FE RC ?1 ll "1 Human; {farmerly rm: ?y n: 9:31.: E-n'nail this gage File List Number: Desurlptign: Enmrne-nt of Elaavar County Commission am under Fin-1134. Type Flle Name Elze FEHC are: 315223 Ni:- ciescripi gin-en FE Fill [Fe-n Hated FIB-F ?25:32:? CIEPDF F535 iJ-zn: I'fzu Pd: Uta-ruled Ileana-t Help Funny lama FEED Fianna mummum 20171020121445839 . FE RC 0 WE eLibrary (formerly FERRIS) of: 2:1 mgg?L; E-rna this gage ACCESSION Number: File List 20171013-5080 Comment of EIarIlon-CaerII-Salem School DisL'ict ur?der RM1B-1. Type Flle Name 5le PDF Lane 10 FE RC PDF 495616? le11er to FERC FERC Generated PDF 25E BSPD: 496018? iJcc I'fo Ade 1c -J.ec:..est IJcn'e'Lsacl Izeset Helu Dr call mam-35m. FunnlengFERGOnllna Hamel]! udaanmmt Benton-Carroll-Salem Local School District fl community irjuafgeJEy t/ie sc?oolk it Keeps. 11685 West State Route 163 - Oak Harbor, Ohio 43449 419-898-6210 - October 19, 2017 Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: Grid Resiliency Pricing Rule FERC Docket No. RM18-1-000 COMMENTS OF THE BENTON-CARROLL-SALEM LOCAL SCHOOL DISTRICT IN SUPPORT OF THE PROPOSED RESILIENCY RULE I have been serving as the Superintendent of the Benton?Carroll-Salem Local School District for the past 5 years. In that time, I have come to understand important relationship between the strength of a region?s economy and the need for a robust and reliable electricity grid to maintain our economy and help it grow. This critical linkage has become even more crucial given the recent catastrophic events (such as severe storms) that have adversely impacted our region?s electricity grid. Now, more than ever, it is essential that all prudent steps be taken to ensure that our region?s economy and electricity grid are suf?ciently bolstered to withstand such events. It is with background that I write with a sense of urgency to address a recent proposal issued by the Department of Energy that most of our school district community and I whole-heartedly support. On September 28, 2017, the DOE issued the ?Grid Resiliency Pricing Rule? (the ?Proposal?) directing the Federal Energy Regulatory Commission to adopt a rule requiring operators of organized markets to ?ensure that certain reliability and Guy L. Parmigian, Cajon H. Keeton Superintendent Treasurer Benton-Carroll-Salem Local School fl community zsjudgecf?y t/ie sc/ioofr it Keeps. 11685 West State Route 163 - Oak Harbor, Ohio 43449 419-898-6210 - resiliency attributes of electric generation sources are fully valued.? Such a rule, as contemplated by the regulatory language of the Proposal, will ensure that existing nuclear and coal-?red electric generating stations, including those in Ottawa County, Ohio will be compensated appropriately and fully for their costs of operation and will avoid premature retirement. Adoption of that rule will sustain the regional economy, enhance reliability and resiliency, assist in reducing harmful emissions, and help avert the ?nancial distress affecting certain coal and/or nuclear power plants in Ottawa County, Ohio that may be retired prematurely if the Proposal is not adopted. Hence, I strongly support the Proposal and share the Secretary?s urgency that FERC act to direct operators of organized markets to issue the requested rule. FERC has the ability to act, and must act, without undue delay to avoid premature closure of crucial power plants and my communities loss of critical economic and reliability bene?ts. FERC has thoroughly examined how electric markets function and how those markets affect the continued operation of crucial power plants needed for reliability for some time. FERC has the requisite basis to act now. There is no time for delay. In addition to acting FERC should also direct organized market operators to issue a comprehensive and enduring set of rules, based on the regulatory language of the Proposal, for the proper compensation of critical power plants. Protracted proceedings undertaken by organized market operators that fail to develop fair, compensatory and transparent rules will only engender market uncertainty and delay in providing suf?cient compensation to these facilities, thereby jeopardizing the operation of the very plants that the DOE seeks to maintain in operation. Guy L. Parmigian, Cajon H. Keeton Superintendent Treasurer Benton-CarroII-Salem Local School District fl community isjucfgerf?y t?e it Keeps. 11685 West State Route 163 Oak Harbor, Ohio 43449 419-898-6210 1. COMMUNICATIONS A11 communications, correspondence, and documents related to this proceeding should be directed to the following person: Guy L. Parmigian, Superintendent Benton-Carroll?Salem Local School District 11685 West State Route 163, Oak Harbor, OH 43449 Phone: (419) 898-6210 Email: II. DESCRIPTION OF LOCAL SCHOOL DISTRICT AND INTEREST IN PROCEEDING The Benton?Carroll-Salem Local School District is an Ohio public school district located in Ottawa County, Ohio who serves 1,500 students in grades The District employs approximately 220 individuals. We are a top performing school district who is ranked in the Top 30 school districts in the state based on our performance on the 2017 A School District Report Card. The Davis?Besse Nuclear Power Station owned by First Energy is located in my school district, and provides more than 1,000 of direct and indirect jobs within our school district as well as millions of dollars in tax revenues that support local governments. The premature retirement of Davis?Besse Nuclear Power Station due to the failure of wholesale power markets in valuing key attributes, such as resiliency, will have a direct impact jobs and tax base in the community I work in. Therefore I, in my of?cial capacity as Superintendent of the Benton-Carroll-Salem School District, have a direct and substantial interest in this proceeding. COMMENTS Guy L. Parmigian, Cajon H. Keeton Superintendent Treasurer Benton-Carroll-Salem Local School fl community zlsjucfged'Ey tlie sc?oo?s it lieeps. 11685 West State Route 163 - Oak Harbor, Ohio 43449 419-898-6210 - A. The Premature Retirement of Davis-Besse Nuclear Power Station Will Have a Signi?cant Economic Impact in the Benton-Carroll-Salem Local School District My fellow community members not only work at the subject plants, but they also work for companies that supply an array of goods and services to the generation facilities that are at risk of closure. In addition, they are employed on major infrastructure and industrial development projects that are dependent on the continued operation of the baseload nuclear power plants. As a result, the wages, terms and conditions of employment of my fellow community members will be directly affected by the closure of these plants. Simply put, many in our community will lose their jobs, thereby further worsening an economy that has already been hampered by a struggling power industry. The recent decline in the electric power industry, for example, has led to reductions in operations and capital improvement expenditures at numerous power production and manufacturing facilities across Ohio. This has led to extreme hardship for my fellow community members employed in this industry as well as their families. It is imperative that baseload nuclear plants continue to operate in light of these dire circumstances. Not only do these coal and nuclear plants provide jobs and economic opportunities for our community, they also generate signi?cant tax revenues that bene?t the municipal entities throughout my region. These entities provide essential services to my community such as education, ?re protection and police. If these generation facilities are forced to retire, an already weak recovery will be hampered, more people will lose their jobs, municipal services will deteriorate, and more families will suffer economic pain and burdens. The impact on the region?s economy will be severe. Guy L. Parmigian. Cajon H. Keeton Superintendent Treasurer Benton-Carroll-Salem Local School community zkjutfged?y tlie sc?ooB it keeps. 11685 West State Route 163 - Oak Harbor, Ohio 43449 419-898-6210 - B. Resilient Nuclear Power Plants Support Reliability In addition to helping to avert an economic catastrophe, the issuance of a rule preserving the continued operation of resilient baseload nuclear power plants will maintain a reliable supply of electricity for the region?s energy-intensive economy in two ways. First, the preservation of certain plants will avoid the need to replace lost generation with imports and the associated construction of infrastructure to facilitate such importation. Preserving baseload nuclear power plants will keep these needed, reliable facilities running close to home without the need to depend on distant resources, particularly during catastrophic events like severe storms, to ful?ll our region?s dynamic need for reliable electricity. Second, premature plant closures will deplete the stable of highly skilled (and speci?cally trained and experienced) employees, many of whom have lived in the region for several years and who take great pride in their work. With a depletion of this skilled and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, utilities will see a direct and adverse impact on their ability to maintain the generation facilities that continue to operate and, as important, their ability to respond to severe contingencies affecting the operation of these remaining plants in operation. In short, allowing baseload nuclear power plants to close prematurely will have an adverse impact on the reliability of the region?s electricity supply and on the reliable operation of the regional electricity system. C. The Proposed Rule Will Preserve the Environmental Bene?ts of Zero- Emission Nuclear Power Plants Guy L. Parmigian, Cajon H. Keeton Superintendent Treasurer Benton-Carroll-Salem Local School )4 community is judged 6y t/ie sc?ools it Keeps. 11685 West State Route 163 - Oak Harbor, Ohio 43449 419-898-6210 - In addition to providing a dependable source of electricity and critical economic support, nuclear-fueled generating stations are bene?cial to the environment. The reliance on nuclear generation capacity prevents the emission of hundreds of millions of tons of greenhouse gases such as carbon dioxide, sulfur dioxide, and nitrous oxide that might otherwise be produced if natural gas-?red and coal-?red generation was used instead to maintain the reliability of the interstate power grid. Operators of other types of emission?free generating facilities, such as wind and solar-powered facilities, receive substantial ?nancial support through production tax credits and compensation for renewable energy credits that is not available to most nuclear?fueled generators. Although both New York and Illinois have recognized the environmental bene?ts to be derived from continued reliance on nuclear-fueled generating facilities, and provide ?nancial support to maintain operation of those generation facilities in their states through the sale of Zero Emission Credits, the State of Ohio has not yet established a similar means of compensating nuclear power plants for their environmental attributes. The Proposal for the FERC to require operators of organized markets to compensate owners of nuclear-powered generating stations fully for the costs of owning and operating their generation facilities would put all such emission-free generating stations on an even footing. More importantly, it would recognize the value of the reliability and resiliency attributes of nuclear?fueled generating stations that help to protect the bulk power supply system from disruptions. D. The Commission Must Act Posthaste to Prevent the Premature Retirement of Resilient Baseload Nuclear Power Plants Guy L. Parmigian, Cajon H. Keeton Superintendent Treasurer Benton-Carroll-Salem Local School District fl community is judged 6y t?e 5050013 it Keeps. 11685 West State Route 163 - Oak Harbor, Ohio 43449 419-898-6210 - In order to mitigate the risk that such generating units may be deactivated prematurely, I strongly urge FERC to adopt the rule proposed by the DOE as and comprehensively as possible. FERC has a suf?cient record to act that will be further bolstered by the comments considered in this proceeding. FERC has thoroughly considered the impact of electric markets on the sustained operation of at-risk power plants and, as noted by the Secretary of the DOE, the time to act is now given the severe impacts to system reliability and resilience, and national security, attendant to the premature closure of crucial power plants. Any protracted delay in creating fully compensatory market rules will only exacerbate the problem of pre?mature closures. In acting FERC should also direct the organized market operators to issue a rule that is not only compensatory (and based on the regulatory language of the Proposal) but comprehensive and enduring. The rules to be issued by operators of organized markets should be fair and transparent, and should ensure that critical power plants can continue to operate for the long-term and without the prospect of repeated re- examination and adjustment to their market compensation. The uncertainty that less than comprehensive and enduring market rules will engender will defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, af/a??t Guy L. Parmigian, .D. Superintendent Benton-Carroll-Salem Local School District Guy L. Parmigian, Cajon H. Keeton Superintendent Treasurer FE RC WIIWE eLibrary (formerly FERRIS) 2" I E-"na' his gage File List Accesslon Number: 201T1027-0EH2 Comments of the City of Belmont in supper! of the proposed Resil'mr'cy Rule unaar RN11 3-1. Type Flle Name 5le FERC Generate: PDF .2514241_p3; 19929? laugh: Bun-l All |?age Range From To AI hone Page 1 28-176 Page 2 21?451 Page 3 Ada 1: Jet: nest Ucw Load IZeset F??nj' Muse milling FERC Onllna. plasma mummuwl 886?203-3533. 20171027-0042 FERC PDF (Unofficial) 10/26/2017 ORIGINAL FlLE9 SECS'Agy PF IIIE COI"NISSfpII October 23, 2017 Re: P ~OCt'2b Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington, DC 20426 NRULAi Oa V FERC Docket No. RM18-1-000 COMMENTS OF THE CITY OF BELMONT IN SUPPORT OF THE PROPOSED RESILIENCY RULE Belmont City Council for the last three years. In that time, I have seen dramatic changes in the economy the strength of a region's economy of Belmont and the important relationship and the need for a robust and reliable between electricity grid to our economy and help it grow. This critical linkage has become even more crucial maintain given the recent catastrophic events (such as severe storms) that have adversely impacted our region's electricity grid. Now, more than ever, it is essential that all prudent steps be taken to ensure that our region's economy and electricity grid are sufficiently bolstered to withstand events. It is with background issued by the Department that I write with a sense of Energy ("DOE") that most of urgency such to address a recent proposal of my constituents and I whole-heartedly support. 28, 2017, the DOE issued the "Grid Resiliency Pricing Rule" (the On September "Proposal" ) directing the Federal Energy Regulatory of organized markets requiring operators attributes of electric generation sources are of Commission ("FERC") to adopt a to "ensure that certain reliability rule and resiliency fully valued." Such a rule, as contemplated by the and coal-fired electric the Proposal, will ensure that existing nuclear regulatory language generating stations, including those in Pleasants County will be compensated appropriately Ie CPil"NiSSIOII Grid Resiliencv Pricina Rule I have been representing & and 20171027-0042 FERC PDF (Unofficial) 10/26/2017 fully for their costs the regional sustain of operation and will avoid premature enhance economy, reliability retirement. and resiliency, of that Adoption rule will assist in reducing harmful emissions, and help avert the financial distress affecting certain coal and/or nuclear power plants in the Pleasants County, West Virginia, Belmont that may be retired prematurely if the Proposal is not adopted. Hence, I strongly support the Proposal and share the Secretary's urgency that FERC act to direct operators of organized markets to issue the requested promptly ability to act, and must act, without undue delay to avoid premature plants and thoroughly operation my constituents loss of critical economic rule. FERC has the closure of crucial power and reliability benefits. FERC has examined how electric markets function and how those markets affect the continued of crucial power plants needed for reliability for some time. FERC has the requisite basis to act now. There is no time for delay. In addition to acting promptly, FERC should also direct organized market operators to issue a comprehensive of rules, the regulatory Protracted language proceedings compensatory of the Proposal, for undertaken by organized market operators to these facilities, thereby jeopardizing set based on of critical power the proper compensation plants. that fail to develop rules will only engender market uncertainty and transparent sufficient compensation and enduring fair, and delay in providing the operation of the very plants that the DOE seeks to maintain in operation. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: R. J. Fitzpatrick Mayor City of Belmont P 0 Box 375, Belmont, WV 26134 304-665-2160, btwv218mainyahoo.corn 20171027-0042 FERC PDF (Unofficial) 10/26/2017 II. DESCRIPTION OF CITY OF BELMONT AND INTEREST IN PROCEEDING R. J. Fitzpatrick is an electedofficial City of Belmont. The First provides hundreds of direct Power is located in my district, and Energy owned by Appalachian and indirect jobs for my constituents, tax revenues that support local governments. the failure of wholesale power markets for Governing of the in Belmont that is responsible The premature retirement in valuing key attributes, direct impact jobs and tax base in the community of dollars in as well as millions of First Energy due to such as resiliency, will have a I represent. Therefore I, in my official capacity as Mayor, have a direct and substantial interest in this proceeding. III. COMMENTS A. The Premature Retirement of First Energy Will Have a Significant Economic Impact in Pleasants County My constituents that supply an array not only work at the subject plants, but they also work for companies of goods and services to the generation facilities that areat risk addition, they are employed on major infrastructure dependent on the continued operation and industrial thereby further worsening power industry. reductions plants. Simply put, many of my constituents of my constituents and capital improvement expenditures facilities across Pleasants County. of my constituents employed in this industry will be directly will lose their a weak economy that has already been hampered The recent decline in the electric power industry, in operations and manufacturing hundreds of these projects that are development of the baseload coal power plants. Over 4 million Dollars. As a result, the wages, terms and conditions of employment affected by the closure of closure. In by a struggling for example, at numerous has led to power production This has led to extreme hardship as well as their families. jobs, for the 20171027-0042 FERC PDF (Unofficial) 10/26/2017 It is imperative Not only circumstances. opportunities constituents throughout to operate in light of these dire coal plants continue coal and nuclear do these for my constituents, entities municipal that baseload they also generate my region. significant These entities tax revenues that benefit the provide If these such as education, fire protection and police. jobs and economic provide plants essential services to my generation facilities are forced to retire, an already weak recovery will be hampered, more people will lose their jobs, municipal services will deteriorate, and more families will suffer economic pain and burdens. The impact on the region's economy will be severe. B. Resilient Coal Power Plants Support Reliability In addition to helping to avert an economic catastrophe, the issuance the continued operation of resilient baseload coal electricity for the region's energy-intensive plants of inf'rastructure depend on distant resources, particularly facilities running vidth imports Preserving of of economy in two ways. First, the preservation to facilitate such importation. will keep these needed, reliable preserving power plants will maintain a reliable supply certain plants will avoid the need to replace lost generation construction of a rule and the associated baseload coal power close to home without the need to during catastrophic events like severe storms, to fulfill our region's dynamic need for reliable electricity. Second, premature plant closures will deplete the stable of highly skilled (and specifically trained and experienced) employees, many of whom have lived in the region for several years and who take great pride in their work. With a depletion workers, and the possible replacement skilled individuals, of these of this skilled and experienced group workers with more distant and perhaps of less- utilities will see a direct and adverse impact on their ability to maintain the generation facilities that continue to operate and, as important, their ability to respond promptly 20171027-0042 FERC PDF (Unofficial) 10/26/2017 to severe contingencies affecting the operation of these baseload coal power plants to close prematurely allowing reliability of the region's electricity plants in operation. In short, remaining will have an adverse impact on the and on the reliable supply operation of the regional electricity system. C. The Proposed Rule Will Preserve the Environmental Nuclear Power Plants In addition to providing a dependable nuclear-fueled generation generating source of electricity and critical economic support, The reliance on nuclear stations are beneficial to the environment. of hundreds of millions of tons of greenhouse gases capacity prevents the emission dioxide, sulfur dioxide, and nitrous oxide that might otherwise be produced if such ascarbon natural Benefits of Zero-Emission gas-fired and coal-fired generation was used instead to maintain the reliability of the interstate power grid. Operators powered receive substantial facilities, compensation generators. of other types of emission-free generating facilities, such as wind and solar- for renewable Although financial credits energy support through is not available that support to maintain operation of those Emission Credits, the State of has not power plants for their environmental generating to most nuclear-fueled and operating benefits to facilities, and provide financial generation facilities in their states through the sale yet established attributes. a similar means their generation stations on an even footing. of compensating of Zero nuclear The Proposal for the FERC to require operators of organized markets to compensate owners of nuclear-powered generating tax credits and both New York and Illinois have recognized the environmental be derived from continued reliance on nuclear-fueled costs of owning production generating stations fully for the facilities would put all such emission-free More importantly, it would recognize the value of the 20171027-0042 FERC PDF (Unofficial) 10/26/2017 reliability and resiliency attributes of nuclear-fueled generating stations that help to protect the bulk power supply system from disruptions. D. The Commission Must Act Posthaste to Prevent the Premature Resilient Baseload Coal Power Plants Retirement of In order to mitigate the risk that such generating units may be deactivated prematurely, strongly urge FERC to adopt the rule proposed by the DOE as promptly and comprehensively I as possible. FERC has a sufficient record to act that will be further bolstered by the comments considered in this proceeding. FERC has thoroughly the sustained operation of at-risk power considered the impact attendant creating fully closure to the premature market compensatory of the DOE, plants and, as noted by the Secretary time to act is now given the severe impacts to system reliability security, of electric markets on of and resilience, and national crucial power plants. Any protracted rules will only exacerbate the problem the delay in of pre-mature closures. In acting promptly, FERC should also direct the organized market operators to issue a rule that is not only compensatory comprehensive and enduring. The rules to be issued by operators fair and transparent, engender language of the Proposal) but of organized markets should be and should ensure that critical power plants can continue to operate for the long-term and without the prospect compensation. (and based on the regulatorv The uncertainty of repeated re-examination that less than comprehensive will defeat the very purpose and adjustment and enduring to their market market rules will of preserving the extended operation of these much- needed power plants. Respectfully submitted, R. J. Fitzpatrick Mayor City of Belmont 20171027-0042 FERC PDF (Unofficial) 10/26/2017 Document Content(s) 14725651.tif..........................................................1-6 FE RC 0 7? WE eLibrary (formerly FERRIS) eroggov E-"na his gage File List A: SESSION Number: 201710236372 Comment of COUNTY BOARD OF COMMISSIONERS urder RIMS-1. Type Flle Name 5le PDF FERC Docm'uents - Ouawa Comtg PDF 357399 No cescripl or given FERC Gen eratec? PDF 93395 Dec I'fo Ade 1c -J.ec:..est Danni?Luau lie-set Help Flal'lmz.I lawns FERG Onllna. plasma ass-ma?a. OTTAWA COUNTY BOARD OF COMMISSIONERS MARK E. COPPELER JAMES M. SASS MARK W. STAHI. 419-734-6111? 419-734-6705 419-?34-6706 COUNTY ADMINISTRATORICLERK RHONDA SLAUTEHBECK 41 9-734-6729 Main Office: 41 9-734-6710 October 23, 2017 Neil Chatterjee, Chairman Cheryl A. LaFleur, Commissioner Robert F. Powelson, Commissioner Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Dear Mr. Chairman and Commissioners: Please accept this letter as formal acknowledgement and gratitude to the Department of Energy and the Federal Energy Regulatory Commission for commencing a rulemaking proposal for your consideration and final action to help ensure a secure, resilient and reliable electric grid that is important to our nation. The grid system is threatened by the premature retirement of power plants that can withstand fuel supply disruptions caused by man-made and natural disasters. These fuel-secure baseload resources can support the energy demands of customers, businesses and industries in critical times. Such rule under your consideration would ensure our nation has access to resilient, reliable and affordable electricity that is essential to drive our economy, security and quality of life. However, our energy sector has reached a grave point in which due to current market rules that prioritize short term market conditions, we do not properly value the range of benefits that baseload power plants offer. The current short term market conditions are allowing the closing of long term strategic assets prematurely. Our community in Ottawa County would certainly feel the devastation if the Davis?Besse Nuclear Power Plant were to terminate operations. These facilities are regional economic engines that provide thousands of jobs not only at the generating facilities and throughout their supply chains, but also in the shops, restaurants, lodging, entertainment venues and other business that call Ottawa County home. in addition, local schools, police and fire departments and other vital community services rely heavily on tax revenues paid by these plants. 315 Madison Street, Room 103 - Port Clinton. Ohio 43452-1993 - 800-?88-8803 Ottawa County Residents - tam 419-734-6898 numenmtlawamhats Developing and implementing market rules that appropriately compensate fuel?secure baseload generating plants is a logical way of addressing this issue and Federal Energy Regulatory Commission?s action must be finalized immediately to prevent additional plant closures. America's energy future depends on preserving the diverse, resilient, dependable and secure electricity supply provided by baseload generation. Ottawa County certainly appreciates your commitment on this matter and respectfully urges your swift action to develop and implement equitable market rules that will prevent premature baseload plant closures, consistent with rules and regulations of the Federal Energy Regulatory Commission pursuant to your authority under the Federal Power Act. Respectfully, Mark W. Stahl, Pr ident Ottawa County Board of Commissioners OTTAWA COUNTY BOARD OF COMMISSIONERS MARK E. COPPELER JAMES M. SASS MARK W. STAHL 419-734-6707 419-734-6705 COUNTY ADMINISTRATORKCLERK RHONDA SLAUTERRECK 41 9-734-6720 Main Office: 419-734?671 0 October 23, 20W Neil Chatterjee, Chairman Cheryl A. LaFleur, Commissioner Robert F. Powelson, Commissioner Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Re: Grid Resiliency Pricing Rule FERC Docket No. COMMENTS OF THE OTTAWA COUNTY BOARD OF COMMISSIONERS IN SUPPORT OF THE PROPOSED RESILIENCY RULE I have been representing. the Ottawa County Board 01? Commissioners in Port Clinton, Ohio over a period ofsix (6) years. [n that time, I have seen dramatic changes in the economy of Ottawa County in Northwest Ohio and the important relationship between the strength of a region?s economy and the need for a robust and reliable electricity grid to maintain our economy and help it expand. This critical linkage has become even more crucial given the recent catastrophic events (such as severe storms) that have adversely impacted our region?s electricity grid. Now, more than ever, it is essential that all prudent steps be taken to ensure that our region?s economy and electricity grid are suf?ciently bolstered to withstand such events. It is because of this, there is a sense of urgency to address a recent proposal issued by the Department of Energy 315 Madison Street. Room 103 - Purl Clinton. Ohio 43452-1093 . 800-?88-8803 Ottawa County Residents - fax: 419-734-6898 numeoeltawamhms On September 28, 2017, the DOE issued the ?Grid Resiliency Pricing Rule? (the ?Proposal?) directing the Federal Energy Regulatory Commission to adopt a rule requiring operators of organized markets to ?ensure that the reliability and resiliency attributes of generation with on-site fuel supplies are fully valued and in particular to exercise its authority to develop new market rules that will achieve this urgent objective.? Such a rule, as contemplated by the regulatory language of the Proposal, will ensure that existing nuclear and coal-?red electric generating stations, including those in Ottawa County, Ohio will be compensated appropriately and fully for their costs of operation for certain eligible units physically located within the Commission-approved organized market and will avoid premature retirement. Adoption of that rule will sustain the regional economy, enhance reliability and resiliency, assist in reducing harmful emissions, and help avert the ?nancial distress affecting the nuclear power plant in Ottawa County, Port Clinton, Ohio that may be retired prematurely if the Proposal is not adopted in a timely manner. Hence, I strongly support the Proposal and share the Department of Energy Secretary?s urgency that the FERC act to direct operators of organized markets to issue the requested rule. FERC has the ability to act, and must act, without undue delay to avoid premature closure of crucial power plants and our constituents loss of critical economic and reliability bene?ts. FERC has thoroughly examined how electric markets function and how those markets affect the continued operation of crucial power plants needed for reliability for some time. FERC has the requisite basis to act now. There is no time for delay. In addition to acting FERC should also direct organized market operators to issue a comprehensive and enduring set of equitable rules, based on the regulatory language of the Proposal, for the proper compensation of critical power plants. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Mark W. Stahl, President Ottawa County Board of Commissioners 315 Madison Street, Room 103, Port Clinton, OH 43452 419-734-6710 mstahl@co.ottawa.oh.us II. DESCRIPTION OF OTTAWA COUNTY BOARD OF COMMISSIONERS AND INTEREST IN PROCEEDING Mark W. Stahl is an elected of?cial in Ottawa County, Ohio who as a member of a three (3) member Board that is responsible for the general administrative body for county government. Commissioners can perform those duties which are speci?cally authorized by the General Assembly and no more. They are the county government taxing, budgeting, appropriating, and purchasing authority. They hold title to county property. Individual commissioners have no power to act independently. All formal and of?cial actions must be taken by the board of county commissioners acting as a body by majority or unanimous vote. Commissioners also have a myriad of other responsibilities including hearing and ruling on annexations, approving drainage improvements through the petition ditch process, establishing water and sewer districts and making improvements, and providing for solid waste disposal. Commissioners also appoint department heads of of?ces for which they have responsibility and also appoint members to a variety of boards and commissions, and also serve on some boards such as the board of revision, the county records commission, and the planning commission. Commissioners must work with all other county elected of?cials to assure that they are properly funded to perform their statutory duties. But it is the non-statutory duties of county commissioners that make them different from other county elected of?cials. By necessity, county commissioners must take a broad view of actions necessary to make the county a better place to live and work. Many commissioners are thus active in promoting public/private partnerships in human services, economic development, health, and infrastructure development. Other commissioners take an active role in improving the environment, promoting job training programs, and improving agriculture in their counties. County commissioners must be astute and have good business sense. Perhaps the most important attribute of a county commissioner is the ability to lead, to listen to the needs of the citizens and other elected of?cials, to compromise, and to develop a consensus on priority issues to improve the county. The Davis-Besse Nuclear Power Plant is located in Ottawa County, Ohio, and provides thousands of direct and indirect jobs for our constituents, as well as, millions of dollars in tax revenues that support local governments, a school district, and various non-pro?t agencies. The premature retirement of the Davis-Besse Nuclear Power Plant due to the failure of wholesale power markets in valuing key attributes, such as resiliency, will have a direct impact on jobs and the tax base in the community we represent. Therefore I, in my of?cial capacity as President of the Board of Ottawa County Commissioners, have a direct and substantial interest in this proceeding. COMMENTS A. The Premature Retirement of the Davis-Besse Nuclear Power Plant Will Have a Signi?cant Economic Impact in Ottawa County, Ohio. Our constituents not only work at the subject plant, but they also work for companies that supply an array of goods and services to the generation facilities that are at risk of closure. In addition, they are employed on major infrastructure and industrial development projects that are dependent on the continued operation of the baseload nuclear power plants. As a result, the wages, terms and conditions of employment of our constituents will be directly affected by the closure of this plant. Simply put, many of our constituents will lose theirjobs, thereby hindering an economy that has already been hampered by a struggling power industry. It is imperative that baseload nuclear plants continue to operate in light of these dire circumstances. Not only do these nuclear plants provide jobs and economic opportunities for our constituents, they also generate signi?cant tax revenues that bene?t the entities throughout our region. These entities provide essential services to our constituents such as education, ?re protection and police. If these generation facilities are forced to retire, people will lose their jobs, services will deteriorate, and families will suffer economic pain and burdens. The impact on the region?s economy will be severe. B. Resilient Nuclear Power Plants Support Reliability. In addition to helping to avert an economic catastrophe, the issuance of an equitable rule preserving the continued operation of resilient baseload nuclear power plants will maintain a reliable supply of electricity for the region?s energy-intensive economy in two ways. First, the preservation of certain plants will avoid the need to replace lost generation with imports and the associated construction of infrastructure to facilitate such importation. Preserving baseload nuclear power plants will keep these needed, reliable facilities running close to home without the need to depend on distant resources, particularly during catastrophic events like severe storms, to fulfill our region?s dynamic need for reliable electricity. Second, premature plant closures will deplete the resource of highly skilled (and speci?cally trained and experienced) employees, many of whom have lived in the region for several years and who take great pride in their work. With a depletion of this skilled and experienced group of workers, and the possible replacement of these workers with more distant individuals, utilities will see a direct and adverse impact on their ability to maintain the generation facilities that continue to operate and their ability to respond to severe contingencies affecting the operation of these remaining plants in operation. In short, allowing baseload nuclear power plants to close prematurely will have an adverse impact on the reliability of the region?s electricity supply and on the reliable operation of the regional electricity system. C. The Proposed Rule Will Preserve the Environmental Bene?ts of Zero-Emission Nuclear Power Plants. In addition to providing a dependable source of electricity and critical economic support, nuclear-fueled generating stations are bene?cial to the environment. The reliance on nuclear generation capacity prevents the emission of hundreds of millions of tons of greenhouse gases such as carbon dioxide, sul?ir dioxide, and nitrous oxide. The Proposal for the FERC to require operators of organized markets to compensate owners of nuclear-powered generating stations ?illy for the costs of owning and operating their generation facilities would put all such emission-free generating stations on an even footing. More importantly, it would recognize the value of the reliability and resiliency attributes of nuclear-meled generating stations that help to protect the bulk power supply system from disruptions. D. The Commission Must Act Posthaste to Prevent the Premature Retirement of Resilient Baseload Nuclear Power Plants. In order to mitigate the risk that such generating units may be deactivated prematurely, I strongly urge FERC to adopt the rule proposed by the DOE as and comprehensively as possible. FERC has a suf?cient record to act that will be further bolstered by the comments considered in this proceeding. FERC has thoroughly considered the impact of electric markets on the sustained operation of at-risk power plants and, as noted by the Secretary of the DOE, the time to act is now given the severe impacts to system reliability and resilience, and national security, attendant to the premature closure of crucial power plants. Any protracted delay in creating fully compensatory market rules will only exacerbate the problem of premature closures. The future depends on maintaining a portfolio of energy generation resources that contribute reliability, affordability and resiliency to our nation?s electric grid. Ottawa County certainly appreciates your time and commitment on this matter. We respectfully ask that you implement equitable rules, under your authority, ol? the Federal Power Act to ensure the security, resiliency, and reliability of the nation?s electric grid. Respectfully submitted, Mark W. Stahl President Ottawa County Board of Commissioners FE RC 0 eLibrary (formerly FERRISE-rna this gage File List ACCESSION Number: 29171023531"- Comment of Pleasant: undel RM1B-1. Type Flle Name 5le DF PIE asan1s Cou'g' Schools use-?me ?ts to 2334'? No script or given Ucc l'fo Ade 1c Jamest IZeset Help Funny mulling FERG- OnllnE. plasma mummuwl October ,2017 THE PROPOSED RESILIENCY RULE I have County County, West Virginia and the have seen relationship S electricity grid to maintain our more cmcial llT11r">,",rT<.l economy and the need for a robust and help it grow. This critical linkage has become even events (such as severe storms) that have adversely recent Now, more than ever, it is essential that all pmdent our to ensure our I write with a sense of urgency to address a recent Uu.'-'n.F,A that most of my constituents and I the "Grid Resiliency Pricing Commission to "ensure that certain sources are valued." Such a mle, as contemplated will ensure that existing nuclear and coal-fired stations, be economy and electricity grid are sufficiently bolstered to withstand such events. It is with of I for the last seven years. In that County, West Virginia will be Error! Unknown document property name. to costs of nn"-r