnes <[email protected]>, "[email protected]" nwogberg@penin ulacleanenergy com
Rick,
Thank you for the response. It was our intent to make sure all were aware of our position.
Regards,
Bart Pantoja
Financial Secretary Treasurer
The Building & Construction Trades Council of San Mateo County 1153 Che Drive, Fo ter City CA 94404
(650) 358 9977
On Mar 23, 2023 at 10 34 AM 0700, Rick DeGolia rdegolia@ci atherton ca u , wrote Bart, thank you for your below email. This Proposed Workforce and Environmental Justice position paper was presented to PCE as part of the comments that we received in connection with the Executive Committee agenda and discussion of staff proposed modifications to Policy 10 It isn't specifically clear why this is being forwarded now to the Board at this time, but this is on our next Executive Committee agenda in connection with our consideration of the proposed changes to Policy 10 This isn't included on the Board agenda for Thursday's meeting Warm regards, Rick
Rick DeGolia
March 22, 2023
Rick DeGolia, Chair
Board of Directors
Peninsula Clean Energy
2075 Woodside Rd.
Redwood City, CA 94061
Honorable Chair DeGolia,
The CCA Workforce & Environmental Justice Standards Alliance is a group of more than 35 allied labor, climate, environmental, and environmental justice organizations advocating for California’s Community Choice agencies, including California Community Power (CC Power), to adopt and implement best practice workforce and environmental justice standards for CCA-contracted or owned clean energy projects.
We applaud Peninsula Clean Energy’s leadership developing and institutionalizing diversity, equity, access and inclusion (DEAI) into your Strategic Plan, and Ethical Procurement and Sustainable Workforce policies. We recognize PCE’s current workforce and environmental justice practices and policy as a leading example among CCAs.
The CCA Workforce & EJ Standards Alliance has collaboratively developed a comprehensive Policy Resolution (attached) which reflects utility industry standard and best practice. We have conducted a full comparison of our policy resolution against PCE’s practice and proposed policy and found alignment with most of your practices and many of your policies. However, we have identified a number of critical DEAI and Sustainable Workforce related policy and practice gaps in the following areas: targeted hire, CCA-owned projects, community benefits, meaningful community engagement, evaluation and selection, and local resilience.
Staff is preparing to present updated DEAI and Sustainable Workforce policy language to the Executive Committee on April 10 and the full board on April 27. We request your support for our Alliance leadership to work with your staff to understand the identified gaps and improve proposed policy language where appropriate before it is presented to the Executive Committee in April.
As we continue to work with other CCAs across the state to adopt industry standard workforce and environmental justice policies for clean energy projects, we want PCE to maintain its position as the model CCA we point to for its leadership supporting workers and the diverse communities that host its clean energy projects. We look forward to the opportunity to work with you and your staff to strengthen your proposed DEAI and sustainable workforce policies in alignment with your agency's espoused DEAI, workforce, and environmental values.
Sincerely,
Alphabetical endorsement list of alliance organizations follows:
Susan Penner, Co-Chair, Legislative Working Group, 1000 Grandmothers for Future Generations
Alan Weiner, Coordinator, 350 Conejo / San Fernando Valley Al Weinrub, Coordinator, California Alliance for Community Energy Ana Rosa Rizo-Centino, Network Manager, Central Coals Climate Justice Network Lynda Marin, Chapter Lead, Citizens’ Climate Lobby, Santa Cruz Chapter Michael Chiacos, Policy Director, Community Environmental Council Ratha Lai, CEO, Critical Impact Consulting
Rita Casaverde, Executive Director, Diversity Coalition, San Luis Obispo County John Foran, Founding Editor, Eco-Vista
Leah Redwood, Action Coordinator, Extinction Rebellion San Francisco Bay Area Tim Frank, Representative, Building and Construction Trades Council of Alameda Bart Pantoja, Building and Construction Trades Council of San Mateo County Paul Guiterrez, Business Manager, IBEW Local 234
Chuck Huddleston, Business Manager, IBEW Local 413
Greg Bonato, Business Manager, IBEW Local 595
John Doherty, Business Manager, IBEW Local 6
Mark Simonin, Business Manager, IBEW Local 639
David Mauro, Business Manager, IBEW Local 617
Hector Huezo, California Director, Jobs to Move America Veronica Wilson, CA Organizer, Labor Network for Sustainability Benjamin Eichert, Director, Let’s Green CA!
Jessica Tovar, Steering Committee Member, Local Clean Energy Alliance Gopal Shanker, President, Récolte Energy
Nancy Faulstich, Executive Director, Regeneración Pajaro Valley Sara Nelson, Executive Director, Romero Institute
Alex Lansberg, Director, Research & Advocacy, San Francisco Electrical Contractors Association
Jill ZamEk, Board Member, San Luis Obispo Mothers for Peace Joni Eisen, Representative, San Francisco Climate Emergency Coalition Ken Hough, Executive Director, Santa Barbara County Action Network Pauline Seales, Educator Organizer, Santa Cruz Climate Action Network Eric Veium, Chair, SLO Climate Coalition
Melissa Yu, Senior Energy Campaigns Representative, Sierra Club Timothy Duda, Directory, Terra Advocati
Kristin Kusanovich, Founder, tUrn Climate Crisis Awareness & Action Bijan Ashtiani-Eisemann, Organizer, UC Green New Deal Coalition Attachment: CCA Workforce and Environmental Justice Standards Alliance Policy Resolution Workforce and Environmental Justice Policy for Energy Procurement UPDATE: Dec. 7, 2022
PROPOSED RESOLUTION
Community Choice Aggregation (CCA) Governing Board to adopt a resolution that directs staff to develop and implement a Workforce and Environmental Justice Policy for CCA Energy Procurement which includes the following:
1. Competitive, clean and renewable power supply
CCA shall supply clean and renewable power and services1(new local, distributed, and Renewable Portfolio Standard (RPS) qualifying resources) to customers at competitive rates.
CCA shall include criteria in the bid evaluation process to prioritize projects that advance local resilience.
CCA shall prioritize Category 1 bundled RECs for all projects to meet its renewable energy goals. CCA shall avoid projects involving Category 2 and 3 RECs. If a CCA plans to use Category 2 or 3 RECs, the CCA shall produce a report on why alternatives were not feasible.
2. Workforce
Whether or not a construction project is a public work as defined by the California Labor Code, contracting partners shall comply with California prevailing wage provisions applicable to public works projects, including but not limited to the Labor Code sections pertaining to employment of apprentices on public works projects.
All construction work that falls within an apprenticeable occupation in the building and construction trades shall be performed by a skilled and trained workforce in accordance with Chapter 2.9 (commencing with Section 2600) of Part 1 of Division 2 of the Public Contract Code.
1 Clean and renewable means new local, distributed, and RPS qualifying resources only. Biomass technologies that incinerate municipal solid waste or combust woody or agricultural biomass in urban areas are excluded.
1 A preference for a Project Labor Agreement (PLA) will be incorporated into the bidder evaluation ranking process:
i. Work done under a PLA shall be deemed to meet the requirements of payment of prevailing wage and and use of apprentices, and shall supersede the skilled and trained workforce requirement ii. For projects that do not implement a PLA, an audit will be required to ensure compliance with payment of prevailing wages, compliance with skilled and trained workforce requirements and to demonstrate any employment of apprentices
CCA shall state a preference in the request for proposals for the use of local labor with a deliberate emphasis on targeted hiring of women, minorities, gender non-conforming, residents of low income communities, the formerly incarcerated, and veterans.
CCA shall first give a preference to projects that are located in a county or city that receives electric service from CCA , then to projects that are located within California, and then to projects whose first point of connection is within California.
CCA-owned projects shall be constructed through a multi-trade project labor agreement or through multiple such agreements, consistent with the Public Contract Code provisions authorizing such agreements by public agencies.
3. Environmental
All projects must meet the permitting requirements of the appropriate governing authority/authorities
CCA shall state a preference in the request for proposals for projects that avoid sensitive habitat areas and that comply with conservation plans such as the Desert Renewable Energy Conservation Plan.
CCA shall require in the request for proposals that developers of construction projects address how the project will avoid or mitigate, to the extent feasible, potential environmental and environmental justice impacts of the project.
The request for proposal shall request Global Electronics Council’s Electronic Product Environmental Assessment Tool (EPEAT) ecolabel registration status and level for 2 inverters, modules, and other applicable equipment 2
.
4. Environmental Justice
CCA shall identify disadvantaged community stakeholders (DAC) from the vicinity of projects using a variety of tools such as CalEnviroScreen and the State Department of Housing and Community Development’s opportunity maps. CCA shall make information easily accessible to disadvantaged stakeholders using various outreach methods including workshops, virtual webinars, and presentations at existing community meetings or events.
CCA shall meaningfully engage3 with “disadvantaged community” stakeholders residing within the CCA service area or proposed project area and incorporate input in the decision-making process
CCA shall state a preference in the request for proposals that developers of construction projects identify, in collaboration with community stakeholders, project benefits and negative effects to communities in the project vicinity, with an emphasis on evaluating disproportionate impacts on disadvantaged communities.
CCA shall require in the request for proposals that project developers include details of policies, programs, and practices supporting diversity, equity, and inclusion in their workforce recruitment and retention. Developer performance shall be included in bidder evaluation criteria.
Developers of construction projects shall state opposition to using forced labor in the supply chain.
5. Project evaluation and selection
CCA shall evaluate and select energy projects with a structured, multi-criteria evaluation process which utilizes the policy principles discussed herein.This evaluation process should holistically consider workforce, environmental justice, and community benefits balanced with technical and financial considerations.
3 Meaningful engagement means implementing five recommendations for best practices from Building a Just Energy Future - A framework for community choice aggregators to power equity and democracy in California, 2020 report by the California Environmental Justice Alliance 2 https://globalelectronicscouncil.org/
3 CCA shall publicly publish detailed project evaluation and selection documentation during project approval.
6. CA Community Power (CC Power)
CCA’s representative to the CA Community Power Board shall advocate for adoption of a CA Community Power Workforce and Environmental Justice Policy for Energy Procurement consistent with the terms of this resolution.
CCA’s representatives to the CA Community Power Board shall advocate to form a public advisory committee, including labor, environmental and equity representatives, to ensure transparency and public engagement in CA Community Power's operations and procurement practices.
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