J. ABDUTIJE HAWTE GEHTEH EALEHDAR EDIE wereewars . - - . - . LEARN mesa HERE r" Feurth Suppert Higher Funding Levels . fur River InfraStructure The Federal Energy Regulatery Eemmissien is The feurth fer rivers and its aging infrastructure can?t he censidering a prepesed nJIe frem the Department ef ameng Heads, Railways and Runways. Dur waterways allew the natierr?s I Energy that wguld Dre-genre j?bg and keep wants ?pen_ critical cemmedities grain, ceal, agricultural inputs, steel, pctreleum .. precincts, chemicals, and aggregate materials te he used dcmestically The 53"5 if" The 3* and te reach the expert market in the meat cest?cempetitiye way. Di that ?that Aerial? reliability and resiliency attributes ef electric generatien MUTE seurces are fully yalued,? lteeping plants cpen and ensuring the future cf American jebs - but yeur help is needed new. Public Eemments due Ucteber 23! 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AlaEbama The Hayigatien and Ecesystem Sustainability I I Pregram selyes critical challenges by Marc-r REF: ?Elmira began-u medemiaing waterways' infrastructure and See the brechurefagenda here. restering eur precieus ecesystem. Learn Mere .- I e. Watenrrays Ccuncil Dur Cemmunity Heme Full Fteseurce Listing Latest News Watenrrays Users Beard . . L. .J I Key Issues Hatlenal Waterways Feundatlen 49s a. Eapitel Street. aw Phene: ec2.rss.21 as ?Win? center Stay C?t'll?tEClEd Suite 4m Fax: 31355215? EDHEHUE .. DE EDUUEI Email: 0 Legal Hetice Centact Us Site Map Tllillt E. HDME INC. Engagement Expired Th anlr. yen-u fer are-Hr mte re this. engagement. This. particular call te actipn has. expired, but we en e-e-Llrage '5.?pr ten check put-pm website ten eurlatesl: news. and updates. m: II. itlnE: ?nd" bar. MI- UH Eli-r1? WNWE . man 2m ?lial-1:3 er- n. Hi! .15HIM.M.mun" I .llull alum FLum.| I -. Hum? I ..Iull - - all4min .. . .h I. nu! II. .J lml. I'll.I. 14...Ii. .l . ..L.ulr ..NHL-NW. 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(IL-Hall! sum; FE RC ?1 ll "1 Human; {farmerly rm: ?y n: 9:31.: E-n'nail this gage File List Number: Desurlptign: Enmrne-nt of Ingram Elarga Cnmpany under Type Flle Name Elze FEHC EMBED Ni:- ciescripi gin-en FE Fill [Fe-n Hated EDEHEIB iJ-zn: I'fzu Pd: Uta-ruled Ileana-t Help INGRAM BARGE COMPANY A DANIEL P. MECKLENBORG . ONE BELLE MEADE PLACE CHIEF LEGAL OFFICER AND SECRETARY 4400 HARDING ROAD - P.0. BOX 23049 a if NASHVILLE. TENNESSEE 37205-2290 TEL: 615-295-8209 E-FAX 615?695?3209 October 12, 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 0F INGRAM BARGE COMPANY LLC IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy 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 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 in Ohio, Kentucky, West Virginia, Indiana, Tennessee, Wisconsin and Illinois will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. Ingram Barge Company LLC (?Ingram?) is supplier of waterborne transportation services for use by many river-served coal ?red power plants owned by American Electric Power, Dynegy, Duke Energy, Big Rivers Electric, Dayton Power and Light, Interstate Power Cooperative, Dairyland Power, Tampa Electric, First Energy and Tennessee Valley Authority located in Kentucky, Ohio, West Virginia, West Virginia, Indiana, Tennessee, Wisconsin and Illinois. Ingram has over 140 towboats and nearly 5,000 barges engaged in providing transportation services throughout America?s inland navigation system. Ingram strongly supports the Proposal, and urges the ERC to direct operators of organized markets to adopt appropriate compensation mechanisms in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal and/or nuclear industry, and the resulting impacts on our employees, our economy, the market for barge transportation services, and the reliability of the electric system will be detrimental and severe. 1. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Daniel P. Mecklenborg Chief Legal Of?cer Ingram Barge Company LLC 4400 Harding Road Nashville, TN 37205 in] 615 298 8209 II. DESCRIPTION OF INGRAM BARGE COMPANY LLC Ingram is involved in transporting bulk commodities on America?s inland waterways. It also terminals bulk commodities, and delivers fuel and supplies to the barge and towing industry. Ingram transports coal, aggregates, grain, fertilizer, ores, alloys, steel and chemicals with a ?eet of 140 towboats and 5000 barges. Ingram af?liates include Custom Fuel Services (diesel fuel and supplies) and Triangle Fleet (ship anchorage in Louisiana). For more information, visit it ?In DESCRIPTION OF INGRAM BARGE COMPANY INTEREST IN PROCEEDING Ingram?s economic revenue is directly tied to the continued operation of the many baseload coal ?red power plants that it serves. As a result, the company and its employees may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, Ingram has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. IV. COMMENTS A. The Premature Retirement of River-Served Coal Fired Power Plants Will Have 3 Signi?cant Economic Impact to Ingram, its Employees, and Region The issuance of a rule preserving baseload coal ?red power plants will preserve economic bene?ts to Ingram and its employees, which will therefore continue to sustain the regional economy. As noted above, Ingram provides barge transportation services to the utility industry, including to affected baseload coal ?red power plants. We estimate that Ingram?s annual revenue derived from the sale of barge transportation services to the coal ?red utility industry exceeds $200 million. Premature closure of affected baseload coal ?red power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper Ingram?s economic performance and may force it to reduce employment as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal ?red power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting Ingram and its employees. Additionally, the loss of a signi?cant market buyer for Ingram?s barge transportation services as a result of the premature closure of baseload coal ?red power plants will diminish Ingram?s ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. B. Premature Retirements of Baseload Coal and/0r Nuclear Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal ?red power plants will maintain a reliable supply of electricity for the region?s energy-intensive economy in three 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 coal ?red 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 number 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, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having signi?cant on?site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear?fueled generating stations provide essential reliability and resiliency support to the nation?s bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as ?oods and hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of Ingram?s business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. C. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Fired Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, Ingram strongly urges the FERC to adopt the rule proposed by the DOE as and comprehensively as possible. FERC has a suf?cient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be suf?cient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much?needed power plants. aniel P. Chief Legal Of?cer Ingram Barge Company LLC FE RC ?1 ll "1 BLibl'al'y' {farmerly rm: ?y n: 9:31.: E-n'nail this page File List Number: 2p1?1m 3-52-32 Desurlptign: Epmrne-nt of Campbell napprtatipn Epmpany'. Inc. under Type Flle Name Slap FEHC Lelter 2-31? Stiller ciescripi gin-en FE Fill [Fe-n Hated ?25m GIPDF 33-1 -.1 Up: I'fp Pd: Jpn-eat Uta-ruled Ileana-t Help Funny lama FEED Fianna 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 CAMPBELL TRANSPORTATION COMPANY, INC. (CTC) IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy ("DOE") issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to "ensure that certain reliability and 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 coal-fired electric generating stations in Pennsylvania, Ohio, Tennessee, Kentucky, Indiana, and West Virginia will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. CTC is a Marine Transportation company servicing coal power plants located along the Inland Waterways System including plants owned by American Electric Power, First Energy Corporation, Tennessee Valley Authority, Ohio Valley Electric Corporation, and Lightstone Generation LLC. CTC also has shipyard facilities along these same River Systems. CTC employs over 320 employees engaged in the transportation, construction, and maintenance related to our transportation service business. Campbell Transportation Company, Inc. strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms promptly in order to ensure that owners and operators of coal generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal industry, and the resulting impacts on our employees, our economy, the market for marine transportation services, and the reliability of the electric system will be detrimental and severe. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Gary D. Statler Jr. Managing Director- Safety, Regulatory Compliance, and HR Campbell Transportation Company Inc. 201 South Johnson Road, Suite 303, Houston, PA 15342 724-743-9027 gstatler@barges.us II. DESCRIPTION OF Campbell Transportation Company, Inc. Campbell Transportation Company, Inc. (CTC), is a fully integrated marine services company employing over 320 employees. CTC owns and/or manages over 1,100 barges and 50 towboats on the inland waterways system, along with four shipyard facilities and a marine construction company. Campbell is committed to providing safe, efficient and reliable service to our customers moving over 60 million tons of product annually. III. DESCRIPTION OF CAMPBELL TRANSPORTATION COMPANY, INC.'S INTEREST IN PROCEEDING CTC's economic revenue is directly tied to the continued operation of the baseload coal power plants owned by the aforementioned power generating companies. As a result, the company and its employees may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, CTC has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. IV. COMMENTS A. The Premature Retirement of any of the coal power plants of the aforementioned companies Will Have a Significant Economic Impact to our Company, Employees, and the Region. The issuance of a rule preserving baseload coal power plants will preserve economic benefits to Campbell Transportation Company, Inc. (CTC) and its employees, which will therefore continue to sustain the regional economy. As noted above, CTC provides marine transportation services to the utility industry, including to affected baseload coal power plants. Premature closure of affected baseload coal power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper CTC's economic performance and may force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting CTC and its employees. Additionally, the loss of a significant market buyer for CTC's marine transportation services as a result of the premature closure of baseload coal power plants will diminish CTC's ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. B. Premature Retirements of Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region's energy-intensive economy in three 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 coal 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 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 of this skilled and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond promptly to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having significant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal generating stations provide essential reliability and resiliency support to the nation's bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as floods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of CTC's business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. C. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, CTC strongly urges the FERC to adopt the rule proposed by the DOE as promptly and comprehensively as possible. FERC has a sufficient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting promptly, FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be sufficient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, Gary Statler Managing Director Campbell Transportation Company, Inc. FE RC 0 eLibrary (formerly FERRIS) . ww_?fe -Ag I w. ragov E-rna this gage File List ACCESSION Number: 291710115945 Comment of Campbell Transponatim CDI?npar?y-l Type Flle Name PDF FERC Leuer 1o 2:11? Grin-m c: No script or given FERC Gen erated PDF 25E iJcc I'fo Ade 1c -J.ec:..est IJcn'e'Lsacl Izeset Helu lawns FERG 0n||na_ ??amm nomad Planar-d udaaullrutmal .undar 5le 1? 5755 11-2503 WWUHJI ass-ma?a. mm umber aid ?add 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 CAMPBELL TRANSPORTATION COMPANY, INC. (CTC) IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy ("DOE") issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to "ensure that certain reliability and 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 coal-fired electric generating stations in Pennsylvania, Ohio, Tennessee, Kentucky, Indiana, and West Virginia will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. CTC is a Marine Transportation company servicing coal power plants located along the Inland Waterways System including plants owned by American Electric Power, First Energy Corporation, Tennessee Valley Authority, Ohio Valley Electric Corporation, and Lightstone Generation LLC. CTC also has shipyard facilities along these same River Systems. CTC employs over 320 employees engaged in the transportation, construction, and maintenance related to our transportation service business. Campbell Transportation Company, Inc. strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms promptly in order to ensure that owners and operators of coal generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal industry, and the resulting impacts on our employees, our economy, the market for marine transportation services, and the reliability of the electric system will be detrimental and severe. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Gary D. Statler Jr. Managing Director- Safety, Regulatory Compliance, and HR Campbell Transportation Company Inc. 201 South Johnson Road, Suite 303, Houston, PA 15342 724-743-9027 gstatler@barges.us II. DESCRIPTION OF Campbell Transportation Company, Inc. Campbell Transportation Company, Inc. (CTC), is a fully integrated marine services company employing over 320 employees. CTC owns and/or manages over 1,100 barges and 50 towboats on the inland waterways system, along with four shipyard facilities and a marine construction company. Campbell is committed to providing safe, efficient and reliable service to our customers moving over 60 million tons of product annually. III. DESCRIPTION OF CAMPBELL TRANSPORTATION COMPANY, INC.'S INTEREST IN PROCEEDING CTC's economic revenue is directly tied to the continued operation of the baseload coal power plants owned by the aforementioned power generating companies. As a result, the company and its employees may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, CTC has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. IV. COMMENTS A. The Premature Retirement of any of the coal power plants of the aforementioned companies Will Have a Significant Economic Impact to our Company, Employees, and the Region. The issuance of a rule preserving baseload coal power plants will preserve economic benefits to Campbell Transportation Company, Inc. (CTC) and its employees, which will therefore continue to sustain the regional economy. As noted above, CTC provides marine transportation services to the utility industry, including to affected baseload coal power plants. Premature closure of affected baseload coal power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper CTC's economic performance and may force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting CTC and its employees. Additionally, the loss of a significant market buyer for CTC's marine transportation services as a result of the premature closure of baseload coal power plants will diminish CTC's ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. B. Premature Retirements of Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region's energy-intensive economy in three 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 coal 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 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 of this skilled and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond promptly to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having significant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal generating stations provide essential reliability and resiliency support to the nation's bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as floods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of CTC's business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. C. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, CTC strongly urges the FERC to adopt the rule proposed by the DOE as promptly and comprehensively as possible. FERC has a sufficient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting promptly, FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be sufficient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, Christopher S. Grimm Manager of Regulatory Compliance Campbell Transportation Company, Inc. FE RC ?1 ll "1 BLibl'al'y' {farmerly rm: ?y n: 9:31.: E-n'nail this page File List Number: Desurlptign: Epmrne-nt of Campbell napprtatipn Epmpany'. Inc. under Type Flle Name Slap PM CT: FEFLC 22". 1-3 1? 43365 ciescripi gin-en FE Fill [Fe-n Hated 31145 Dec I'fp Pd: Jpn-eat Uta-ruled Ileana-t Help Funny lama FEED Fianna Campbell Transportation Company, Inc. Foxpointe Centre 201 S. Johnson Road, Suite 303 Houston, PA 15342 Phone: (724) 743-9550 Fax: (724) 873-9013 Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: October 17, 2017 Grid Resiliency Pricing Rule FERC Docket No. RM18-1-000 COMMENTS OF THE CAMPBELL TRANSPORTATION COMPANY, INC. IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy ("DOE") issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to "ensure that certain reliability and 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-fired electric generating stations in the Ohio Valley (Pennsylvania, Ohio, West Virginia, Kentucky, Indiana and Tennessee) will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. 1 Campbell Transportation Company, Inc. ("Campbell") is a river Transportation Company that operates 1,100 barges and 50 tugs on the Ohio River system. Campbell transports coal, limestone, lime, urea and gypsum to a number of coal-fired power plants in the Ohio Valley. These coal-fired power plants are owned by various utilities, including FirstEnergy (Sammis, Pleasants, Mansfield and Fort Martin plants), American Electric Power (Cardinal, Mountaineer, Mitchell, Amos and Rockport plants), Tennessee Valley Authority (Allen and New Johnsonville plants), Lightstone Generation (Gavin plant), and Ohio Valley Electric Corporation (Kyger Creek plant). All these power plants are located on the river system, due to the economic and environmental benefits of river transportation. Campbell has shipyard operations at multiple facilities along the rivers but the majority of our employees live on the tugboats. Campbell employs directly about 400 employees and also employs about an additional 100 employees as subcontractors, bringing our total employment to approximately 500 individuals. Campbell strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms promptly in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal industry, and the resulting impacts on our employees, our economy, the market for river transportation services, and the reliability of the electric system will be detrimental and severe. 2 I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Peter H. Stephaich Chairman and CEO Campbell Transportation Company, Inc. 201 South Johnson Road, Suite 303 Houston, PA 15342-1351 724-746-9544 pstephaich@barges.us II. DESCRIPTION OF CAMPBELL Campbell is a private, family owned, integrated inland marine services transportation company has been moving utility coal for over 70 years. Campbell is based in Pittsburgh, PA and has 5 regional offices/facilities. We operate 1,100 barges and 50 towboats, making Campbell one of the largest carriers of coal on the Ohio River. We move in excess of 25 million tons of coal per year. Moving utility coal on the rivers is our primary business. For more detailed information, our website is www.barges.us III. DESCRIPTION OF CAMPBELL'S INTEREST IN PROCEEDING Campbell's economic revenue is directly tied to the continued operation of the baseload coal fired power plants listed above. As a result, the company and its employees will be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, Campbell has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. 3 IV. COMMENTS A. The Premature Retirement of any of the Plants that we Service Will Have a Significant Economic Impact to our Company, Employees, and Region The issuance of a rule preserving baseload coal power plants will preserve economic benefits to Campbell and its employees, which will therefore continue to sustain the regional economy. As noted above, Campbell delivers millions of tons of coal each year to the utility industry, including to the affected baseload coal power plants. On an annual basis, we generate approximately $100 million of revenue from this principal business activity. This represents in excess of 25 million tons of coal per year. Premature closure of any of the affected baseload power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper Campbell's economic performance and will force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting Campbell and its employees. Additionally, the loss of one or more significant customer(s) for Campbell's river transportation services as a result of the premature closure of baseload coal power plants will diminish Campbell's ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. 4 B. Premature Retirement of River Baseload Coal Fired Power Plants Negative Impact to Inland Waterways System The closure of these large baseload river based power plants will negatively impact the other industry sectors that rely on the river transportation industry. The inland river system is the only underutilized mode of transportation for bulk commodities. The method by which the U.S Army Corps of Engineers is depended on the amount of tons shipped on the system. If tonnages are reduced due to premature closings, then the funding for the lock and dams that are critical to the operations of the system will be reduced, causing operational problems for the remaining users of the system. Besides commercial navigation, other users include, municipal and industrial water supply, hydro generation, recreation flood control and well as economic development. C. Premature Retirements of Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region's energyintensive economy in three 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 coal 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 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 of this skilled 5 and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond promptly to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having significant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation's bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as floods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of Campbell's business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. D. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, Campbell strongly urges the FERC to adopt the rule proposed 6 by the DOE as promptly and comprehensively as possible. FERC has a sufficient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting promptly, FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be sufficient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, Peter H. Stephaich Chairman and CEO Campbell Transportation Company, Inc. 7 eLibrary (formerly.r FERRIS) qua" eroggo 3 E-"na his gage File List ACCESSION Number: 201710195925 Comment of Campbell Transportation Compar?y, Ir?c. under RM1B-1. Type Flle Name Slze PDF FERC Le1tE" Monal'arPD: 42335 No cescripl or given FERC Gen eratec? PDF 25E 39294 Dec I'fo Ade 1c -J.ec:..est Danni?Luau lie-set Help Flal'lmz.I lawns FERG Onllna. plasma ass-ma?a. Campbell Transportation Company, Inc. Foxpointe Centre 201 S. Johnson Road, Suite 303 Houston, PA 15342 Phone: (724) 743-9550 Fax: (724) 873-9013 Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: October 19, 2017 Grid Resiliency Pricing Rule FERC Docket No. RM18-1-000 COMMENTS OF THE CAMPBELL TRANSPORTATION COMPANY, INC. IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy ("DOE") issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to "ensure that certain reliability and 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-fired electric generating stations in the Ohio Valley (Pennsylvania, Ohio, West Virginia, Kentucky, Indiana and Tennessee) will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. 1 Campbell Transportation Company, Inc. ("Campbell") is a river Transportation Company that operates 1,100 barges and 50 tugs on the Ohio River system. Campbell transports coal, limestone, lime, urea and gypsum to a number of coal-fired power plants in the Ohio Valley. These coal-fired power plants are owned by various utilities, including FirstEnergy (Sammis, Pleasants, Mansfield and Fort Martin plants), American Electric Power (Cardinal, Mountaineer, Mitchell, Amos and Rockport plants), Tennessee Valley Authority (Allen and New Johnsonville plants), Lightstone Generation (Gavin plant), and Ohio Valley Electric Corporation (Kyger Creek plant). All these power plants are located on the river system, due to the economic and environmental benefits of river transportation. Campbell has shipyard operations at multiple facilities along the rivers but the majority of our employees live on the tugboats. Campbell employs directly about 400 employees and also employs about an additional 100 employees as subcontractors, bringing our total employment to approximately 500 individuals. Campbell strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms promptly in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal industry, and the resulting impacts on our employees, our economy, the market for river transportation services, and the reliability of the electric system will be detrimental and severe. 2 I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Gary D. Statler Managing Director Campbell Transportation Company, Inc. 201 South Johnson Road, Suite 303 Houston, PA 15342-1351 724-743-9027 gstatler@barges.us II. DESCRIPTION OF CAMPBELL Campbell is a private, family owned, integrated inland marine services transportation company has been moving utility coal for over 70 years. Campbell is based in Pittsburgh, PA and has 5 regional offices/facilities. We operate 1,100 barges and 50 towboats, making Campbell one of the largest carriers of coal on the Ohio River. We move in excess of 25 million tons of coal per year. Moving utility coal on the rivers is our primary business. For more detailed information, our website is www.barges.us III. DESCRIPTION OF CAMPBELL'S INTEREST IN PROCEEDING Campbell's economic revenue is directly tied to the continued operation of the baseload coal fired power plants listed above. As a result, the company and its employees will be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, Campbell has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. 3 IV. COMMENTS A. The Premature Retirement of any of the Plants that we Service Will Have a Significant Economic Impact to our Company, Employees, and Region The issuance of a rule preserving baseload coal power plants will preserve economic benefits to Campbell and its employees, which will therefore continue to sustain the regional economy. As noted above, Campbell delivers millions of tons of coal each year to the utility industry, including to the affected baseload coal power plants. On an annual basis, we generate approximately $100 million of revenue from this principal business activity. This represents in excess of 25 million tons of coal per year. Premature closure of any of the affected baseload power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper Campbell's economic performance and will force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting Campbell and its employees. Additionally, the loss of one or more significant customer(s) for Campbell's river transportation services as a result of the premature closure of baseload coal power plants will diminish Campbell's ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. 4 B. Premature Retirement of River Baseload Coal Fired Power Plants Negative Impact to Inland Waterways System The closure of these large baseload river based power plants will negatively impact the other industry sectors that rely on the river transportation industry. The inland river system is the only underutilized mode of transportation for bulk commodities. The method by which the U.S Army Corps of Engineers is depended on the amount of tons shipped on the system. If tonnages are reduced due to premature closings, then the funding for the lock and dams that are critical to the operations of the system will be reduced, causing operational problems for the remaining users of the system. Besides commercial navigation, other users include, municipal and industrial water supply, hydro generation, recreation flood control and well as economic development. C. Premature Retirements of Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region's energyintensive economy in three 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 coal 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 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 of this skilled 5 and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond promptly to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having significant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation's bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as floods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of Campbell's business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. D. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, Campbell strongly urges the FERC to adopt the rule proposed 6 by the DOE as promptly and comprehensively as possible. FERC has a sufficient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting promptly, FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be sufficient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, Michael Monahan President Campbell Transportation Company, Inc. 7 FE RC 0 eLibrary (formerly FERRIS) d? w. rczgov E-rna this gage File List ACCESSION Number: 291710195139 Comment of Campbell Transponatim CDI?npar?y-l Type Fl le a me DF No script or given FERC Gen erated PDF 25(2923? iJcc I'fo Ade 1c -J.ec:..est IJcn'e'Lsacl Izeset Helu lawns FERG 0n||na_ ??amm nomad Planar-d udaaullrutmal .undar Slze ?1541?22 153813 WWUHJI ass-ma?a. mm umber aid ?add Houston. PA 15342 Phone: (724) 743-9550 Campbell Transportation Company, Inc. Foxpointe Centre 201 S. Johnson Road. Suite 303 Fax.- (724) 373-9013 Federal Energy Regulatory Commission October 19, 2017 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 CAMPBELL TRANSPORTATION COMPANY, INC. EMPLOYEES IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy 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 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 in the Ohio Valley Ohio, West Virginia, Kentucky, Indiana and Tennessee) will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. Campbell Transportation Company, Inc. (?Campbell") is a river Transportation Company that operates 1,100 barges and 50 tugs on the Ohio River system. Campbell transports coal, limestone, lime, urea and gypsum to a number of coal-?red power plants in the Ohio Valley. These coal-fired power plants are owned by various utilities, including FirstEnergy (Sammis, Pleasants, Mans?eld and Fort Martin plants), American Electric Power (Cardinal, Mountaineer, Mitchell, Amos and Rockport plants), Tennessee Valley Authority (Allen and New Johnsonville plants), Generation (Gavin plant), and Ohio Valley Electric Corporation (Kyger Creek plant). All these power plants are located on the river system, due to the economic and environmental bene?ts of river transportation. Campbell has shipyard operations at multiple facilities along the rivers but the majority of our employees live on the tugboats. Campbell employs directly about 400 employees and also employs about an additional 100 employees as subcontractors, bringing our total employment to approximately 500 individuals. Campbell strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms in order to ensure that owners and operators of coal and nuclear-?reled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal industry, and the resulting impacts on our employees, our economy, the market for river transportation services, and the reliability of the electric system will be detrimental and severe. 1. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Gary D. Statler Jr. Managing Director- Safety, Regulatory Compliance, and HR Campbell Transportation Company Inc. 201 South Johnson Road, Suite 303, Houston, PA 15342 724-743-9027 gstatler@barges.us II. DESCRIPTION OF CAMPBELL Campbell is a private, family owned, integrated inland marine services transportation company has been moving utility coal for over 70 years. Campbell is based in Pittsburgh, PA and has 5 regional of?ces/facilities. We operate 1,100 barges and 50 towboats, making Campbell one of the largest carriers of coal on the Ohio River. We move in excess of 25 million tons of coal per year. Moving utility coal on the rivers is our primary business. For more detailed information, our website is 111. DESCRIPTION OF INTEREST IN PROCEEDING Campbell?s economic revenue is directly tied to the continued operation of the baseload coal ?red power plants listed above. As a result, the company and its employees will be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, Campbell has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-?Jeled generating stations in organized markets. IV. COMMENTS A. The Premature Retirement of any of the Plants that we Service Will Have a Signi?cant Economic Impact to our Company, Employees, and Region The issuance of a rule preserving baseload coal power plants will preserve economic bene?ts to Campbell and its employees, which will therefore continue to sustain the regional economy. As noted above, Campbell delivers millions of tons of coal each year to the utility industry, including to the affected baseload coal power plants. On an annual basis, we generate approximately $100 million of revenue from this principal business activity. This represents in excess of 25 million tons of coal per year. Premature closure of any of the affected baseload power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper Campbell?s economic performance and will force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result ?om the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting Campbell and its employees. Additionally, the loss of one or more signi?cant customer(s) for Campbell?s river transportation services as a result of the premature closure of baseload coal power plants will diminish Campbell?s ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. B. Premature Retirement of River Baseload Coal Fired Power Plants - Negative Impact to Inland Waterways System The closure of these large baseload river based power plants will negatively impact the other industry sectors that rely on the river transportation industry. The inland river system is the only underutilized mode of transportation for bulk commodities. The method by which the US Army Corps of Engineers is depended on the amount of tons shipped on the system. If tonnages are reduced due to premature closings, then the funding for the lock and dams that are critical to the Operations of the system will be reduced, causing operational problems for the remaining users of the system. Besides commercial navigation, other users include, municipal and industrial water supply, hydro generation, recreation ?ood control and well as economic development. C. Premature Retirements of Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region?s energy- intensive economy in three 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 coal 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 5 and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having signi?cant on?site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear?fueled generating stations provide essential reliability and resiliency support to the nation?s bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential ?lel supply disruptions that might be caused by natural disasters such as ?oods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of Campbell?s business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. D. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, Campbell strongly urges the FERC to adOpt the rule proposed by the DOE as and comprehensively as possible. FERC has a suf?cient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their ?rll costs of operation will only exacerbate the problem of premature closures. In acting ERC should direct Operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be suf?cient to ensure that critical power plants can continue to Operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully su mitted, Kate Waugaman Sr. Accounting Clerk Campbell Transportation Company FE RC 7? eLibrary (formerly FERRIS) E-rna 1 his gage File List Accesslon Number: 201110194112? Cummenl of Campbell Trenaponatim Company. Inc. under Type Flle Name Slze PDF Jase" Powell AP Carnot-el 33333 wsponal or.PD '5 No script or given FERC Gen erated PDF 37"?9 iJcc I'fo Ade 1c -J.ec:..est Ursa?Lead Izeset Helu FellingI Muse milling FERG OnllnE. please WEB-36M. Campbell Transportation Company, Inc. Foxpointe Centre 201 S. Johnson Road, Suite 303 Houston, PA 15342 Phone: (724) 743-9550 Fax: (724) 873-9013 Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: October 19, 2017 Grid Resiliency Pricing Rule FERC Docket No. RM18-1-000 COMMENTS OF THE CAMPBELL TRANSPORTATION COMPANY, INC. EMPLOYEES IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy ("DOE") issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to "ensure that certain reliability and 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-fired electric generating stations in the Ohio Valley (Pennsylvania, Ohio, West Virginia, Kentucky, Indiana and Tennessee) will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. 1 Campbell Transportation Company, Inc. ("Campbell") is a river Transportation Company that operates 1,100 barges and 50 tugs on the Ohio River system. Campbell transports coal, limestone, lime, urea and gypsum to a number of coal-fired power plants in the Ohio Valley. These coal-fired power plants are owned by various utilities, including FirstEnergy (Sammis, Pleasants, Mansfield and Fort Martin plants), American Electric Power (Cardinal, Mountaineer, Mitchell, Amos and Rockport plants), Tennessee Valley Authority (Allen and New Johnsonville plants), Lightstone Generation (Gavin plant), and Ohio Valley Electric Corporation (Kyger Creek plant). All these power plants are located on the river system, due to the economic and environmental benefits of river transportation. Campbell has shipyard operations at multiple facilities along the rivers but the majority of our employees live on the tugboats. Campbell employs directly about 400 employees and also employs about an additional 100 employees as subcontractors, bringing our total employment to approximately 500 individuals. Campbell strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms promptly in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal industry, and the resulting impacts on our employees, our economy, the market for river transportation services, and the reliability of the electric system will be detrimental and severe. 2 I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Gary D. Statler Jr. Managing Director- Safety, Regulatory Compliance, and HR Campbell Transportation Company Inc. 201 South Johnson Road, Suite 303, Houston, PA 15342 724-743-9027 gstatler@barges.us II. DESCRIPTION OF CAMPBELL Campbell is a private, family owned, integrated inland marine services transportation company has been moving utility coal for over 70 years. Campbell is based in Pittsburgh, PA and has 5 regional offices/facilities. We operate 1,100 barges and 50 towboats, making Campbell one of the largest carriers of coal on the Ohio River. We move in excess of 25 million tons of coal per year. Moving utility coal on the rivers is our primary business. For more detailed information, our website is www.barges.us III. DESCRIPTION OF CAMPBELL'S INTEREST IN PROCEEDING Campbell's economic revenue is directly tied to the continued operation of the baseload coal fired power plants listed above. As a result, the company and its employees will be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, Campbell has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. 3 IV. COMMENTS A. The Premature Retirement of any of the Plants that we Service Will Have a Significant Economic Impact to our Company, Employees, and Region The issuance of a rule preserving baseload coal power plants will preserve economic benefits to Campbell and its employees, which will therefore continue to sustain the regional economy. As noted above, Campbell delivers millions of tons of coal each year to the utility industry, including to the affected baseload coal power plants. On an annual basis, we generate approximately $100 million of revenue from this principal business activity. This represents in excess of 25 million tons of coal per year. Premature closure of any of the affected baseload power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper Campbell's economic performance and will force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting Campbell and its employees. Additionally, the loss of one or more significant customer(s) for Campbell's river transportation services as a result of the premature closure of baseload coal power plants will diminish Campbell's ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. 4 B. Premature Retirement of River Baseload Coal Fired Power Plants Negative Impact to Inland Waterways System The closure of these large baseload river based power plants will negatively impact the other industry sectors that rely on the river transportation industry. The inland river system is the only underutilized mode of transportation for bulk commodities. The method by which the U.S Army Corps of Engineers is depended on the amount of tons shipped on the system. If tonnages are reduced due to premature closings, then the funding for the lock and dams that are critical to the operations of the system will be reduced, causing operational problems for the remaining users of the system. Besides commercial navigation, other users include, municipal and industrial water supply, hydro generation, recreation flood control and well as economic development. C. Premature Retirements of Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region's energyintensive economy in three 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 coal 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 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 of this skilled 5 and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond promptly to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having significant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation's bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as floods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of Campbell's business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. D. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, Campbell strongly urges the FERC to adopt the rule proposed 6 by the DOE as promptly and comprehensively as possible. FERC has a sufficient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting promptly, FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be sufficient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, [Insert name] [Insert business title] [Insert organization name] 7 FE RC 0 WE eLibrary (formerly FERRIS) of: 2:1 mgg?L; E-rna this gage File List ACCESSION Number: 291710235049 Des: rlption; Comment 0? Campbell Tlansponatim Compar?y. Inc. under Type Flle Name 5le PDF 20?? 20 39 DB 754653 No descriptor given FERC Gen eralec PDF 7532?? 'Jcc I'fo 1c Dena-Load lie-set HE FERG 0n||na_ WWUHJI meme-35m. Mums? Houston. PA 15342 Phone: (724) 743-9550 Fax: (724) 873-9013 Campbell Transportation Company, Inc. Foxpointe Centre 201 S. Johnson Road. Suite 303 Federal Energy Regulatory Commission October 19, 2017 Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: Grid Resiliency Pricing Rule FERC Docket No. COMMENTS OF THE CAMPBELL TRANSPORTATION COMPANY. INC. EMPLOYEES IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy 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 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 in the Ohio Valley Ohio, West Virginia, Kentucky, Indiana and Tennessee) will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. Campbell Transportation Company, Inc. (?Campbell?) is a river Transportation Company that operates 1,100 barges and 50 tugs on the Ohio River system. Campbell transports coal, limestone, lime, urea and gypsum to a number of coal-?red power plants in the Ohio Valley. These coal-?red power plants are owned by various utilities, including FirstEnergy (Sammis, Pleasants, Mans?eld and Fort Martin plants), American Electric Power (Cardinal, Mountaineer, Mitchell, Amos and Rockport plants), Tennessee Valley Authority (Allen and New ohnsonville plants), Generation (Gavin plant), and Ohio Valley Electric Corporation (Kyger Creek plant). All these power plants are located on the river system, due to the economic and environmental bene?ts of river transportation. Campbell has shipyard operations at multiple facilities along the rivers but the majority of our employees live on the tugboats. Campbell employs directly about 400 employees and also employs about an additional 100 employees as subcontractors, bringing our total employment to approximately 500 individuals. Campbell strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal industry, and the resulting impacts on our employees, our economy, the market for river transportation services, and the reliability of the electric system will be detrimental and severe. 1. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Gary D. Statler Jr. Managing Director? Safety, Regulatory Compliance, and HR Campbell Transportation Company Inc. 201 South Johnson Road, Suite 303, Houston, PA 15342 724-743-9027 gstatler@barges.us II. DESCRIPTION OF CAMPBELL Campbell is a private, family owned, integrated inland marine services transportation company has been moving utility coal for over 70 years. Campbell is based in Pittsburgh, PA and has 5 regional of?ces/facilities. We operate 1,100 barges and 50 towboats, making Campbell one of the largest carriers of coal on the Ohio River. We move in excess of 25 million tons of coal per year. Moving utility coal on the rivers is our primary business. For more detailed information, our website is DESCRIPTION OF INTEREST IN PROCEEDING Campbell?s economic revenue is directly tied to the continued operation of the baseload coal ?red power plants listed above. As a result, the company and its employees will be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, Campbell has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. IV. COMMENTS A. The Premature Retirement of any of the Plants that we Service Will Have a Significant Economic Impact to our Company, Employees, and Region The issuance of a rule preserving baseload coal power plants will preserve economic bene?ts to Campbell and its employees, which will therefore continue to sustain the regional economy. As noted above, Campbell delivers millions of tons of coal each year to the utility industry, including to the affected baseload coal power plants. On an annual basis, we generate approximately $100 million of revenue ?om this principal business activity. This represents in excess of 25 million tons of coal per year. Premature closure of any of the affected baseload power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper Campbell?s economic performance and will force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting Campbell and its employees. Additionally, the loss of one or more signi?cant customer(s) for Campbell?s river transportation services as a result of the premature closure of baseload coal power plants will diminish Campbell?s ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. B. Premature Retirement of River Baseload Coal Fired Power Plants - Negative Impact to Inland Waterways System The closure of these large baseload river based power plants will negatively impact the other industry sectors that rely on the river transportation industry. The inland river system is the only underutilized mode of transportation for bulk commodities. The method by which the US Army Corps of Engineers is depended on the amount of tons shipped on the system. If tonnages are reduced due to premature closings, then the funding for the lock and dams that are critical to the operations of the system will be reduced, causing operational problems for the remaining users of the system. Besides commercial navigation, other users include, municipal and industrial water supply, hydro generation, recreation ?ood control and well as economic development. C. Premature Retirements of Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region?s energy- intensive economy in three 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 coal 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 5 and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having signi?cant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation?s bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as ?oods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of Campbell?s business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. D. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, Campbell strongly urges the FERC to adopt the rule proposed by the DOE as and comprehensively as possible. FERC has a suf?cient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be sufficient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Mike Wallace Manager- Ohio River Shipyard Facilities Barge Maintenance Campbell Transportation Company FE RC ?1 ll "1 BLibl'al'y' {farmerly rm: ?y n: 9:31.: E-n'nail this page File List Number: ENHDEEI-EDEE- Desurlptign: Epmrne-nt of Campbell napprtatipn Epmpany'. Inc. under Type Flle Name Slap FEHC 31952 ciescripi gin-en FE Fill [Fe-n Hated 3235 Up: I'fp Pd: Jpn-eat Uta-ruled Ileana-t Help Funny lama FEED Fianna Campbell Transportation Company, Inc. Foxpointe Centre 201 S. Johnson Road, Suite 303 Houston, PA 15342 Phone: (724) 743-9550 Fax: (724) 873-9013 Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: October 19, 2017 Grid Resiliency Pricing Rule FERC Docket No. RM18-1-000 COMMENTS OF THE CAMPBELL TRANSPORTATION COMPANY, INC. EMPLOYEES IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy ("DOE") issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to "ensure that certain reliability and 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-fired electric generating stations in the Ohio Valley (Pennsylvania, Ohio, West Virginia, Kentucky, Indiana and Tennessee) will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. 1 Campbell Transportation Company, Inc. ("Campbell") is a river Transportation Company that operates 1,100 barges and 50 tugs on the Ohio River system. Campbell transports coal, limestone, lime, urea and gypsum to a number of coal-fired power plants in the Ohio Valley. These coal-fired power plants are owned by various utilities, including FirstEnergy (Sammis, Pleasants, Mansfield and Fort Martin plants), American Electric Power (Cardinal, Mountaineer, Mitchell, Amos and Rockport plants), Tennessee Valley Authority (Allen and New Johnsonville plants), Lightstone Generation (Gavin plant), and Ohio Valley Electric Corporation (Kyger Creek plant). All these power plants are located on the river system, due to the economic and environmental benefits of river transportation. Campbell has shipyard operations at multiple facilities along the rivers but the majority of our employees live on the tugboats. Campbell employs directly about 400 employees and also employs about an additional 100 employees as subcontractors, bringing our total employment to approximately 500 individuals. Campbell strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms promptly in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal industry, and the resulting impacts on our employees, our economy, the market for river transportation services, and the reliability of the electric system will be detrimental and severe. 2 I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Gary D. Statler Jr. Managing Director- Safety, Regulatory Compliance, and HR Campbell Transportation Company Inc. 201 South Johnson Road, Suite 303, Houston, PA 15342 724-743-9027 gstatler@barges.us II. DESCRIPTION OF CAMPBELL Campbell is a private, family owned, integrated inland marine services transportation company has been moving utility coal for over 70 years. Campbell is based in Pittsburgh, PA and has 5 regional offices/facilities. We operate 1,100 barges and 50 towboats, making Campbell one of the largest carriers of coal on the Ohio River. We move in excess of 25 million tons of coal per year. Moving utility coal on the rivers is our primary business. For more detailed information, our website is www.barges.us III. DESCRIPTION OF CAMPBELL'S INTEREST IN PROCEEDING Campbell's economic revenue is directly tied to the continued operation of the baseload coal fired power plants listed above. As a result, the company and its employees will be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, Campbell has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. 3 IV. COMMENTS A. The Premature Retirement of any of the Plants that we Service Will Have a Significant Economic Impact to our Company, Employees, and Region The issuance of a rule preserving baseload coal power plants will preserve economic benefits to Campbell and its employees, which will therefore continue to sustain the regional economy. As noted above, Campbell delivers millions of tons of coal each year to the utility industry, including to the affected baseload coal power plants. On an annual basis, we generate approximately $100 million of revenue from this principal business activity. This represents in excess of 25 million tons of coal per year. Premature closure of any of the affected baseload power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper Campbell's economic performance and will force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting Campbell and its employees. Additionally, the loss of one or more significant customer(s) for Campbell's river transportation services as a result of the premature closure of baseload coal power plants will diminish Campbell's ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. 4 B. Premature Retirement of River Baseload Coal Fired Power Plants Negative Impact to Inland Waterways System The closure of these large baseload river based power plants will negatively impact the other industry sectors that rely on the river transportation industry. The inland river system is the only underutilized mode of transportation for bulk commodities. The method by which the U.S Army Corps of Engineers is depended on the amount of tons shipped on the system. If tonnages are reduced due to premature closings, then the funding for the lock and dams that are critical to the operations of the system will be reduced, causing operational problems for the remaining users of the system. Besides commercial navigation, other users include, municipal and industrial water supply, hydro generation, recreation flood control and well as economic development. C. Premature Retirements of Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region's energyintensive economy in three 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 coal 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 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 of this skilled 5 and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond promptly to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having significant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation's bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as floods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of Campbell's business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. D. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, Campbell strongly urges the FERC to adopt the rule proposed 6 by the DOE as promptly and comprehensively as possible. FERC has a sufficient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting promptly, FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be sufficient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, [Insert name] [Insert business title] [Insert organization name] 7 eLibrary (formerly.r FERRIS) E-rna 1 his gage File List Accesslon Number: 201110235153 Cummenl of Campbell Tranaponatim Company. Inc. under RM1B-1. Type Flle Name 5|ze Doc. FERC Le1ter CTC 31952 1D 1? DOC No cescripl or given FERC Generated PDF 25E 22?230 iJcc I'fo Ade 1c -J.ec:..est Ursa?Lead Izeset Helu FellingI Muse FERG OnllnE. plasma WEB-36M. Campbell Transportation Company, Inc. Foxpointe Centre 201 S. Johnson Road, Suite 303 Houston, PA 15342 Phone: (724) 743-9550 Fax: (724) 873-9013 Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: October 19, 2017 Grid Resiliency Pricing Rule FERC Docket No. RM18-1-000 COMMENTS OF THE CAMPBELL TRANSPORTATION COMPANY, INC. EMPLOYEES IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy ("DOE") issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to "ensure that certain reliability and 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-fired electric generating stations in the Ohio Valley (Pennsylvania, Ohio, West Virginia, Kentucky, Indiana and Tennessee) will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. 1 Campbell Transportation Company, Inc. ("Campbell") is a river Transportation Company that operates 1,100 barges and 50 tugs on the Ohio River system. Campbell transports coal, limestone, lime, urea and gypsum to a number of coal-fired power plants in the Ohio Valley. These coal-fired power plants are owned by various utilities, including FirstEnergy (Sammis, Pleasants, Mansfield and Fort Martin plants), American Electric Power (Cardinal, Mountaineer, Mitchell, Amos and Rockport plants), Tennessee Valley Authority (Allen and New Johnsonville plants), Lightstone Generation (Gavin plant), and Ohio Valley Electric Corporation (Kyger Creek plant). All these power plants are located on the river system, due to the economic and environmental benefits of river transportation. Campbell has shipyard operations at multiple facilities along the rivers but the majority of our employees live on the tugboats. Campbell employs directly about 400 employees and also employs about an additional 100 employees as subcontractors, bringing our total employment to approximately 500 individuals. Campbell strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms promptly in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal industry, and the resulting impacts on our employees, our economy, the market for river transportation services, and the reliability of the electric system will be detrimental and severe. 2 I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Gary D. Statler Jr. Managing Director- Safety, Regulatory Compliance, and HR Campbell Transportation Company Inc. 201 South Johnson Road, Suite 303, Houston, PA 15342 724-743-9027 gstatler@barges.us II. DESCRIPTION OF CAMPBELL Campbell is a private, family owned, integrated inland marine services transportation company has been moving utility coal for over 70 years. Campbell is based in Pittsburgh, PA and has 5 regional offices/facilities. We operate 1,100 barges and 50 towboats, making Campbell one of the largest carriers of coal on the Ohio River. We move in excess of 25 million tons of coal per year. Moving utility coal on the rivers is our primary business. For more detailed information, our website is www.barges.us III. DESCRIPTION OF CAMPBELL'S INTEREST IN PROCEEDING Campbell's economic revenue is directly tied to the continued operation of the baseload coal fired power plants listed above. As a result, the company and its employees will be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, Campbell has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. 3 IV. COMMENTS A. The Premature Retirement of any of the Plants that we Service Will Have a Significant Economic Impact to our Company, Employees, and Region The issuance of a rule preserving baseload coal power plants will preserve economic benefits to Campbell and its employees, which will therefore continue to sustain the regional economy. As noted above, Campbell delivers millions of tons of coal each year to the utility industry, including to the affected baseload coal power plants. On an annual basis, we generate approximately $100 million of revenue from this principal business activity. This represents in excess of 25 million tons of coal per year. Premature closure of any of the affected baseload power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper Campbell's economic performance and will force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting Campbell and its employees. Additionally, the loss of one or more significant customer(s) for Campbell's river transportation services as a result of the premature closure of baseload coal power plants will diminish Campbell's ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. 4 B. Premature Retirement of River Baseload Coal Fired Power Plants Negative Impact to Inland Waterways System The closure of these large baseload river based power plants will negatively impact the other industry sectors that rely on the river transportation industry. The inland river system is the only underutilized mode of transportation for bulk commodities. The method by which the U.S Army Corps of Engineers is depended on the amount of tons shipped on the system. If tonnages are reduced due to premature closings, then the funding for the lock and dams that are critical to the operations of the system will be reduced, causing operational problems for the remaining users of the system. Besides commercial navigation, other users include, municipal and industrial water supply, hydro generation, recreation flood control and well as economic development. C. Premature Retirements of Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region's energyintensive economy in three 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 coal 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 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 of this skilled 5 and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond promptly to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having significant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation's bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as floods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of Campbell's business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. D. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, Campbell strongly urges the FERC to adopt the rule proposed 6 by the DOE as promptly and comprehensively as possible. FERC has a sufficient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting promptly, FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be sufficient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, Heather Longshore Human Resources Business Partner Campbell Transportation Company 7 FE RC ?Ill ?1 eLibrery {fermerly Pinewjere; e1: 3 a. 'u gm E-meil thie gage File List Number: Eemrne-nt of Campbell Trenep-ertatim Camp-any. Inc. under Flle Heme FEHC Le1ter ETC ES Ni:- gin-en FE HI: Gen erated iJeI: I'fe Fade 1e -J.eeL-eet lewee FEED mammawee? MERGE-MM. Campbell Transportation Company, Inc. Foxpointe Centre 201 S. Johnson Road, Suite 303 Houston, PA 15342 Phone: (724) 743-9550 Fax: (724) 873-9013 Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: October 19, 2017 Grid Resiliency Pricing Rule FERC Docket No. RM18-1-000 COMMENTS OF THE CAMPBELL TRANSPORTATION COMPANY, INC. EMPLOYEES IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy ("DOE") issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to "ensure that certain reliability and 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-fired electric generating stations in the Ohio Valley (Pennsylvania, Ohio, West Virginia, Kentucky, Indiana and Tennessee) will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. 1 Campbell Transportation Company, Inc. ("Campbell") is a river Transportation Company that operates 1,100 barges and 50 tugs on the Ohio River system. Campbell transports coal, limestone, lime, urea and gypsum to a number of coal-fired power plants in the Ohio Valley. These coal-fired power plants are owned by various utilities, including FirstEnergy (Sammis, Pleasants, Mansfield and Fort Martin plants), American Electric Power (Cardinal, Mountaineer, Mitchell, Amos and Rockport plants), Tennessee Valley Authority (Allen and New Johnsonville plants), Lightstone Generation (Gavin plant), and Ohio Valley Electric Corporation (Kyger Creek plant). All these power plants are located on the river system, due to the economic and environmental benefits of river transportation. Campbell has shipyard operations at multiple facilities along the rivers but the majority of our employees live on the tugboats. Campbell employs directly about 400 employees and also employs about an additional 100 employees as subcontractors, bringing our total employment to approximately 500 individuals. Campbell strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms promptly in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal industry, and the resulting impacts on our employees, our economy, the market for river transportation services, and the reliability of the electric system will be detrimental and severe. 2 I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Gary D. Statler Jr. Managing Director- Safety, Regulatory Compliance, and HR Campbell Transportation Company Inc. 201 South Johnson Road, Suite 303, Houston, PA 15342 724-743-9027 gstatler@barges.us II. DESCRIPTION OF CAMPBELL Campbell is a private, family owned, integrated inland marine services transportation company has been moving utility coal for over 70 years. Campbell is based in Pittsburgh, PA and has 5 regional offices/facilities. We operate 1,100 barges and 50 towboats, making Campbell one of the largest carriers of coal on the Ohio River. We move in excess of 25 million tons of coal per year. Moving utility coal on the rivers is our primary business. For more detailed information, our website is www.barges.us III. DESCRIPTION OF CAMPBELL'S INTEREST IN PROCEEDING Campbell's economic revenue is directly tied to the continued operation of the baseload coal fired power plants listed above. As a result, the company and its employees will be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, Campbell has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. 3 IV. COMMENTS A. The Premature Retirement of any of the Plants that we Service Will Have a Significant Economic Impact to our Company, Employees, and Region The issuance of a rule preserving baseload coal power plants will preserve economic benefits to Campbell and its employees, which will therefore continue to sustain the regional economy. As noted above, Campbell delivers millions of tons of coal each year to the utility industry, including to the affected baseload coal power plants. On an annual basis, we generate approximately $100 million of revenue from this principal business activity. This represents in excess of 25 million tons of coal per year. Premature closure of any of the affected baseload power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper Campbell's economic performance and will force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting Campbell and its employees. Additionally, the loss of one or more significant customer(s) for Campbell's river transportation services as a result of the premature closure of baseload coal power plants will diminish Campbell's ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. 4 B. Premature Retirement of River Baseload Coal Fired Power Plants Negative Impact to Inland Waterways System The closure of these large baseload river based power plants will negatively impact the other industry sectors that rely on the river transportation industry. The inland river system is the only underutilized mode of transportation for bulk commodities. The method by which the U.S Army Corps of Engineers is depended on the amount of tons shipped on the system. If tonnages are reduced due to premature closings, then the funding for the lock and dams that are critical to the operations of the system will be reduced, causing operational problems for the remaining users of the system. Besides commercial navigation, other users include, municipal and industrial water supply, hydro generation, recreation flood control and well as economic development. C. Premature Retirements of Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region's energyintensive economy in three 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 coal 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 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 of this skilled 5 and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond promptly to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having significant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation's bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as floods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of Campbell's business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. D. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, Campbell strongly urges the FERC to adopt the rule proposed 6 by the DOE as promptly and comprehensively as possible. FERC has a sufficient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting promptly, FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be sufficient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, Heather Longshore Human Resources Business Partner Campbell Transportation Company 7 FE RC ll 7 eLibrary {farmerly Wag rm: EV mqma; E-mail this page File List Number: [1,553 rlptign: Epmrne-nt of Campbell napprtatipn Cpmpany'. Inc. under Type Flle Name Din-I:- FEHC Lelter :Tt: ES 61952 1? 11pm: Ni:- ciescripi gin-en FE [Fe-n Brat-an:= ?25:32:? 3229 Up: I'fp 1i: Um-?Lned Help Funny lama FEED mllna. plasma mammawm? MERGE-MM. Campbell Transportation Company, Inc. Foxpointe Centre 201 S. Johnson Road, Suite 303 Houston, PA 15342 Phone: (724) 743-9550 Fax: (724) 873-9013 Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: October 19, 2017 Grid Resiliency Pricing Rule FERC Docket No. RM18-1-000 COMMENTS OF THE CAMPBELL TRANSPORTATION COMPANY, INC. EMPLOYEES IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy ("DOE") issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to "ensure that certain reliability and 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-fired electric generating stations in the Ohio Valley (Pennsylvania, Ohio, West Virginia, Kentucky, Indiana and Tennessee) will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. 1 Campbell Transportation Company, Inc. ("Campbell") is a river Transportation Company that operates 1,100 barges and 50 tugs on the Ohio River system. Campbell transports coal, limestone, lime, urea and gypsum to a number of coal-fired power plants in the Ohio Valley. These coal-fired power plants are owned by various utilities, including FirstEnergy (Sammis, Pleasants, Mansfield and Fort Martin plants), American Electric Power (Cardinal, Mountaineer, Mitchell, Amos and Rockport plants), Tennessee Valley Authority (Allen and New Johnsonville plants), Lightstone Generation (Gavin plant), and Ohio Valley Electric Corporation (Kyger Creek plant). All these power plants are located on the river system, due to the economic and environmental benefits of river transportation. Campbell has shipyard operations at multiple facilities along the rivers but the majority of our employees live on the tugboats. Campbell employs directly about 400 employees and also employs about an additional 100 employees as subcontractors, bringing our total employment to approximately 500 individuals. Campbell strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms promptly in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal industry, and the resulting impacts on our employees, our economy, the market for river transportation services, and the reliability of the electric system will be detrimental and severe. 2 I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Gary D. Statler Jr. Managing Director- Safety, Regulatory Compliance, and HR Campbell Transportation Company Inc. 201 South Johnson Road, Suite 303, Houston, PA 15342 724-743-9027 gstatler@barges.us II. DESCRIPTION OF CAMPBELL Campbell is a private, family owned, integrated inland marine services transportation company has been moving utility coal for over 70 years. Campbell is based in Pittsburgh, PA and has 5 regional offices/facilities. We operate 1,100 barges and 50 towboats, making Campbell one of the largest carriers of coal on the Ohio River. We move in excess of 25 million tons of coal per year. Moving utility coal on the rivers is our primary business. For more detailed information, our website is www.barges.us III. DESCRIPTION OF CAMPBELL'S INTEREST IN PROCEEDING Campbell's economic revenue is directly tied to the continued operation of the baseload coal fired power plants listed above. As a result, the company and its employees will be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, Campbell has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. 3 IV. COMMENTS A. The Premature Retirement of any of the Plants that we Service Will Have a Significant Economic Impact to our Company, Employees, and Region The issuance of a rule preserving baseload coal power plants will preserve economic benefits to Campbell and its employees, which will therefore continue to sustain the regional economy. As noted above, Campbell delivers millions of tons of coal each year to the utility industry, including to the affected baseload coal power plants. On an annual basis, we generate approximately $100 million of revenue from this principal business activity. This represents in excess of 25 million tons of coal per year. Premature closure of any of the affected baseload power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper Campbell's economic performance and will force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting Campbell and its employees. Additionally, the loss of one or more significant customer(s) for Campbell's river transportation services as a result of the premature closure of baseload coal power plants will diminish Campbell's ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. 4 B. Premature Retirement of River Baseload Coal Fired Power Plants Negative Impact to Inland Waterways System The closure of these large baseload river based power plants will negatively impact the other industry sectors that rely on the river transportation industry. The inland river system is the only underutilized mode of transportation for bulk commodities. The method by which the U.S Army Corps of Engineers is depended on the amount of tons shipped on the system. If tonnages are reduced due to premature closings, then the funding for the lock and dams that are critical to the operations of the system will be reduced, causing operational problems for the remaining users of the system. Besides commercial navigation, other users include, municipal and industrial water supply, hydro generation, recreation flood control and well as economic development. C. Premature Retirements of Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region's energyintensive economy in three 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 coal 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 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 of this skilled 5 and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond promptly to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having significant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation's bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as floods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of Campbell's business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. D. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, Campbell strongly urges the FERC to adopt the rule proposed 6 by the DOE as promptly and comprehensively as possible. FERC has a sufficient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting promptly, FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be sufficient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, [I Nsert name]PAUL STONEBREAKER [Insert business title]MASTER OF M/V RUSS MOBLEY [Insert organization name]CAMPBELL TRANSPORTATION COMPANY 7 FE RC 0 eLibrary (formerly FERRIS) of: 2?;ng E-rna this gage File List ACCESSION Number: 291710236133 TYPE Flle Name PDF Campus T'awsporlatie'v FERC Gen erated PDF 251 iJcc I'fo Ade 1c -J.ec:..est IJcn'e'Lsacl Izeset Comment of Campbell Transponatim CDI?npar?y-l lawns FERG 0n||na_ ??amm nomad Planar-dude .undar 5le 338584 393? 85 Wares? mm umber aid ?add Houston, PA 15342 Phone: (724) 743-9550 Fax: (724) BIB-9013 Campbell Transportation Company, Inc. Foxpointe Centre 201 S. Johnson Road. Suite 303 Federal Energy Regulatory Commission October 19, 2017 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 CAMPBELL TRANSPORTATION COMPANY, INC. EMPLOYEES IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy 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 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-fired electric generating stations in the Ohio Valley Ohio, West Virginia, Kentucky, Indiana and Tennessee) will be compensated fully for their costs of Operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued Operation and maintenance of those generating stations. Campbell Transportation Company, Inc. (?Campbell?) is a river Transportation Company that operates 1,100 barges and 50 tugs on the Ohio River system. Campbell transports coal, limestone, lime, urea and gypsum to a number of coal-?red power plants in the Ohio Valley. These coal-?red power plants are owned by various utilities, including FirstEnergy (Sammis, Pleasants, Mans?eld and Fort Martin plants), American Electric Power (Cardinal, Mountaineer, Mitchell, Amos and Rockport plants), Tennessee Valley Authority (Allen and New Johnsonville plants), Generation (Gavin plant), and Ohio Valley Electric Corporation (Kyger Creek plant). All these power plants are located on the river system, due to the economic and environmental bene?ts of river transportation. Campbell has shipyard operations at multiple facilities along the rivers but the majority of our employees live on the tugboats. Campbell employs directly about 400 employees and also employs about an additional 100 employees as subcontractors, bringing our total employment to approximately 500 individuals. Campbell strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms in order to ensure that owners and operators of coal and nuclear?fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal industry, and the resulting impacts on our employees, our economy, the market for river transportation services, and the reliability of the electric system will be detrimental and severe. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Gary D. Statler Jr. Managing Director- Safety, Regulatory Compliance, and HR Campbell Transportation Company Inc. 201 South Johnson Road, Suite 303, Houston, PA 15342 724-743-9027 gstatler@barges.us II. DESCRIPTION OF CAMPBELL Campbell is a private, family owned, integrated inland marine services transportation company has been moving utility coal for over 70 years. Campbell is based in Pittsburgh, PA and has 5 regional offices/facilities. We operate 1,100 barges and 50 towboats, making Campbell one of the largest carriers of coal on the Ohio River. We move in excess of 25 million tons of coal per year. Moving utility coal on the rivers is our primary business. For more detailed information, our website is DESCRIPTION OF INTEREST IN PROCEEDING Campbell?s economic revenue is directly tied to the continued operation of the baseload coal fired power plants listed above. As a result, the company and its employees will be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, Campbell has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered ?thher by these comments supporting the continued operation of coal and nuclear?fueled generating stations in organized markets. IV. COMMENTS A. The Premature Retirement of any of the Plants that we Service Will Have a Signi?cant Economic Impact to our Company, Employees, and Region The issuance of a rule preserving baseload coal power plants will preserve economic bene?ts to Campbell and its employees, which will therefore continue to sustain the regional economy. As noted above, Campbell delivers millions of tons of coal each year to the utility industry, including to the affected baseload coal power plants. On an annual basis, we generate approximately $100 million of revenue from this principal business activity. This represents in excess of 25 million tons of coal per year. Premature closure of any of the affected baseload power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper Campbell?s economic performance and will force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting Campbell and its employees. Additionally, the loss of one or more significant customer(s) for Campbell?s river transportation services as a result of the premature closure of baseload coal power plants will diminish Campbell?s ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. B. Premature Retirement of River Baseload Coal Fired Power Plants - Negative Impact to Inland Waterways System The closure of these large baseload river based power plants will negatively impact the other industry sectors that rely on the river transportation industry. The inland river system is the only underutilized mode of transportation for bulk commodities. The method by which the US Army Corps of Engineers is depended on the amount of tons shipped on the system. If tonnages are reduced due to premature closings, then the funding for the lock and dams that are critical to the operations of the system will be reduced, causing operational problems for the remaining users of the system. Besides commercial navigation, other users include, municipal and industrial water supply, hydro generation, recreation ?ood control and well as economic development. C. Premature Retirements of Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region?s energy- intensive economy in three 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 coal 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 5 and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having signi?cant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation?s bulk power system. The availability of a long-term supply of ?le] at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as ?oods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of Campbell?s business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. D. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, Campbell strongly urges the FERC to adopt the rule proposed by the DOE as and comprehensively as possible. FERC has a suf?cient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs ofoperation will only exacerbate the problem of premature closures. In acting FERC should direct operators oforganized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be sufficient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended Operation of these much-needed power plants. Respectfully m'tted, Steve Grizzel Director of Safety, Training Claims Management Campbell Transportation Company, Inc. FE RC 0 eLibrary (formerly FERRIS) a; 3 ?1 "m'm'gf?'li E-"na his gage File List ACCESSION Number: 29171023532? Comment of Campbell Transportation Compar?y, Type Flle Name 5le PDF FERC Lem;r Pawel 10 23 45793 No cescripl or given FERC Gen eratec? PDF 3"175 Ucc I'fo Ade 1c -J.ec:..est Danni?Luau lie-set Help Flal'lmz.I lawns FERG Onllna. plasma ass-ma?a. Campbell Transportation Company, Inc. Foxpointe Centre 201 S. Johnson Road, Suite 303 Houston, PA 15342 Phone: (724) 743-9550 Fax: (724) 873-9013 Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: October 19, 2017 Grid Resiliency Pricing Rule FERC Docket No. RM18-1-000 COMMENTS OF THE CAMPBELL TRANSPORTATION COMPANY, INC. EMPLOYEES IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy ("DOE") issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to "ensure that certain reliability and 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-fired electric generating stations in the Ohio Valley (Pennsylvania, Ohio, West Virginia, Kentucky, Indiana and Tennessee) will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. 1 Campbell Transportation Company, Inc. ("Campbell") is a river Transportation Company that operates 1,100 barges and 50 tugs on the Ohio River system. Campbell transports coal, limestone, lime, urea and gypsum to a number of coal-fired power plants in the Ohio Valley. These coal-fired power plants are owned by various utilities, including FirstEnergy (Sammis, Pleasants, Mansfield and Fort Martin plants), American Electric Power (Cardinal, Mountaineer, Mitchell, Amos and Rockport plants), Tennessee Valley Authority (Allen and New Johnsonville plants), Lightstone Generation (Gavin plant), and Ohio Valley Electric Corporation (Kyger Creek plant). All these power plants are located on the river system, due to the economic and environmental benefits of river transportation. Campbell has shipyard operations at multiple facilities along the rivers but the majority of our employees live on the tugboats. Campbell employs directly about 400 employees and also employs about an additional 100 employees as subcontractors, bringing our total employment to approximately 500 individuals. Campbell strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms promptly in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal industry, and the resulting impacts on our employees, our economy, the market for river transportation services, and the reliability of the electric system will be detrimental and severe. 2 I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Gary D. Statler Jr. Managing Director- Safety, Regulatory Compliance, and HR Campbell Transportation Company Inc. 201 South Johnson Road, Suite 303, Houston, PA 15342 724-743-9027 gstatler@barges.us II. DESCRIPTION OF CAMPBELL Campbell is a private, family owned, integrated inland marine services transportation company has been moving utility coal for over 70 years. Campbell is based in Pittsburgh, PA and has 5 regional offices/facilities. We operate 1,100 barges and 50 towboats, making Campbell one of the largest carriers of coal on the Ohio River. We move in excess of 25 million tons of coal per year. Moving utility coal on the rivers is our primary business. For more detailed information, our website is www.barges.us III. DESCRIPTION OF CAMPBELL'S INTEREST IN PROCEEDING Campbell's economic revenue is directly tied to the continued operation of the baseload coal fired power plants listed above. As a result, the company and its employees will be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, Campbell has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. 3 IV. COMMENTS A. The Premature Retirement of any of the Plants that we Service Will Have a Significant Economic Impact to our Company, Employees, and Region The issuance of a rule preserving baseload coal power plants will preserve economic benefits to Campbell and its employees, which will therefore continue to sustain the regional economy. As noted above, Campbell delivers millions of tons of coal each year to the utility industry, including to the affected baseload coal power plants. On an annual basis, we generate approximately $100 million of revenue from this principal business activity. This represents in excess of 25 million tons of coal per year. Premature closure of any of the affected baseload power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper Campbell's economic performance and will force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting Campbell and its employees. Additionally, the loss of one or more significant customer(s) for Campbell's river transportation services as a result of the premature closure of baseload coal power plants will diminish Campbell's ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. 4 B. Premature Retirement of River Baseload Coal Fired Power Plants Negative Impact to Inland Waterways System The closure of these large baseload river based power plants will negatively impact the other industry sectors that rely on the river transportation industry. The inland river system is the only underutilized mode of transportation for bulk commodities. The method by which the U.S Army Corps of Engineers is depended on the amount of tons shipped on the system. If tonnages are reduced due to premature closings, then the funding for the lock and dams that are critical to the operations of the system will be reduced, causing operational problems for the remaining users of the system. Besides commercial navigation, other users include, municipal and industrial water supply, hydro generation, recreation flood control and well as economic development. C. Premature Retirements of Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region's energyintensive economy in three 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 coal 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 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 of this skilled 5 and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond promptly to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having significant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation's bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as floods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of Campbell's business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. D. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, Campbell strongly urges the FERC to adopt the rule proposed 6 by the DOE as promptly and comprehensively as possible. FERC has a sufficient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting promptly, FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be sufficient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, Casey Powell Harbor Captain Campbell Transportation 7 FE RC 0 WE eLibrary (formerly FERRIS) of: 2:1 mgg?L; E-rna this gage File List ACCESSION Number: 291710236531 Des: rlption; Comment 0? Campbell Tlansponatim Company. Inc. under Type Flle Name Slze PDF 20? 2? 23 19 396543 No descriptor given FERC Generate: PDF 'Jec I'fo 1c Jen-est Ileset He FERG 0n||na_ WWUHJI enema-35m. Mums? Houston. PA 15342 Phone: (724) 743-9550 Fax: (724) 873-9013 - Campbell Transportation Company, Inc. Foxpointe Centre 201 S. Johnson Road. Suite 303 Federal Energy Regulatory Commission October 19, 2017 Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: Grid Resiliency Pricing Rule FERC Docket No. COMMENTS OF THE CAMPBELL TRANSPORTATION COMPANY, INC. EMPLOYEES IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy 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 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 in the Ohio Valley Ohio, West Virginia, Kentucky, Indiana and Tennessee) will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term Viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. Campbell Transportation Company, Inc. (?Campbell?) is a river Transportation Company that operates 1,100 barges and 50 tugs on the Ohio River system. Campbell transports coal, limestone, lime, urea and gypsum to a number of coal-?red power plants in the Ohio Valley. These coal-?red power plants are owned by various utilities, including FirstEnergy (Sammis, Pleasants, Mans?eld and Fort Martin plants), American Electric Power (Cardinal, Mountaineer, Mitchell, Amos and Rockport plants), Tennessee Valley Authority (Allen and New ohnsonville plants), Li Generation (Gavin plant), and Ohio Valley Electric Corporation (Kyger Creek plant). All these power plants are located on the river system, due to the economic and environmental bene?ts of river traHSportation. Campbell has shipyard operations at multiple facilities along the rivers but the majority of our employees live on the tugboats. Campbell employs directly about 400 employees and also employs about an additional 100 employees as subcontractors, bringing our total employment to approximately 500 individuals. Campbell strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal industry, and the resulting impacts on our employees, our economy, the market for river transportation services, and the reliability of the electric system will be detrimental and severe. 1. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Gary D. Statler Jr. Managing Director- Safety, Regulatory Compliance, and HR Campbell Transportation Company Inc. 201 South Johnson Road, Suite 303, Houston, PA 15342 724-743-9027 gstatler@barges.us 11. DESCRIPTION OF CAMPBELL Campbell is a private, family owned, integrated inland marine services transportation company has been moving utility coal for over 70 years. Campbell is based in Pittsburgh, PA and has 5 regional of?ces/facilities. We operate 1,100 barges and 50 towboats, making Campbell one of the largest carriers of coal on the Ohio River. We move in excess of 25 million tons of coal per year. Moving utility coal on the rivers is our primary business. For more detailed information, our website is 111. DESCRIPTION OF INTEREST IN PROCEEDING Campbell?s economic revenue is directly tied to the continued operation of the baseload coal ?red power plants listed above. As a result, the company and its employees will be directly affected by the actions taken by the FERC and Operators of organized markets in this proceeding. Thus, Campbell has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. IV. COMMENTS A. The Premature Retirement of any of the Plants that we Service Will Have a Signi?cant Economic Impact to our Company, Employees, and Region The issuance of a rule preserving baseload coal power plants will preserve economic bene?ts to Campbell and its employees, which will therefore continue to sustain the regional economy. As noted above, Campbell delivers millions of tons of coal each year to the utility industry, including to the affected baseload coal power plants. On an annual basis, we generate approximately $100 million of revenue from this principal business activity. This represents in excess of 25 million tons of coal per year. Premature closure of any of the affected baseload power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper Campbell?s economic performance and will force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting Campbell and its employees. Additionally, the loss of one or more signi?cant customer(s) for Campbell?s river transportation services as a result of the premature closure of baseload coal power plants will diminish Campbell?s ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. B. Premature Retirement of River Baseload Coal Fired Power Plants - Negative Impact to Inland Waterways System The closure of these large baseload river based power plants will negatively impact the other industry sectors that rely on the river transportation industry. The inland river system is the only underutilized mode of transportation for bulk commodities. The method by which the U.S Army Corps of Engineers is depended on the amount of tons shipped on the system. If tonnages are reduced due to premature closings, then the ?mding for the lock and dams that are critical to the operations of the system will be reduced, causing operational problems for the remaining users of the system. Besides commercial navigation, other users include, municipal and industrial water supply, hydro generation, recreation ?ood control and well as economic development. C. Premature Retirements of Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region?s energy- intensive economy in three 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 coal 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 5 and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having signi?cant on-site ?tel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation?s bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential ?Jel supply disruptions that might be caused by natural disasters such as ?oods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation ?om an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of Campbell?s business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. D. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, Campbell strongly urges the FERC to adopt the rule proposed by the DOE as and comprehensively as possible. FERC has a sufficient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be suf?cient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, -, 1'1. J?b/ Dan Lacek Managing Director? Operations Campbell Transportation Company FE RC 0 7? WE eLibrary (formerly FERRIS) of: 2:1 mgg?L; E-rna this gage File List A: SESSION Number: 291710236533 Comment of Elainbridge Chemical Compar?y ur?der Type Flle Name 5le L?icraS-oft 'u?Jo'd Che"'ca .DDCX 234-15 No script or given FERC Gen erated PDF ?2511295 PDF ?349 iJcc I'fo Ade 1c -J.ec:..est IJcn'e'Lsacl Izeset Helu FERG 0n||na_ WWUHJI ass-ma?a. Mums? October 23, 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 BAINBRIDGE CHEMICAL COMPANY IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy ("DOE") issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to "ensure that certain reliability and 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-fired electric generating stations in Pennsylvania will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. Bainbridge Chemical Company (BCC) is a manufacturer of emulsified sulfur for use by the Shippenport, PA power plant owned by First Energy power plant located in [insert location of coal and/or nuclear power plant]. [Insert shortened name or acronym of company] has manufacturing facilities at [insert facility location], and has a total of [insert number] employees engaged in the production/provision of [name product/service]. Bainbridge Chemical Company strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms promptly in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal and/or nuclear industry, and the resulting impacts on our employees, our economy, the market for emulsified sulfur, and the reliability of the electric system will be detrimental and severe. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Bainbridge Chemical Company Mr. Jesse Maranville, President PO Box 1165 Valdosta GA 31603-1165 229-244-000 jesse@georgiagulfsulfur.com II. DESCRIPTION OF BAINBRIDGE CHEMICAL COMPANY Bainbridge Chemcial Company is a manufacturer of sulfur products from the sulfur burned off in the natural gas plants of the Florida panhandle. BBC takes molten sulfur and produces flowable sulfur for power plant scrubbers to help decrease the emissions of gas from coal fire power plants. BBC relies on coal fire power plants and pulp and paper mills to use this product. III. DESCRIPTION OF BAINBRIDGE CHEMICAL COMPANY'S INTEREST IN PROCEEDING Bainbridge Chemical Company]'s economic revenue is directly tied to the continued operation of the baseload First Energy - Shippenport power plant. As a result, the company and its employees may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, Bainbridge Chemical Company has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclearfueled generating stations in organized markets. IV. COMMENTS A. The Premature Retirement of First Energy - Shippenport, PA Will Have a Significant Economic Impact to Company, Employees, and Region The issuance of a rule preserving baseload coal fire power plants will preserve economic benefits to Bainbridge Chemical Company and its employees, which will therefore continue to sustain the regional economy. As noted above, Bainbridge Chemical Company provides emulsified sulfur to the utility industry, including to affected baseload coal fire power plants. Bainbridge Chemical Company revenue is estimated at $500,000 per yer which provides employment for workers in South Georgia. Premature closure of affected baseload coal fire power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will Bainbridge Chemical Company's economic performance and may force it to lay off employees as a necessary costsaving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal fire power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting Bainbridge Chemical Company and its employees. Additionally, the loss of a significant market buyer for BBC emulsified sulfur product as a result of the premature closure of baseload coal fire power plants will diminish BBC's ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. B. Premature Retirements of Baseload [Coal and/or Nuclear] Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal fired power plants will maintain a reliable supply of electricity for the region's energy-intensive economy in three 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 coal fired 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 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 of this skilled and experienced group of workers, and the possible replacement of these workers with more distant and perhaps lessskilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond promptly to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having significant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation's bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as floods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of Bainbridge Chemical Company's business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. C. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Fired Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, Bainbridge Chemical Company strongly urges the FERC to adopt the rule proposed by the DOE as promptly and comprehensively as possible. FERC has a sufficient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting promptly, FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be sufficient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, Jesse Maranville President Bainbridge Chemical Company FE RC ll 7 eLibrary {farmerly is" rm: EV mqma; E-mail this gage File List Ancesslun Number: 2D1?1a1g-50m Enmrne-nt Di E. WILCDK under Type Flle Name Elze Emmi-L 'i'u'ilccw. FEHC Duck-a1 533155 cieacripmr' give-n FE FEE Genera-21:3 9.325.: Um: I'fcu min: 1-: Anzac-est lites-9t October 23, 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 BABCOCK WILCOX IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy 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 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 in Ohio will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. Babcock Wilcox is a global leader in the supply of advanced energy and environmental technologies and services for utility and industrial markets, including electric utilities such as FirstEnergy. has manufacturing operations in the US and in several locations around the world and has several thousand employees engaged in the production/provision of power generation systems, equipment and services that are needed for the continued reliable operation of baseload generating facilities owned by electric utilities throughout the region, including those operated by FirstEnergy. Babcock Wilcox strongly supports the Proposal, and urges the ERC to direct operators of organized markets to adopt appropriate compensation mechanisms in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. Failure to act will threaten the viability of the coal and/or nuclear industry, and the resulting impacts on our employees, our economy, the market for products and services for the power generation industry, and the reliability of the electric system will be detrimental and severe. 1. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Mark Low Senior Vice President, Power Segment Babcock Wilcox 20 South Van Buren Avenue, Barberton, Ohio 44203 330-860-1890 mslow@babcock.com II. DESCRIPTION OF BABCOCK WILCOX Babcock Wncox is comrn qite ed to 11e1u1rg its customers p1ov1r ere-liable, ef11cient and environmentally sustainable fossil fuel power, and offers prove? 11. systems custom- designed technologies, retro?ts, parts, services an more The company 15 at so one 31 the world's leading c0?11racto1s and s11up?1ers or equipment an i-tec1mologies that turn solid waste and biomass into thennai energy. 1t also provides customv- engineered techno1ogies ?01 p011? utio 11. control, coating and drying, process steam generation, cooling, heat recovery and other applications for a wide variety of industries. DESCRIPTION OF BABCOCK INTEREST IN PROCEEDING As noted above, the employees of Babcock Wilcox provide products and services to the electric utility industry that are essential to the continued and reliable operation of baseload coal generation facilities. A key segment of our business is dependent on the continued operation of electric generation facilities, including baseload coal power plants. As a result, the wages, terms and conditions of employment of our workers, and the conduct of business may be directly affected by the actions taken by FERC and the operators of organized markets in this proceeding. Thus, Babcock Wilcox has a direct and substantial interest in this proceeding. IV. COMMENTS A. The Premature Retirement of Baseload Coal Power Plants Will Have a Severe Economic Impact on Ohio The jobs and local economies in the communities in which suppliers to the affected coal generating facilities are located are dependent on the electric power industry in the region. The jobs of at least 1,000 skilled employees at in Ohio are dependent on providing products and services to baseload coal power plants, and result in revenues approaching $1 billion per year. It is therefore evident that the supply of products and services to baseload coal power plants makes a signi?cant contribution to the strength of the economy in this region. The premature deactivation of baseload generating facilities will have a signi?cant adverse impact on the local economy that could result in signi?cant job losses at Babcock Wilcox, and at the several other vendors engaged in providing goods and services needed to support operation of base load generating facilities. Overall, thousands more workers are employed indirectly to support operation of those facilities. In addition to the direct economic impact related to a premature closing of baseload coal generation facilities (including a reduction in revenue to Babcock Wilcox and the resulting job losses and rising unemployment), the regional economy will also suffer indirectly. The loss of sales of materials and supplies required to support irstEnergy?s power plants would be expected to result in a loss of tax revenues relied upon by local communities for the essential municipal services that they provide. Additionally, the supply of goods and services needed to support continued operation of baseload generating facilities bene?ts from the availability of economies of scale. Loss of the market for these goods and services as a result of the premature deactivation of such generating facilities would be expected to make the supply of such goods and services less ef?cient, and would thereby lead to higher prices for such goods and services consumed by the generation facilities that remain in operation. B. The Premature Retirement of Baseload Coal Power Plants Can Disrupt Fuel Supply Markets The premature deactivation of coal-?red generating facilities will be particularly disruptive to companies in the coal supply industry. Although coal suppliers rely heavily on sales of coal required for generation of electricity to sustain their mining operations, deactivation of coal-fired generating plants will eliminate a major consumer of coal from the market, and may thereby cause existing mining operations to be curtailed or shut down, with the attendant loss of jobs, commodity scarcity, and commodity price escalation. At the same time, employment of workers engaged in the transportation of coal, whether by truck, barge, or train, would be diminished. Finally, the termination of long-term coal supply contracts for sales of coal to electric utilities may also cause the market for supply of coal to remaining sellers and purchasers of coal to become more volatile, which could negatively impact coal power plants located in states operating under vertically-integrated cost-of?service regulation. C. The Premature Retirement of Baseload Coal Power Plants Will Diminish System Reliability The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region?s energy-intensive economy in three 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 coal 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, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having signi?cant on?site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation?s bulk power system. The availability of a long-tenn supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as ?oods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. D. The Commission Must Adopt the Proposed Rule Without Delay In order to mitigate the risk that such baseload generating units may be deactivated prematurely, Babcock Wilcox strongly urges ERC to adopt the rule proposed by the DOE as and comprehensively as possible. FERC has a suf?cient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of pre-mature closures. In acting FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be suf?cient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitte Mark Low Senior Vice President, Power Segment Babcock Wilcox FE RC eLibrary (formerly FERRIS) 5' fe -. I rcqov E-mail his gage File List Accesslon Number: 201T1013-5063 Comment at Industry.r Ten'n'rnal and Salvage Lndar RM1B-1. Type Flle Name 5le FERC SIGNED 255T94 No cesc'iptor' give-n FERC Generated PDF 253? iJcc I'fo Ada 1c deal-est Dena-Load Izeset Help October 13, 2017 Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: Grid Resiliency Pricing Rule FERC Docket No. COMMENTS OF THE PRESIDENT OF INDUSTRY TERMINAL AND SALVAGE IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy 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 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?fired electric generating stations in Ohio, and West Virginia will be compensated ?illy for their costs of operation. Adoption of that rule will thus sustain the long- term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. Industry Terminal and Salvage (ITS) is a service provider for use by the The Bruce Mans?eld power plant owned by First Energy Corporation located in Shippingport, ITS has barge ?eeting and marine service facilities at Industry, and has a total of seventy employees engaged in the production/provision of barge ?eeting, towing, barge loading, barge and boat repairs, and barge cleaning. ITS strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal and/or nuclear industry, and the resulting impacts on our employees, our economy, the market for ITS, and the reliability of the electric system will be detrimental and severe. 1. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Bradley Busatto President Industry Terminal and Salvage Company 107 Canton Street P.O. Box 255 Industry, 15052 (724)643-1871 bradbusatto@yahoo.com II. DESCRIPTION OF INDUSTRY TERMINAL AND SALVAGE ITS is a family owned and operated founded in 1979 and has operated continuously since then. ITS owns and operates towboats and barge ?eets on the Upper Ohio River. Barge towing, ?eeting, cleaning, repairs, and unloading of barges comprises the bulk of our business. ITS is a Member of the AWO and follows its Responsible Carrier Program. DESCRIPTION OF INDUSTRY TERMINAL AND INTEREST IN PROCEEDING economic revenue is directly tied to the continued operation of the base load for the Bruce Mans?eld coal-?red power plant. As a result, the company and its employees may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, ITS has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. IV. COMMENTS A. The Premature Retirement of the Bruce Mans?eld Plant Will Have a Signi?cant Economic Impact to Company, Employees, and Region The issuance of a rule preserving baseload coal power plants will preserve economic bene?ts to ITS and its employees, which will therefore continue to sustain the regional economy. As noted above, ITS provides barge and marine services to the utility industry, including to affected baseload coal power plants. The annual revenue that is generated by the coal ?red power plant services we provide is approximately $6,000,000 per year. Premature closure of affected baseload coal power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper Industry Terminal and Salvage?s economic performance and may force it to lay off employees as a necessary cost? saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal ?red power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting ITS and its employees. Additionally, the loss of a signi?cant market buyer for barge and marine services as a result of the premature closure of baseload coal ?red power plants will diminish ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. B. Premature Retirements of Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region?s energy-intensive economy in three 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 coal 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 ?llfill 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, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having signi?cant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation?s bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to Withstand potential fuel supply disruptions that might be caused by natural disasters such as ?oods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an offasite source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. C. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, ITS strongly urges the FERC to adopt the rule proposed by the DOE as and comprehensively as possible. FERC has a suf?cient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be suf?cient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully 7. hmitted, I . PRESIDENT INDUSTRY TERMIAL AND SALVAGE COMPANY FE RC 0 7? WE eLibrary (formerly FERRIS) of: 2:1 mgg?L; E-rna this gage Accesslon Number: Desc?p?on: Type PDF FERC PDF Gen erated iJcc I'fo Ade 1c -J.ec:..est File List Comment of DeNDxDirect, LLC Lndar RM1B-1. Flle Name 5le DeNoxDi-ect FERC PBF 95573 No cescripl or given 102360 Haw-Load Izeset Mm Dr call ass-macro. Hamel]! udaaullrutrm] October 12, 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 DeNoxDirect, LLC IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy ("DOE") issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to "ensure that certain reliability and 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-fired electric generating stations in West Virginia be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. DeNoxDirect is a National Provider of Urea Reagent for use by multiple power plants located Ohio, West Virginia, and Pennsylvania. DeNoxDirect, LLC has manufacturing facilities in Ohio and West Virginia and has a total of 14 employees or contractors engaged in the production/provision of urea manufacturing and/or delivery and logistics. DeNoxDirect, LLC strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms promptly in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal and/or nuclear industry, and the resulting impacts on our employees, our economy, the market for Industrial Reagent, and the reliability of the electric system will be detrimental and severe. In Summary, we believe the attack on Coal and Nuclear needs to cease, enough is enough and we applaud FERC for its interest in adopting appropriate measures. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Matthew Garrett Managing Partner DeNoxDirect, LLC Denver, CO (800) 362-8399 matt@denoxdirect.com II. DESCRIPTION OF DeNoxDirect, LLC DeNoxDirect is a leading provider of urea reagent powder and solution in North America. Through our extensive sales and logistics network we provide over 25 large customers with the reagent they need daily. Our urea reagent is used in removing millions of tons NOx throughout North America annually. III. DESCRIPTION OF DeNoxDirect, LLC's INTEREST IN PROCEEDING DeNoxDirect, LLC's economic revenue is directly tied to the continued operation of the baseload operations of approximately 6 power generating facilities under review by FERC. As a result, the company and its employees may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, DeNoxDirect,LLC has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclearfueled generating stations in organized markets. IV. COMMENTS A. The Premature Retirement of any of FirstEnergy's plants Will Have a Significant Economic Impact to Company, Employees, and Region The issuance of a rule preserving baseload power plants will preserve economic benefits to DeNoxDirect, LLC and its employees, which will therefore continue to sustain the regional economy. As noted above, DeNoxDirect, LLC provides Urea Reagent the utility industry, including to affected baseload FirstEnergy power plants. Premature closure of affected baseload power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper our economic performance and may force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting our company and the whole region. Additionally, the loss of a significant market buyer for urea as a result of the premature closure of baseload power plants will diminish our ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. B. Premature Retirements of Baseload Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload power plants will maintain a reliable supply of electricity for the region's energy-intensive economy in three 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. 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 of this skilled and experienced group of workers, and the possible replacement of these workers with more distant and perhaps lessskilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond promptly to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having significant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation's bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as floods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of DeNoxDirect's business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. C. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, DeNoxDirect, LLC strongly urges the FERC to adopt the rule proposed by the DOE as promptly and comprehensively as possible. FERC has a sufficient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting promptly, FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be sufficient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, Matt Garrett Managing Partner DeNoxDirect, LLC FE RC ll 7 eLibrary {farmerly Wag rm: EV E-mail this gage Number: [1,553 rlptign: Enmrne-nt of Happily.I .1 Transit GEL. Inc. Lander Type Flle Name Elze teammate. MST Re Ru Ni:- cie script gin-en FE HE [Fe-n Brat-an:= lg?ll?l?i?QE Um: I'fzu Fad: 1i: Um-?Lned He'll:L Funny lama FEED mllna. plasma MERGE-MM. October 24, 2017 Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: Grid Resiliency Pricing Rule FERC Docket No. 3-1-000 COMNIENTS 0F SUPPLY TRANSIT INC. IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy issued the ?Grid Resiliency Pricing Rule? (the directing the Federal Energy Regulatory Commission to adopt a rule requiring operators of organized markets to ?ensure that certain reliability and resiliency attributes of electric generation sources are ?Jlly valued.? Such a rule, as contemplated by the regulatory language of the Proposal, will ensure that existing nuclear and coal??red electric generating stations in western will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. Supply Transit Co., Inc. is dry bulk goods trucking operation that handles materials such as scrubber stone and coal, for use by Bruce Mans?eld coal power plant, and others, owned by FirstEnergy Corp, located in Shippingport, PA. has transloading and material handling facilities in Portersville, PA, and has more than one hundred employees engaged in the productionfprovision of dry bulk goods trucking. strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal and/or nuclear industry, and the resulting impacts on our employees, our economy, the market for trucking, and the reliability of the electric system will be detrimental and severe. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Mark President Supply Transit Co., Inc. 296 Currie Road Portersville, PA 1605] 724-368?8040 II. DESCRIPTION OF SUPPLY TRANSIT CO., INC. Dry bulk goods trucking operation, located in Portersville, PA. hauls a variety of dry bulk products between in the Pittsburgh region and throughout the Midwest and Mid- Atlantic. McCIymonds provides a diverse range of services, but primarily runs dump trucks, which are primed for the scrubber stone, coal and other materials required in the electric generation business. DESCRIPTION OF SUPPLY TRANSIT CO., INTEREST IN PROCEEDING economic revenue is directly tied to the continued operation of the baseload Bruce Mans?eld power plant. As a result, the company and its employees may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. IV. COMMENTS A. The Premature Retirement of Bruce Mans?eld Will Have :1 Signi?cant Economic Impact to Company, Employees, and Region The issuance of a rule preserving baseload coal andr?or nuclear power plants will preserve economic bene?ts to and its employees, which will therefore continue to sustain the regional economy. As noted above, provides material handling and transloading to the utility industry, including to affected baseload coal power plants. On an annual basis, generates approximate $2,000,000 per year of revenue from servicing coal ?red power plants. Premature closure of affected baseload coal power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper economic performance and may force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting and its employees. Additionally, the loss of a signi?cant market buyer for services as a result of the premature closure of baseload coal power plants will diminish ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. B. Premature Retirements of Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region?s energy-intensive economy in three 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 coal 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, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having signi?cant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation?s bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as ?oods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. C. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, strongly urges the FERC to adopt the rule proposed by the DOE as and comprehensively as possible. FERC has a suf?cient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be suf?cient to ensure that critical power plants can continue to operate for their remaining service lives, without the prospect of repeated reexamination and adjustment to their market compensation. The uncertainty that less than comprehensive and enduring market rules will engender may defeat the very purpose of preserving the extended operation of these much-needed power plants. Res eetfully submitted, ecre en its IMH- 6% Mark W. MeClymonds 4 *5 ymands President Supply Transit (30., Inc. FE RC 7? 7 eLibrary {farmerly mien; an: a. E-mail this gage File List Ancesslon Number: Enmrne-nt of BRANCH ENERGY. Inc under Ema-1. Flle Name Elze BRANCH LETTER TEI 35353-33 de scrip-1 gin-en FE HE [Fe-n Brat-2:5 Enamels: Um: I'fzu Fad: 1c- lites-net NORTH BRANCH ENERGY, INC BOX 1064 Coraopolis, 15108 7249471966 Telephone 7249471968 Fax October 20,, 2017 Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington} DC 20426 Re: Grid Resiliency PricingRule FERC Docket No. RM18-1-000 COMNIENTS OF NORTH BRANCH ENERGY INC. IN SUPPORT OF THE PRPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy 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 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 in Western and Ohio will be compensated ?rlly for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous Vendors throughout the region to support the continued operation and maintenance of those generating stations. North Branch Energy, Inc. is a supplier of products for use by the Bruce Mans?eld and WH. Sammis power plants owned by First Energy Corp. The plants are located in Shippingport, and Stratton, Ohio respectively. NBE has a waste coal operation located off of Route 980 in Bulger, and has a contractor and his employees engaged in the reclamation of a legacy waste coal pile. NBE strongly supports the Proposal, and urges the FERC to direct Operators of organized markets to adopt apprOpriate compensation mechanisms in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the Viability of the coal and/or nuclear industry, and the resulting impacts on our employees, our economy, the market for coal recovery, coal sales, waste coal operations and the reliability of the electric system will be detrimental and severe. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Raymond J. Bologna President North Branch Energy PO. Box 1064 Coraopolis, PA 15108 724-947?1966 RIB1900@aol.com 11. DESCRIPTION OF NORTH BRANCH ENERGY North Branch Energy, Inc. is a waste coal recovery company, which is currently conducting coal recovery operation and reclamation on a large waste coal pile. 1H. DESCRIPTION OF NORTH BRANCH ENERGY, INCIS INTEREST IN PROCEEDING North Branch Energy, Inc.? 5 economic revenue is directly tied to the continued operation of the baseload of Bruce Mans?eld and WH. Sammis power plants. As a result, the company and its employees may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, North Branch Energy, Inc. has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. IV. COMMENTS A. The Premature Retirement of Bruce Mans?eld or W.H. Sammis Power Plants Will Have 3 Signi?cant Economic Impact to Company, Employees, and Region The issuance of a rule preserving baseload coal power plants will preserve economic bene?ts to North Branch Energy, Inc. and its employees, which will therefore continue to sustain the regional economy. As noted above, North Branch Energy, Inc. provides a waste coal operation to the utility industry, including to affected baseload coal power plants. Premature closure of affected baseload coal power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper North Branch Energy? economic performance and may force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting North Branch Energy, Inc. and its employees. Additionally, the loss of a signi?cant market buyer for North Branch Energy, Incis waste coal, as a result of the premature closure of baseload coal power plants will diminish North Branch Energy, Inc?s ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. B. Premature Retirements of Baseload [Coal and/or Nuclear] Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued Operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region?s energy-intensive economy in three 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 coal 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? 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 of this skilled and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less?skilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having signi?cant on?site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-meled generating stations provide essential reliability and resiliency support to the nation?s bulk power system. The availability of a long-term supply of ?rel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as ?oods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of ?rel to these generators, which is not dependent on transportation from an off?site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of North Branch Energy, Inc. 3 business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. C. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely. North Branch Energy. Inc. strongly urges the FERC to adopt the rule proposed by the DOE as and comprehensively as possible. FERC has a suf?cient record on which to act. As noted by the Secretary of the DOE. the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their costs of Operation will only exacerbate the problem of premature closures. In acting FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be suf?cient to ensure that critical power plants can continue to operate for their remaining service lives. 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 may defeat the very purpose of preserving the extended operation of these much?needed power plants. submitted. 41?? a. .Ij. 13air? air-f3? Li. i if} .- exited? Lia.? if" eff?" {?36 . - Raymond J. Bolognd President North Branch Energy. Inc. eLibrery {fizwrr'rierljir ere; 2* dz: mm E-n'iail this gage File List Ancesslen Number: Eemment ef?i??'ieeling and Lake Erie Railway.- un-zler Type Flle Name Elze We'd FEHC Ni:- cieecripi gin-en FE F13 Gen ereteci iJei: I'fe Pd: 1: Hell:L Funny lemma FEED Fianna windfall-Maren? MERGE-MFG. October 24, 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 WHEELING & LAKE ERIE IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy ("DOE") issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to "ensure that certain reliability and 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-fired electric generating stations in Ohio will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. The Wheeling & Lake Erie (W&LE) is supplier of services for use by the First Energy and Rhino Energy power plants owned by Rhino Resource Partners and FirstEnergy Corporation with power plants located in Cadiz, OH and Akron, OH. Rhino Energy has manufacturing facilities at Jewett, OH and it is unknown how many employees are at this facility. FirstEnergy Corporation has manufacturing facilities in Akron, OH and the company has a total of 15,500 employees engaged in the production/provision of electricity. The W&LE strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms promptly in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal and/or nuclear industry, and the resulting impacts on our employees, our economy, the market for coal moved by rail, and the reliability of the electric system will be detrimental and severe. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Drew Nelson VP Sales and Marketing Wheeling & Lake Erie Railway 100 East First Street, Brewster, OH 44613 330-767-7282 dnelson@wlerwy.com II. DESCRIPTION OF THE WHEELING & LAKE ERIE RAILWAY The W&LE is the largest Ohio-based regional railroad, operating over 840 miles of track in Ohio, Pennsylvania, and West Virginia while moving over 150,000 carloads per year to 120 customers. The W&LE is privately owned and employees over 425 people. There are six major rail yards across the system and connections with three Class I carriers (Norfolk Southern, CSXT, Canadian National). The W&LE also has a locomotive fleet of over 95 locomotives, as well as an in-house locomotive and car repair shop. III. DESCRIPTION OF THE WHEELING & LAKE ERIE RAILWAY'S INTEREST IN PROCEEDING The W&LE's economic revenue is directly tied to the continued operation of the baseload Rhino Energy and FirstEnergy power plants. As a result, the company and its employees may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, the W&LE has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. IV. COMMENTS A. The Premature Retirement of Rhino Energy and FirstEnergy Will Have a Significant Economic Impact to Company, Employees, and Region The issuance of a rule preserving baseload coal power plants will preserve economic benefits to the W&LE and its employees, which will therefore continue to sustain the regional economy. As noted above, the W&LE provides rail transportation to the utility industry, including to affected baseload coal power plants. Estimated revenue from the movement of coal via rail is $1 million/year. Premature closure of affected baseload coal power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper the W&LE's economic performance and may force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting the W&LE and its employees. Additionally, the loss of a significant market buyer for the W&LE's rail transportation as a result of the premature closure of baseload coal power plants will diminish the W&LE's ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. B. Premature Retirements of Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region's energy-intensive economy in three 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 coal 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 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 of this skilled and experienced group of workers, and the possible replacement of these workers with more distant and perhaps lessskilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond promptly to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having significant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation's bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as floods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of The Wheeling & Lake Erie Railway's business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. C. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, the W&LE strongly urges the FERC to adopt the rule proposed by the DOE as promptly and comprehensively as possible. FERC has a sufficient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting promptly, FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be sufficient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, Drew Nelson VP Sales and Marketing The Wheeling & Lake Erie Railway FE RC ?1 ll "1 Human; {farmerly rm: ?y in 9:31.: E-n'iail this gage File List Number: 2913'1013-5151 Desurlptign: Enmrne-nt of FreightEar America. Inc under Type Flle Name Elze Letter Fira Ni:- ciescripi gin-en FE Fill [Fe-n Hated iJ-zi: I'fzu Pd: Umn-?Lnad Ileana-t Help October 16, 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 FREIGHTCAR AMERICA, INC IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy ("DOE") issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to "ensure that certain reliability and 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-fired electric generating stations in the United States will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. FrieghtCar America, Inc ("FCA") is a supplier of railcars for use by almost all the power companies throughout the United States that generate electricity by burning coal. FCA has manufacturing facilities in Cherokee, AL; Danville, IL; Roanoke, Virginia, and has a total of 1,500 employees engaged in the production of railcars. Two North Riverside Plaza Suite 1300 Chicago, IL 60606 USA 312.928.0850 Fax 312.928.0890 www.freightcaramerica.com FCA strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms promptly in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal and/or nuclear industry, and the resulting impacts on our employees, our economy, the railway market, market for coal cars, and the reliability of the electric system will be detrimental and severe. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Theodore W. Baun Chief Commercial Officer FreightCar America, Inc. Two North Riverside Plaza; Suite 1300 Chicago, IL 60606 312-928-0850 tbauns@freightcar.net II. DESCRIPTION OF FREIGHTCAR AMERICA, INC FreightCar America, Inc. manufactures a wide range of railroad freight cars, supplies railcar parts and leases freight cars through its JAIX Leasing Company subsidiary. FreightCar America designs and builds high-quality railcars, including coal cars, bulk commodity cars, covered hopper cars, intermodal and non-intermodal flat cars, mill gondola cars, coil steel cars, and boxcars. It is headquartered in Chicago, Illinois.FreightCar America is publicly traded on NASDAQ under the ticker symbol Two North Riverside Plaza Suite 1300 Chicago, IL 60606 USA 312.928.0850 Fax 312.928.0890 www.freightcaramerica.com RAIL. More information about FreightCar America is available on its website at www.freightcaramerica.com. III. DESCRIPTION OF FREIGHTCAR AMERICA INC'S INTEREST IN PROCEEDING FCA's economic revenue is directly tied to the continued operation of the baseload coal power plants. As a result, the company and its employees may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, FCA has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. IV. COMMENTS A. The Premature Retirement of any Coal Plant Will Have a Significant Economic Impact to Company, Employees, and Region The issuance of a rule preserving baseload coal power plants will preserve economic benefits to FCA and its employees, which will therefore continue to sustain the regional economy. As noted above, FCA provides railcars to the utility industry, including to affected baseload coal power plants. Historically, the railcar manufacturing industry has delivered billions of dollars' worth of railcars and related parts to utilities with baseload coal facilities.. Premature closure of affected baseload coal power plants will result in direct economic impacts in the form of lost revenue from this very important market segment. Two North Riverside Plaza Suite 1300 Chicago, IL 60606 USA 312.928.0850 Fax 312.928.0890 www.freightcaramerica.com A decrease in revenue will hamper FCA's economic performance and may force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting FCA and its employees. Additionally, the loss of a significant market buyer for FCA's railcars as a result of the premature closure of baseload coal power plants will diminish FCA's ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. B. Premature Retirements of Baseload [Coal and/or Nuclear] Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region's energyintensive economy in three 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 coal 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. Two North Riverside Plaza Suite 1300 Chicago, IL 60606 USA 312.928.0850 Fax 312.928.0890 www.freightcaramerica.com 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 of this skilled and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond promptly to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having significant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation's bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as floods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of FCA's business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. Two North Riverside Plaza Suite 1300 Chicago, IL 60606 USA 312.928.0850 Fax 312.928.0890 www.freightcaramerica.com C. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, FCA strongly urges the FERC to adopt the rule proposed by the DOE as promptly and comprehensively as possible. FERC has a sufficient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting promptly, FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be sufficient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, Leslie G. Wood Vice President of Sales FreightCar America, Inc. Two North Riverside Plaza Suite 1300 Chicago, IL 60606 USA 312.928.0850 Fax 312.928.0890 www.freightcaramerica.com Two North Riverside Plaza Suite 1300 Chicago, IL 60606 USA 312.928.0850 Fax 312.928.0890 www.freightcaramerica.com FE RC 7 eLibrary {farmerly .49. rwwv?emgav mm E-mail this gage File List Number: [1,553 rlptign: Enmme-nt of Camalm Canal Cnmpany under HRH-34. Type Flle Name Elze FIB-F Coal Cantu-g Comma-Hi 3145? T13 Ni:- cie script gin-en FE HE Gen Brat-2:5 Um: I'fzu Fad: 1c? Help October 16, 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 CAMELOT COAL COMPANY IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy ("DOE") issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to "ensure that certain reliability and 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-fired electric generating stations in Pennsylvania, Ohio & West Virginia will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. Camelot is a supplier of coal for use by the Sammis & Bruce Mansfield power plants owned by FirstEnergy, located in Ohio (Sammis) & Bruce Mansfield (Pennsylvania). Camelot is the Sales Agent for Coal Mines in Pennsylvania, Ohio & West Virginia that employee as an aggregate 700+ employees.. Camelot strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms promptly in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal and/or nuclear industry, and the resulting impacts on our employees, our economy, the market for coal, and the reliability of the electric system will be detrimental and severe. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Thomas A Jones President Camelot Coal Company 323 S Main Street, Zelienople PA 16063 (724) 452-1416 tjones@camelotcoal.com II. DESCRIPTION OF CAMELOT COAL COMPANY Camelot is a leading Coal Sales, Contract Administration & Logistics Company, Incorporated in the State of Pennsylvania, in 1968. III. DESCRIPTION OF CAMELOT'S INTEREST IN PROCEEDING Camelot's economic revenue is directly tied to the continued operation of the baseload Sammis & Bruce Mansfield power plants. As a result, the company and its employees may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, Camelot has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. IV. COMMENTS A. The Premature Retirement of Sammis & Bruce Mansfield Power Plants Will Have a Significant Economic Impact to Company, Employees, and the Region. The issuance of a rule preserving baseload coal fired power plants will preserve economic benefits to Camelot and its employees, which will therefore continue to sustain the regional economy. As noted above, Camelot provides coal to the utility industry, including to the affected baseload coal power plants. Premature closure of affected baseload coal power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper Camelot's economic performance and may force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting Camelot and its employees. Additionally, the loss of a significant market buyer for Camelot's coal as a result of the premature closure of baseload coal fired power plants will diminish Camelot's ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. B. Premature Retirements of Baseload Coal Fired Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal fired power plants will maintain a reliable supply of electricity for the region's energy-intensive economy in three 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 coal fired 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 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 of this skilled and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond promptly to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having significant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation's bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as floods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of Camelot's business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. C. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Fired Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, Camelot strongly urges the FERC to adopt the rule proposed by the DOE as promptly and comprehensively as possible. FERC has a sufficient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting promptly, FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be sufficient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Camelot Coal Company FLU. Elm: 211 -323 3- MAIN PA [7'341452-1416 FM: 1152-1418 Respectfully submitted, Thomas A Jones President Camelot Coal Company FE RC ll 7 eLibrary {farmerly Wag rm: EV E-mail this gage File List Number: ED1T1D1B-5033 [1,553 rlptign: Enmrne-nt of and Equipment Company Inc. under Type Flle Name Elze Erin: E: uizun'iem Seminary mam-v.5- 27?4'33 FE Ni:- ciescripi gin-en FE HE [Fe-n Brat-an:= 16336 Um: I'fzu min: He'll:L Faun-mm FEHG China. plum-El u? 5552mm. October 17, 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 J AND J EQUIPMENT COMPANY INC. IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy ("DOE") issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to "ensure that certain reliability and 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-fired electric generating stations in West Virginia will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating stations. J and J Equipment Company Inc. is a supplier of services for use by the Pleasants Power Station a power plant owned by First Energy, a power plant located in Pleasants County West Virginia. J and J Equipment has a supply facility at Belmont, WV, and has a total of 12 employees engaged in the production/provision of CCB hauling and landfill development and operation. J and J Equipment strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms promptly in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal and/or nuclear industry, and the resulting impacts on our employees, our economy, the market for trucking and site development, and the reliability of the electric system will be detrimental and severe. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Max Hall Manager J and J Equipment Company Inc. 5981 South Pleasants Highway St. Mary's, WV 26170 304-665-2823 Teresamax1@suddenlink.net II. DESCRIPTION OF J AND J EQUIPMENT Trucking, excavating, and site development. III. DESCRIPTION OF J AND J EQUIPMENT'S INTEREST IN PROCEEDING J and J Equipment's economic revenue is directly tied to the continued operation of the baseload Pleasants power plant. As a result, the company and its employees may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, J and J Equipment has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear-fueled generating stations in organized markets. IV. COMMENTS A. The Premature Retirement of Pleasants Power Will Have a Significant Economic Impact to Company, Employees, and Region The issuance of a rule preserving baseload coal power plants will preserve economic benefits to J and J Equipment and its employees, which will therefore continue to sustain the regional economy. As noted above, J and J Equipment provides transportation and site development to the utility industry, including to affected baseload coal power plants. To the extend available, $5,000,000.00 of revenue derived from the sale of services to baseload coal generation facilities on an annual basis. Premature closure of affected baseload coal power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper J and J Equipment's economic performance and may force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting J and J Equipment and its employees. Additionally, the loss of a significant market buyer for J and J Equipment's trucking and site development as a result of the premature closure of baseload coal power plants will diminish J and J Equipment's ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. B. Premature Retirements of Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region's energy-intensive economy in three 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 coal 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 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 of this skilled and experienced group of workers, and the possible replacement of these workers with more distant and perhaps lessskilled individuals, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond promptly to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having significant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation's bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as floods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of J and J Equipment's business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. C. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, J and J Equipment strongly urges the FERC to adopt the rule proposed by the DOE as promptly and comprehensively as possible. FERC has a sufficient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting promptly, FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be sufficient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, Max Hall Manager and Equipment Company Inc. FE RC ?1 ll 7 eLibrery {fermerly e" .49 2.11m E-n'ieil li'iie gage File List Number: Desurlptinn: Eemment oi Richmond Hill. Inmrpereled under Type Flle Heme Elze FEHC-Himmend Mil Grid Heeil er 23-227?? Ne given FE HE Gen eretee? PDF #251 23312? Dec I'fe Fade 1e -J.ee L-eet Dew-Lead Help Funny lemme FEED mllne. plasma mind fermimunrcell HEB-MTG. Richmond Mill, Inc. P.O. Box 1298 Steubenville, OH 43952 740-266-8100 October 31, 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 0F RICHMOND MILL, INCORPORATED SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy 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 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 in Ohio will be compensated fully for their costs of operation. Adoption of that rule will thus sustain the long-term viability of critical power plants while preserving the jobs associated with goods and services supplied by numerous vendors throughout the region to support the continued operation and maintenance of those generating statlons. Richmond Mill, Incorporated (?Richmond Mill?) is a supplier of transporation and ash disposal services used by the W.H. Sammis power plant owned by FirstEnereg. The W.H. Sammis power plant is located in Stratton, Ohio. Richmod Mill has operating facilities at their ?y ash disposal site, machine shop and truck garage and has a total of 25 employees and contractors engaged in the provision of ash hauling and disposal services. Richmond Mill strongly supports the Proposal, and urges the FERC to direct operators of organized markets to adopt appropriate compensation mechanisms in order to ensure that owners and operators of coal and nuclear-fueled generating stations are compensated fully for the costs of continued operation of those generating stations. The failure to act will threaten the viability of the coal and/or nuclear industry, and the resulting impacts on our employees, our economy, the market for services, and the reliability of the electric system will be detrimental and severe. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Paul P. Carapellotti Secretary and Treasurer Richmond Mill, Incorporated P.O. Box 1298, Steubenville, OH 43952 740-266-8100 paul@anthonymining.com II. DESCRIPTION OF RICHMOND MILL, INCORPORATED Richmond Mill, Incorporated is a supplier of goods and services to irstEnergy?s W.H. Sammis power plant. Primary services include transportation and disposal of ?y ash and bottom ash generated at the W.H. Sammis power plant. DESCRIPTION OF RICHMOD INTEREST IN PROCEEDING Richmond Mill?s economic revenue is directly tied to the continued operation of the baseload of W.H. Sammis coal ?red power plant. As a result, the company and its employees may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, Richmond Mill has a direct and substantial interest in this proceeding. Additionally, the record in this proceeding will be bolstered further by these comments supporting the continued operation of coal and nuclear?fueled generating stations in organized markets. IV. COMMENTS A. The Premature Retirement of W.H. Sammis Plant Will Have 3 Signi?cant Economic Impact to Company, Employees, and Region The issuance of a rule preserving baseload coal power plants will preserve economic bene?ts to Richmond Mill and its employees, which will therefore continue to sustain the regional economy. As noted above, Richmod Mill provides transportation and ash disposal services to the utility industry, including to affected baseload coal power plants. Richmond Mill derives approximately $3,000,000 in annual revenue from these services. Premature closure of affected baseload coal power plants will result in direct economic impacts in the form of lost revenue. A decrease in revenue will hamper Richmond Mill?s economic performance and may force it to lay off employees as a necessary cost-saving mechanism, which will harm the regional economy. Indirect economic impacts will also result from the premature closure of affected baseload coal power plants in the form of a loss of tax revenue from the plants. A reduced tax base will likely result in a reduction in critical municipal services, thereby negatively impacting Richmond Mill and its employees. Additionally, the loss of a signi?cant market buyer for Richmond Mill?s ash hauling and disposal services as a result of the premature closure of baseload coal power plants will diminish Richmond Mill?s ability to achieve economies of scale, thereby leading to higher prices for such goods and services consumed by the generation facilities that remain in operation and other consumers. B. Premature Retirements 0f Baseload Coal Power Plants Will Negatively Impact the Reliability of the Bulk Power System The issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region?s energy-intensive economy in three 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 coal 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, we will see a direct and adverse impact on our ability to maintain the generation facilities that continue to operate and, as important, our ability to respond to severe contingencies affecting the operation of these remaining plants in operation. Third, the baseload generation facilities that may be retired prematurely offer stability and optionality by virtue of having signi?cant on-site fuel storage capability. As the Secretary of the DOE has demonstrated, baseload coal and nuclear-fueled generating stations provide essential reliability and resiliency support to the nation?s bulk power system. The availability of a long-term supply of fuel at the site of such generating stations enables those generating stations to withstand potential fuel supply disruptions that might be caused by natural disasters such as ?oods, hurricanes, or by sabotage. Additionally, the availability of a reliable supply of fuel to these generators, which is not dependent on transportation from an off-site source, ensures the continued supply of electricity to the grid at a time when other sources of electricity may be shut down. A resilient and reliable grid is absolutely essential to the conduct of Richmond Mill?s business, both under normal operating conditions and particularly during recovery efforts following a catastrophic event. Adoption of the Proposal will help ensure that the critical electricity grid remains robust and reliable. C. The Commission Must Take Immediate Action to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such baseload generating units may be deactivated prematurely, Richmond Mill, Incorporated strongly urges the FERC to adopt the rule proposed by the DOE as and comprehensively as possible. FERC has a suf?cient record on which to act. As noted by the Secretary of the DOE, the time to act is now. Any protracted delay in creating compensatory procedures designed to ensure that operators of baseload generation facilities are able to recover their full costs of operation will only exacerbate the problem of premature closures. In acting FERC should direct operators of organized markets to issue a mechanism for compensating operators of baseload generating stations (and based on the regulatory language of the Proposal) that is comprehensive and enduring. The compensation mechanisms to be adopted by operators of organized markets should be suf?cient to ensure that critical power plants can continue to operate for their remaining service lives, 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 may defeat the very purpose of preserving the extended operation of these much?needed power plants. Respectfully submitted, Paul P. Carapellotti Secretary and Treasurer Richmond Mill, Incorporated