The Scaffold Initiative submitted this comment on Colorado's WIOA State Plan Modification for Program Years 2026-2027. The Denver-Boulder-Colorado Springs corridor has become a national hub for aerospace, defense technology, and cybersecurity — industries where AI integration is accelerating across operations and mission-critical systems. Colorado's energy sector is navigating a deliberate transition from fossil fuels to renewables, creating a workforce that needs both traditional competencies and new digital skills, while the state's proactive AI governance legislation further supports the case for embedding AI skills in its workforce development infrastructure. We recommend designating AI literacy as a core workforce competency, integrating AI skills benchmarks into measurable skill gains, partnering with community-based organizations for contextualized training, and exploring waiver authority for AI-readiness pilot programs.
SUBJECT: Public Comment on Colorado WIOA State Plan Modification, Program Years 2026-2027
Submitted by: The Scaffold Initiative | thescaffoldinitiative.org | outreach@thescaffoldinitiative.org
Submitted to: Colorado Workforce Development Council (CWDC)
Date: April 3, 2026
The Scaffold Initiative is a 501(c)(4) social welfare organization incorporated in Wyoming and operating nationally, with organizational leadership based in Memphis, Tennessee and a mission focused on expanding AI and digital workforce readiness for workers facing displacement or barriers to economic mobility. Our Executive Director, Ricky Tucker, is a workforce development practitioner with over 40 years of experience in adult education, business coaching, and career development, based in Memphis, Tennessee.
We commend Colorado for undertaking the PY 2026-2027 State Plan modification and write to offer substantive input on the following priorities established by Training and Employment Guidance Letters 07-25 and 05-25. Colorado's decision to engage in this modification cycle reflects a commitment to aligning its workforce system with evolving federal priorities, and we appreciate the opportunity to contribute to that process.
TEGL 07-25's Pillar V explicitly calls for states to prioritize "AI literacy and skills development across the public workforce system" and create "new models of workforce innovation built to match the speed and scale of AI-driven economic transformation." We urge Colorado to:
Colorado's economy is undergoing a multi-front AI transformation that touches every major sector. The Denver-Boulder-Colorado Springs corridor has become a national hub for aerospace, defense technology, and cybersecurity — industries where AI integration is accelerating across operations, analysis, and mission-critical systems. The state's energy sector is navigating a deliberate transition from fossil fuels to renewables, creating a workforce that needs both traditional energy competencies and new digital skills to operate AI-driven grid management, predictive maintenance, and resource optimization systems. Colorado's tourism and outdoor recreation economy — a significant employer across mountain communities and rural areas — is also encountering AI in hospitality operations, resource management, and visitor services. A deliberate AI skills strategy within the WIOA plan would connect these diverse workforce populations to a common set of digital competencies, ensuring that Colorado workers across the Front Range, Western Slope, and mountain communities all have structured pathways to AI literacy. Colorado's position as a state that has proactively legislated on AI governance further supports the case for embedding AI skills in its workforce development infrastructure.
TEGL 07-25's Pillar II calls for states to integrate "AI-powered tools including comprehensive talent marketplaces composed of comprehensive learner records or learning and employment records solutions, credential registries, and skills-based job description generators." We recommend:
Under TEGL 05-25's waiver framework, Colorado has authority to request waivers that enable innovative AI-readiness pilot programs. We specifically recommend Colorado explore a waiver allowing On-the-Job Training (OJT) reimbursement to extend to AI skills roles in non-traditional settings, consistent with TEGL 05-25's encouragement to raise OJT reimbursement caps and expand incumbent worker training.
The Scaffold Initiative is developing capacity to serve as a community partner in implementing AI and digital literacy training integrated with public workforce systems nationwide. As a nationally operating organization, we are committed to building capacity in service of Colorado's workforce goals. We offer:
We welcome the opportunity to engage further with the Colorado Workforce Development Council.
Respectfully submitted,
Ricky Tucker
Executive Director, The Scaffold Initiative
outreach@thescaffoldinitiative.org
thescaffoldinitiative.org
Three priority recommendations: designating AI literacy as a core competency eligible for ITA funding, including AI/digital skills in measurable skill gains reporting, and partnering with community-based organizations that provide contextualized AI training for adult learners, dislocated workers, and youth.
Colorado faces a multi-front AI transformation. The Denver-Boulder-Colorado Springs corridor is a national hub for aerospace, defense technology, and cybersecurity where AI integration is accelerating. The state's energy sector is transitioning from fossil fuels to renewables, requiring new digital skills for AI-driven grid management and predictive maintenance. Tourism and outdoor recreation — a significant employer across mountain communities — is also encountering AI in hospitality and visitor services.
Under TEGL 05-25, Colorado could request waivers allowing On-the-Job Training reimbursement to extend to AI skills roles in non-traditional settings, raise OJT reimbursement caps, and expand incumbent worker training programs.
Curriculum and facilitation for AI/digital skills training aligned to employer demand, train-the-trainer capacity for Workforce Center staff, and partnership development with regional employers to validate competencies and create hiring pipelines.