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Staying Current: A Community Readiness Framework for Marine Energy Applied to River Current Energy in Alaska

Marine energy-including wave, tidal, and river current energy-can provide a local energy source for rural and remote communities. Marine energy has the potential to bolster self-sufficiency and create economic opportunities while preserving ecological integrity. Communities may be interested in deploying, testing, and advancing these early-stage technologies to meet their needs. However, limited capacity, workforce constraints, and other barriers can challenge development. To better understand a community's interest in and preparedness for marine energy, we developed a suite of 150 'metrics of readiness.' Organized across seven categories-technical, social, environmental, strategic, governance, economic, financial-and 29 subcategories, the metrics provide a holistic perspective beyond the technical aspects of an energy device. We conducted a desktop application of the metrics of readiness for Igiugig, Alaska. The metrics were applied retrospectively for two points in time: before (2009) and after (2018) in-stream testing of a river current energy device. By documenting changes among categories and subcategories of the metrics, our results show the evolving nature of community readiness for river current energy. They also illustrate how our interdisciplinary framework captures the investment in environmental effects research and commitment to strategic planning that occurred in Igiugig. In future applications, we envision the framework could be used to foster public engagement in marine energy, collaborate with communities in project development, shape capacity building activities, prioritize investments, and inform research needs. While our study focuses on enabling river current energy in Alaska, the metrics of readiness have the potential to inform implementation of other renewable technologies with communities in new geographies.

13 HYDRO ENERGY

Advancing Asset Management in Water Infrastructure Systems

Aging water system infrastructure, including drinking water, wastewater, and stormwater, poses a growing challenge for utilities and municipalities. These water systems have well documented challenges with respect to their age, condition, and level of service. ASCE annual report cards consistently rate these infrastructure systems in the United States as underfunded, overcapacity, or past service life (ASCE 2025 Report Card). For example, Chini and Stillwell (2017) estimated that the mean water loss in drinking water systems, i.e., non-revenue water, is approximately 16% across the United States. These concerns are not just relegated to the United States, with Courtenay, British Columbia, identifying 17% of their water main pipes as in a ‘poor’ condition state, defined as a category condition 5 out of 5 (City of Courtenay, 2024). These cases illustrate the challenges utilities are facing to manage extensive networks of infrastructure to deliver a consistent and high level of service. For buried infrastructure such as water systems, studies suggest that preventative interventions can lead to lower maintenance costs and fewer service disruptions (Mazumder et al, 2018; Li et al, 2014). The demonstrated need and benefit of appropriately applied asset management is juxtaposed against the relatively sparse literature that evaluates water systems within an asset management construct. Since 2020, just 37 papers specifically reference asset management in the Journal of Water Resources Planning and Management. Of those, only a few specifically look to develop strategies for improved asset management. Therefore, we highlight four key research areas that represent opportunities for advancement of asset management research for water systems. First, advances in condition assessment and forecasting are needed to better estimate asset deterioration using diverse datasets. Second, machine learning (ML) and artificial intelligence (AI) hold promise for predictive maintenance and investment prioritization, though questions of generalizability and model transparency remain. Third, applying a value of information framework can guide utilities in making cost-effective sensor deployment and data collection decisions, to direct monitoring strategies towards data-informed asset management decisions. Finally, integrated infrastructure management is critical, requiring coordinated planning with other infrastructure systems and stakeholder engagement to reduce costs and enhance service delivery.

Chini, Christopher M.

NARUC Resilience Framework

The NARUC Resilience Framework provides state regulators and other key stakeholders with a structured approach to considering policies and programs that will enhance grid resilience amid evolving technological, environmental and economic challenges. This Framework consolidates insights from nationwide workshops and peer discussions into six actionable components: (1) setting goals and objectives, (2) leveraging use cases, (3) establishing shared definitions, (4) ensuring inclusive process leadership, (5) addressing critical design questions, and (6) guiding implementation. This Framework is intended as a strategic tool for regulators to navigate resilience investments, prioritize affordability, integrate stakeholder needs, and foster collaboration across agencies, all while balancing cost-effectiveness with societal and economic resilience outcomes. By presenting a structured approach to decision-making rather than prescriptive solutions, the Framework supports nuanced, jurisdiction-specific resilience planning and is adaptable to the dynamic demands of modern energy systems

24 POWER TRANSMISSION AND DISTRIBUTION

Nine Canyon Long-Duration Energy Storage: A Feasibility Study

The Nine Canyon Long Duration Energy Storage (LDES) Feasibility Study explores the technical and economic viability of deploying advanced energy storage technologies at Energy Northwest's (EN) Nine Canyon (9C) Wind Project site in Benton County, Washington. Supported by the Washington State Department of Commerce and the U.S. Department of Energy’s Office of Electricity under its LDES Voucher Program, the study represents a collaborative effort between EN, Pacific Northwest National Laboratory (PNNL), and ARES North America. At the core of this effort is the development of a generalized techno-economic modeling framework and evaluation tool designed to assess the value proposition of LDES projects across a variety of contexts. The modeling tool is technology-agnostic and accommodates user-defined parameters such as rated power, energy duration, round-trip efficiency, capital and operational costs, and dispatch constraints. It also integrates economic inputs, including market prices, energy revenue structures, and financing parameters to evaluate performance through key metrics. The tool provides utilities with a transparent, adaptable platform to support decision-making, investment prioritization, and portfolio planning for various storage technologies. To guide scenario design and interpretation, the study first surveyed the LDES technology landscape, including lithium-ion batteries, flow batteries, non-hydro gravity storage, and thermo-mechanical systems, comparing cost trajectories, technical performance, safety and hazards, materials sourcing and recyclability, and spatial/siting considerations. This literature-grounded review highlights technology trade-offs and reinforces the need to align technology choice with site characteristics, use cases, and project objectives. A companion chapter examines ownership structures (EN ownership, third-party ownership, shared models) and offtake options (energy marketing, capacity/energy PPAs, time-of-use PPAs, block-delivery PPAs, and tolling), where PPAs (power purchase agreements) represent contractual arrangements for buying and selling electricity. The chapter also highlights implications for risk allocation, capital access, operational control, and revenue certainty. The study also evaluates supervisory control and data acquisition (SCADA) and transmission interconnection pathways, options include upgrading the existing SCADA or deploying a dedicated LDES controller, with attention to protection schemes, data telemetry, cybersecurity, and regulatory coordination with BPA. In addition, an ARES-specific geotechnical and hydrology assessment presented in the appendix screens multiple corridors for slope stability, bearing capacity, cut-and-fill magnitude, and stormwater behavior.

25 ENERGY STORAGE

Addressing the Split Incentive Challenge for Enhanced Solar Adoption in Multifamily Rental Properties [Abstract]

The split incentive problem is particularly pronounced in rental markets, where landlords prioritize investments that directly increase property value or rental income. Since energy savings from solar photovoltaic (PV) systems primarily benefit tenants, landlords may perceive little return on investment unless mechanisms exist to recapture some of the financial gains. The primary objective of this project is to develop a publicly available, web-based tool to analyze the U.S. Department of Energy’s ResStock database, which models the U.S. residential building stock. The tool allows users to filter buildings by location, type, HVAC system, square footage, and other characteristics, and outputs typical electric load profiles. By leveraging location-specific electric load data, Fram Energy aims to advance business strategies that address the split incentive barrier and promote the adoption of solar PV installations in rental properties. In addition, a machine learning model will be developed to weigh the marginal contribution of building features across the dataset in predicting electricity demand, supporting guided decision making in forecasting electric load profiles. Lastly, based on each building’s location, load profile, and utility’s electricity rate, an optimized solar photovoltaic array and battery energy storage system will be sized to provide energy arbitrage opportunities.

14 SOLAR ENERGY

Guidance for Grid Resilience Decisions in Rural Minnesota

This report assesses the hazard landscape of the state of Minnesota, identifies weather hazards that are most impactful to the distribution system, includes a statewide assessment of household access to services dependent on reliable power, reviews resilience planning activities of electric utilities in Minnesota, and presents analysis of distribution grid performance in the face of extreme weather events with data from seven electric cooperatives dispersed throughout outstate Minnesota. This information is synthesized to provide considerations for resilience investment prioritization.

29 ENERGY PLANNING, POLICY, AND ECONOMY

Stakeholder-guided holistic, Adaptive Framework for enhancing community Energy Resilience (SAFER) (Final Technical Report)

The Stakeholder-guided holistic, Adaptive Framework for enhancing community Energy Resilience (SAFER) project advances resilience science and engineering by addressing challenges in rural Kansas communities where aging infrastructure, extreme weather, and socioeconomic disparities heighten vulnerability to energy disruptions. Traditional approaches often focus on technical performance while overlooking community concerns and priorities. SAFER responds by integrating community perspectives with advanced analytical frameworks to create a holistic model for measuring and improving resilience. Project objectives included developing novel resilience metrics, advancing modeling frameworks that capture interdependencies across infrastructures, and embedding community-centric indicators directly into planning processes for distributed energy resources. The key technical innovations included the creation of self-organizing map (SOM)-based indices for objective resilience quantification, hetero-functional graph theory (HFGT) models linking power, water, transportation, and community assets, and graph neural network (GNN) tools for identifying critical nodes in complex systems. Community-centric energy planning was demonstrated through optimal siting and sizing of (photovoltaic) PV and battery storage, ensuring resilience enhancements also addressed energy burden and energy insecurity. SAFER engaged community partners in Dodge City and Ford County through surveys, focus groups, and workshops, generating more than 600 responses that established baseline measures of energy burden, financial insecurity, and willingness-to-pay to avoid outages. This data, organized in terms of a community capitals framework, informed the development of weighted reliability indices that better reflect community costs than traditional utility metrics. SAFER’s GNN-based critical node identification framework identified expert-labelled critical nodes with over 99% accuracy, while also uncovering additional functionalities essential for proactive resilience planning. The project’s models demonstrated that optimal PV and storage deployment could improve resilience indices by over 11 percent, with dispatch strategies further enhancing outcomes, confirming both the technical effectiveness and economic feasibility of these approaches. Through its combined emphasis on rigorous modeling, community-focused planning, and community engagement, SAFER advances the state of resilience research while delivering direct benefits to rural communities. The project provides tools, guidelines, and resilience heatmaps that help utilities, local governments, and residents better anticipate disruptions, prioritize investments, and strengthen the capacity to withstand and recover from energy-related hazards. Furthermore, the developed HFG and GNN frameworks are designed for transferability, allowing them to be adapted for resilience planning in other communities with minimal retraining. This inductive learning capability provides a scalable pathway to extend the SAFER project’s impact. Thus, creating a foundation for a nationally applicable model of infrastructure resilience. Additionally, the HFG can also be extended to include other FEMA community lifelines.

14 SOLAR ENERGY

Greenhouse gas emissions reduction strategies that maximize portfolio-wide life cycle cost reduction, resilience, and environmental justice benefits

While strategies to achieve net-zero emissions at an individual site are well understood, new analysis methods are required for organizations seeking to achieve net-zero across multiple facilities, each with concurrent priority goals. At a portfolio level, distinct locations present varied challenges that cannot be addressed through singular solutions, and competing goals can take precedence with the assumption that net-zero emissions strategies deter from energy resilience and cost savings, therefore negatively impacting nearby communities. This study tests these assumptions by analyzing 16 diverse sites (varying in size, climate, and energy use) to identify strategies that reduce emissions and assess the impact these strategies have on life cycle costs, resilience, and communities with environmental justice concerns. Methods were developed to approximate missing information essential to net-zero evaluation. Established methods were augmented to evaluate life cycle costs, resilience, and environmental justice impacts across a set of strategies and accommodate the multi-criteria analyses. Potential benefits from identified strategies were quantified using site characteristics and a set of corresponding metrics. The net-zero analysis found that 11 sites could use on-site strategies to eliminate all but 2% of emissions generated. The remaining emissions can be offset, for instance through sequestration, executed at the portfolio scale. On-site carbon-free energy was found to reduce 51% of emissions across all sites; efficiency reduced 19% of emissions; sequestration 16%; procured carbon-free energy 15%; fuel switching 1.6%; and fleet electrification 1.3%. Building electrification, however, increased emissions by 4.4%. Different strategies also provide cost, resilience, and/or environmental justice benefits—the degree to which varies with individual site conditions. The findings indicate an advantage to considering the strategies as a comprehensive set, which leads to co-benefits, both in the ability to achieve net-zero goals and in advancing other goals. The results present the case for comprehensive advanced planning at the portfolio level to prioritize investments that will balance the minimization of emissions and life cycle cost with the maximization of resilience and environmental justice benefits. The novel methods for evaluation and integration, valuation of benefits, and consideration at the portfolio scale allow organizations to select investments that simultaneously address multiple key priorities.

Net-Zero Emissions

Equitable Energy Metrics for Integration into Building Performance Standard Tracking Platforms: Preprint

Building Performance Standards (BPS) are being adopted globally and in the United States of America, where 14 different states and jurisdictions have a policy in place and many others are under development (Department of Energy (DOE) 2023). Accurate and equitable data sources are essential to make informed decisions about focusing investment on upgrading buildings to meet jurisdictional goals. There have been multiple new tools developed related to Energy Equity and Environmental Justice (EEEJ) and the resulting datasets need to be integrated into large building port-folios for quick access and better scalability. Integrating EEEJ data in a user-friendly format can help decision makers more quickly assess impacts and analyze the multitude of potentially significant metrics for which there is not yet consensus. In the U.S. and Canada, many BPS ordinances rely primarily on ENERGY STAR Portfolio Manager (ESPM) to capture building characteristics and energy and water consumption data. These datasets can then be imported into city-specific building tracking tools like the Standard Energy Efficiency Data Platform (SEED). Crucially, BPS decision makers require an efficient means of identifying buildings in priority communities to effectively allocate resources and funding. This process must integrate seamlessly with existing jurisdictional toolsets for optimal utility. This paper will demonstrate, for the case of Washington D.C.'s (the District) data, a workflow that provides actionable data for building upgrade investment prioritization in disadvantaged communities.

BPS

Strategies for Flood Resilience and Grid Investment Among Iowa's Electric Distribution Utilities

Flooding poses a growing threat to Iowa's electric distribution system, yet utilities face significant data and modeling challenges in planning effective resilience investments. This report provides a foundational assessment of how distribution utilities in Iowa, investor-owned, municipal, and cooperative, approach resilience planning, with a focus on flood risk. It combines hazard characterization, review of state and utility practices, and application of NLR's Energy Resilience Analysis for Distribution Systems (ERAD) and Capacity Expansion Decision Support for Distribution Networks (CADET) tools. Using FEMA floodplains, Iowa Flood Center depth grids, and utility infrastructure data, the analysis quantifies asset exposure, simulates outage risks, and evaluates resilience strategies such as pole hardening, undergrounding, and substation protection. Results indicate that while feeder-level upgrades provide incremental benefits, the most significant reductions in outage risk are achieved through targeted substation interventions. The report highlights key data gaps, such as limited elevation data and fragility functions, and underscores the need for probability-weighted investment frameworks to address both frequent and catastrophic flood events. These insights aim to support utilities, state agencies, and federal partners in prioritizing resilience investments that safeguard Iowa's electric grid against future flooding.

24 POWER TRANSMISSION AND DISTRIBUTION

Bridging the Gap on Data and Analysis for Distribution System Planning: Information That Utilities Can Provide Regulators, State Energy Offices and Other Stakeholders

Electric utilities conduct planning annually to ensure their distribution system meets technical standards, policies, and regulations; addresses forecasted grid conditions; satisfies customer needs; and advances utility priorities. The plan identifies grid deficiencies, analyzes potential solutions, and prioritizes capital investments and other expenditures. About 20 U.S. states and jurisdictions require regulated utilities to file some type of distribution system plan with the public utility commission for review. Requirements for sharing distribution system data and analyses vary widely, from few specific requirements to a detailed list of information that must be provided. While utilities conduct extensive analysis to develop distribution system plans, in most jurisdictions regulators and stakeholders do not know what data are available and how the utility uses the data in planning and investing. This report aims to bridge the gap by increasing understanding of the types of data and analyses utilities employ to develop distribution system plans and how the information affects their decision-making. The report describes information that states and stakeholders can ask for related to 11 data categories: -Forecasting loads and distributed energy resources (DERs) -Scenario analysis -Worst-performing circuits -Asset management strategy -Hosting capacity analysis -Value of DERs -Grid needs assessment -Cost-effectiveness framework for investments -Distribution system investment strategy and implementation -Geotargeted programs -Non-wires alternatives procurements.

24 POWER TRANSMISSION AND DISTRIBUTION

Data-driven Community-centered Resilient Assessment and Planning Toolkit for Nexus of Energy and Water (DCRAPT-NEW)

Urban areas, including Detroit and Pittsburgh, have suffered significant dual outages of the electrical and water infrastructure in the past decade due, in part, to the increasing number of extreme weather events. With increasing temperatures and rainfall intensity, these regions need to prepare for increasing extreme events through community-based energy and water resilience analysis, planning, and enhancement. This project developed a suite of open-source, open-access, community-centered, data-driven assessment and distributed energy resource (DER) and planning tools for energy and water resilience enhancement in urban areas. Through establishing a multi-level community awareness and engagement mechanism and a comprehensive collection of power outage and flooding data, an innovative group of community energy and water resilience assessment and planning tools have been developed for a wide range of users with differing and variable sets of data available to them. The developed tools include (1) DOE EAGLE-I data-driven, deep-learning assisted resilience assessment and DER planning tools at the county level with socioeconomic factors incorporated; (2) Utility annual power outage data-driven tools for long term resilience assessment and DER planning and 15-min power outage data-driven tools for short term resilience assessment and planning; (3) Detailed engineering tools for energy and water systems resilience assessment and planning when the system topology and component fragility curves are available; (4) Alternative Resiliency Metric Calculation that extracts and separates outage and restoration processes; and (5) Co-optimization tools that evaluate the resilience of the power and sewage system and allow users to conduct joint planning with energy and wastewater systems. The developed tools provide planners, decision-makers, and stakeholders with powerful capabilities to systematically evaluate system/community resilience and optimal and actionable guidance for enhancing resilience while prioritizing DER investments. The tools have been used and validated in Detroit and Pittsburgh and can be used in other areas of the nation. In addition, this project will (1) advance the knowledge and applications of machine-learning methods in analyzing and fusing different layers of information and generating meaningful data points such as generating rare weather events; (2) significantly improve the energy and water resilience of the identified communities in Detroit and Pittsburgh and prepare for more frequent and severe weather conditions; (3) help communities assess extreme weather event impacts and address short-term and long-term resilience-related issues The developed tools have been made public via GitHub and demonstrated to community stakeholders and utility companies via the two annual workshops and numerous community engagement meetings. The project outcomes are also disseminated through publications in various journals and conference proceedings, and presentations at top conferences.

13 HYDRO ENERGY

Weather-Driven Resilience for Distribution Systems

With increasing billion dollar disasters due to weather events, it is of utmost priority for utility and grid operators to maintain and enhance the resilience of distribution grid. Traditionally, such analysis were conducted with reliability metrics alone. However, with increasing complexity of distribution grid and advancements in grid edge resources, evaluating grid resilience is challenging and involves multi-faceted analysis of the impact of weather events on the distribution grid. This presentation provides background, details, and future works in the field of weather-driven resilience for power distribution systems.

24 POWER TRANSMISSION AND DISTRIBUTION

Long-Term Impacts of Constrained Transmission Deployment on the Cost-Reliability Tradeoff

Traditional Resource Adequacy (RA) frameworks in the U.S. undervalue the contributions of inter-regional transmission to resource adequacy during stress periods, focusing on the availability of nameplate capacity instead. However, availability of nameplate capacity does not always translate into electricity delivery, especially during tail events. Moreover, the rapid deployment of energy-limited resources and increasing electricity demand challenge existing resource adequacy frameworks and couple regional electricity demand and availability of supply via transmission. We propose a two-stage framework that goes beyond the existing capacity-centered approaches to reveal the RA contributions of transmission. In the first stage we introduce a multi-objective optimization framework to quantify the merits of transmission expansion via Pareto Frontiers under alternative futures of no transmission investment, primary energy resources availability and demand growth. The second stage focuses on tail events and leverages the results of the first stage to characterize the risk profile of regional consumers across the U.S. under the alternative energy futures. We find that no new transmission can lead to a more expensive and less reliable national grid across scenarios, however, the impact on regional RA can vary. The probabilistic analysis reveals that transmission investments can alleviate the tail risk of consumers, however, the availability of fuel resources does not always alleviate regional tail risks. Our findings inform policymakers and utilities on the prioritization of transmission investments to mitigate the risk of widespread outages, also for tail events, and ensure reliable and affordable electricity delivery to all.

24 POWER TRANSMISSION AND DISTRIBUTION

Lessons Learned from the Clean Energy to Communities (C2C) Peer-Learning Cohort Evaluating and Prioritizing Municipal Buildings for Energy Efficiency and Decarbonization Investment

The National Renewable Energy Laboratory (NREL), with support from World Resources Institute (WRI), designed and led a six-month peer-learning cohort from January through July 2024 on "Enhancing Resilience at Critical Facilities through Solar, Storage, and Microgrids" as part of the U.S Department of Energy's Clean Energy to Communities (nrel.gov/c2c) (C2C) program. Representatives from 15 municipalities, municipal utilities, colleges, and Tribes from across the United States participated in monthly workshops covering best practices for planning and deploying local resilience projects. This document shares key takeaways, lessons learned, and resources from the cohort.

buildings

Recycling Wind Energy Systems in the United States Part 1: Providing a Baseline for America's Wind Energy Recycling Infrastructure for Wind Turbines and Systems

The U.S. investments in building this new wind energy capacity will not only mobilize millions of tons of raw and processed materials in existing supply chains, some of which are critical materials, but also create new types and large volumes of end-of-life (EOL) waste streams. Building efficient, cost-effective, and environmentally responsible EOL management infrastructure of wind energy system components is pivotal in diverting upcoming volumes of waste stream from landfills, recovery of critical materials and reducing life cycle emissions from production of primary commodity materials . The primary goal of this report is to organize and communicate findings from this assessment on how alternate materials, designs and manufacturing processes could enable more efficient, cost-effective, and environmentally responsible disassembly and resource recovery from wind energy technologies. The findings of this assessment could inform prioritization of RD&D investment spending to meet Energy Act of 2020 directions. This assessment focused on key RD&D recommendations for three main temporal phases: Short-term (2023-2026), medium-term (2026 through 2035) and long-term (beyond 2035).

17 WIND ENERGY

Residential Building Stock Characterization in Palm Beach County, Florida

This building stock characterizations is intended to help Palm Beach County (PBC) Office of Resilience (OOR) and municipalities composing the Municipal Resilience Partnership prioritize building energy efficiency investments to reduce energy costs and increase resilience for the county's most vulnerable residents. The analysis utilizes NREL’s ResStock model to characterize PBC’s residential building stock, including building type, renter/owner status, size (square footage), age of buildings (vintage), HVAC system types, and, for multi-family buildings, number of units. Building energy efficiency, weatherization, and electrification upgrade packages were assessed for approximate cost, customer bill-savings, and emissions reductions potential and findings will help guide OOR financial assistance program design.

32 ENERGY CONSERVATION, CONSUMPTION, AND UTILIZATI

Integration of equitable resilience metrics into climate-informed electric utility planning processes: phase one

Working together, Sandia National Laboratories, Southern California Edison (SCE) - an Investor-Owned Utility (IOU) - and the California Public Utilities Commission (CPUC) are studying how electric utilities can use equity and resilience metrics to help inform the prioritization and sequencing of resilience-driven infrastructure investments. To this end, this project evaluated “Social Burden,” an equitable resilience metric which measures the potential impact of disruptions in access to non-electric critical services on people and estimates community resilience to these disruptions. The Social Burden was expanded to incorporate SCE’s existing equity metric and applied to evaluate the potential impacts from a range of climate-informed hypothetical outage scenarios developed under SCE’s 2022 Climate Adaptation Vulnerability Assessment. One baseline (“blue-sky”) state and eight different outage scenarios were evaluated to measure the potential impacts of the outages on non-electric infrastructure, critical services, and people. Key findings include: 1) the Social Burden framework is flexible enough to adapt to and build upon existing utility equity and/or resilience metrics, 2) Social Burden results highlight the high degree of non-electric service redundancy within the SCE service area with most (6/8) hypothetical outage scenarios predicted to increase people’s Social Burden by less than 10%; however, 3) access to critical services and people’s ability to obtain them is unequal and spatially clustered, meaning that there are some hypothetical outage scenarios (2/8) that will exert a higher toll on communities directly experiencing the outage as well as some nearby communities with pre-existing vulnerabilities. The report concludes with recommendations for potential use cases of the expanded Social Burden metric and identifies priority follow-on work. Potential use cases may include incorporating equity into IOU’s prioritization of climate resilience investments. Additionally, Social Burden analysis may provide additional data and insights to augment grid planning, potentially by identifying additional needs and/or prioritizing previously identified needs.

24 POWER TRANSMISSION AND DISTRIBUTION