By: Fllad Date: Dumiptiun: Baum: 10/24/2017 ELibrary File List eLibrary (formerly FERRIS)            Search   \n   E­mail this page File List Advanced Search   New Dockets     Accession Number:   20171017­5105 Docket Search   Description:   Comment of FirstEnergy Corp.under RM18­1. (Erroneously Filed ­ Replaced with 20171017­5140) Daily Search     Request List   Logon   Help      Type   File Name Size MicroSoft Word         28282       FERC Generated   PDF     Help ­ Accessible    Login: Guest    Doc Info     IBEW Local 1289 Labor Comments 10.13.17.DOCX         No description given       17932   12507685.PDF Add to Request   DownLoad   Reset     Help     For any issues regarding FERC Online, please contact ferconlinesupport@ferc.gov or call 866­208­3676.    Please include a current mail address, telephone number, and email address. https://elibrary-backup.ferc.gov/idmws/file_list.asp 1/1 You don't have permission to access This document. This document (eLibrary accession no. 201?lOl7?5105) is Privileged. The public may ?le a FOIA request under 18 C.F.R. 388.108. FE RC ll 7 eLibrary {farmerly Wag rm: EV E-mail this gage File List Number: [1,553 rlptign: Enmrne-nt of IE?lE'i'i?. Ln-sal Lander [Thii ?ling replanai Type Flle Name Elze Micr-cuS-al't Liz-cg Can-me 3113 232-32 Ni:- ciescripi gin-en FE [Fe-n Brat-an:= ?5'32 Um: I'fzu min: He'll:L Funny lama FEED mllna. plasma mammawm? MERGE-MM. 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. RM18-1-000 COMMENTS OF THE INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS, LOCAL UNION 1289 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 New Jersey will be compensated appropriately and fully for their costs of operation and will avoid premature retirement. Adoption of that rule will thus sustain the long-term viability of critical power plants, preserve and create jobs, maintain electric reliability, and provide substantial economic benefits to the many hard-working Americans living throughout the region. IBEW Local 1289 strongly supports the Proposal and shares the Secretary's urgency that FERC act promptly to direct operators of organized markets to issue the requested rule. FERC has the ability to act, and must act, without undue delay to avoid premature closure of crucial power plants and our members' loss of critical economic and reliability benefits. FERC has thoroughly examined how electric markets function and how those markets affect the continued operation of crucial power plants needed for reliability for some time. FERC has the requisite basis to act now. There is no time for delay. In addition to acting promptly, FERC should also direct organized market operators to issue a comprehensive and enduring set of rules, based on the regulatory language of the Proposal, for the proper compensation of critical power plants. Protracted proceedings undertaken by organized market operators that fail to develop fair, compensatory and transparent rules will only engender market uncertainty and delay in providing sufficient compensation to these facilities, thereby jeopardizing the operation of the very plants that the DOE seeks to maintain in operation. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Brian Kube President & Business Mgr. IBEW Local 1289 PO Box 1690, Wall, NJ, 07719 732-918-9559 BrianKube@ibew1289.org II. DESCRIPTION OF IBEW LOCAL 1289 IBEW Local 1289 is a progressive labor organization that represents individuals in the Utility, and Generation industries. III. DESCRIPTION OF IBEW LOCAL 1289'S INTEREST IN PROCEEDING IBEW Local 1289 is a party to a collective bargaining agreements with the owners of baseload coal and nuclear power plants located in Ohio, Pennsylvania and New Jersey. As a result, the wages, terms and conditions of employment of its members may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, IBEW Local 1289 members have a direct and substantial interest in this proceeding. As well, the unique perspective of IBEW Local 1289 and its members will only serve to enhance the record in this proceeding. IV. COMMENTS The communities where struggling baseload coal and nuclear power plants are located are dependent on the jobs and economic development opportunities the power plants provide. The recent decline in Ohio, Pennsylvania and New Jersey's electric power industry, for example, has led to reductions in operations and capital improvement expenditures at numerous power production and manufacturing facilities across these states. This has led to extreme hardship for the thousands of union workers employed in this industry as well as their families. It is imperative that baseload coal and nuclear plants continue to operate in light of these dire circumstances. Baseload coal and nuclear plants in these 3 states provide thousands of MWs of reliable power, and provide union jobs and economic opportunities to IBEW Local 1289 members. IBEW Local 1289 has approximately 1400 members working in both utility and generating occupations in New Jersey, specifically the Oyster Creek nuclear plant and NRG generating operations. In addition to direct labor in the generation sector, the maintenance and capital improvement work at these plants supports the local economy by creating thousands of well-paying union jobs for contractors. These plants also contribute millions each year in state and local tax revenues that support local schools, police and fire departments and other vital public services. The loss of jobs, tax revenue, and the ripple effect of such losses throughout the local economy, will have a severely detrimental impact on the region. The issuance of a rule preserving the continued operation of resilient baseload coal and nuclear power plants will maintain a reliable supply of electricity for the region's energyintensive economy in two ways. First, the preservation of certain plants will avoid the need to replace lost generation with imports and the associated construction of infrastructure to facilitate such importation. Preserving baseload coal and nuclear power plants will keep these needed, reliable facilities running close to home without the need to depend on distant resources, particularly during catastrophic events like severe storms, to fulfill our region's dynamic need for reliable electricity. Second, premature plant closures will deplete the 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. In short, allowing baseload coal and nuclear power plants to close prematurely will have an adverse impact on the reliability of the region's electricity supply and on the reliable operation of the regional electricity system. Rates for the sale of electricity that are inadequate to sustain the operation of base load generation facilities that provide reliability and resiliency support cannot be considered to be just and reasonable. Because of the loss of jobs, the significant reduction in payments to local governments, and the decline in electricity resource and grid reliability that would result from deactivation of the nuclear and coal-fired generating facilities in Ohio, it is essential that the FERC adopt a rule, such as that proposed by DOE, which will ensure that such generating facilities are fully compensated for their costs and will remain in operation. In order to mitigate the risk that such generating units may be deactivated prematurely, IBEW Local 1289 strongly urges FERC to adopt the rule proposed by the DOE as promptly and comprehensively as possible. FERC has a sufficient record to act that will be further bolstered by the comments considered in this proceeding. FERC has thoroughly considered the impact of electric markets on the sustained operation of at-risk power plants and, as noted by the Secretary of the DOE, the time to act is now given the severe impacts to system reliability and resilience, and national security, attendant to the premature closure of crucial power plants. Any protracted delay in creating fully compensatory market rules will only exacerbate the problem of premature closures. In acting promptly, FERC should also direct the organized market operators to issue a rule that is not only compensatory (and based on the regulatory language of the Proposal) but comprehensive and enduring. The rules to be issued by operators of organized markets should be fair and transparent, and should ensure that critical power plants can continue to operate for the long-term and without the prospect of repeated re-examination and adjustment to their market compensation. The uncertainty that less than comprehensive and enduring market rules will engender will defeat the very purpose of preserving the extended operation of these muchneeded power plants. Respectfully submitted, Brian Kube President & Business Manager IBEW Local 1289 Fllad By: Fllad Data: Dumlptiun: FE RC ll ?1 eLibrary {farmerly rm: EU as: mam: E-mail thii gage File List Ancesslon Number: Enmrne-nt of FIRST CDHPURATIDH under Type Flle Name Micr-cuS-nft Liz-cg Lib-3r Cam"-E-r15 de scrip-1 gin-en FE HI: Gen I'fzu Fad: 1i: lites-net HEIR- 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. RM18-1-000 COMMENTS OF THE UTILITY WORKERS UNION OF AMERICA, LOCAL UNION 350 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 and Pennsylvania will be compensated appropriately and fully for their costs of operation and will avoid premature retirement. Adoption of that rule will thus sustain the long-term viability of critical power plants, preserve and create jobs, maintain electric reliability, and provide substantial economic benefits to the many hard-working Americans living throughout the region. UWUA Local 350 strongly supports the Proposal and shares the Secretary's urgency that FERC act promptly to direct operators of organized markets to issue the requested rule. FERC has the ability to act, and must act, without undue delay to avoid premature closure of crucial power plants and our members' loss of critical economic and reliability benefits. FERC has thoroughly examined how electric markets function and how those markets affect the continued operation of crucial power plants needed for reliability for some time. FERC has the requisite basis to act now. There is no time for delay. In addition to acting promptly, FERC should also direct organized market operators to issue a comprehensive and enduring set of rules, based on the regulatory language of the Proposal, for the proper compensation of critical power plants. Protracted proceedings undertaken by organized market operators that fail to develop fair, compensatory and transparent rules will only engender market uncertainty and delay in providing sufficient compensation to these facilities, thereby jeopardizing the operation of the very plants that the DOE seeks to maintain in operation. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Norm DeLong President UWUA Local 350 68256 Meadow Ave., St. Clairsville, Ohio 43950 740-310-3964 delongn@firstenergycorp.com II. DESCRIPTION OF UWUA LOCAL 350 UWUA Local 350 is a progressive labor organization that represents individuals who support the Electric Generation industry. III. DESCRIPTION OF UWUA LOCAL 350'S INTEREST IN PROCEEDING UWUA Local 350 is a party to a collective bargaining agreement with the owners of baseload coal and nuclear power plants located in Ohio and Pennsylvania. As a result, the wages, terms and conditions of employment of its members may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, UWUA Local 350 members have a direct and substantial interest in this proceeding. As well, the unique perspective of UWUA Local 350 and its members will only serve to enhance the record in this proceeding. IV. COMMENTS The communities where struggling baseload coal and nuclear power plants are located are dependent on the jobs and economic development opportunities the power plants provide. The recent decline in Ohio and Pennsylvania's electric power industry, for example, has led to reductions in operations and capital improvement expenditures at numerous power production and manufacturing facilities across these states. This has led to extreme hardship for the thousands of union workers employed in this industry as well as their families. It is imperative that baseload coal and nuclear plants continue to operate in light of these dire circumstances. Baseload coal and nuclear plants in Ohio and Pennsylvania provide thousands of MWs of reliable power, and provide union jobs and economic opportunities to UWUA Local 350 members. UWUA 350 has approximately 15 members who work in Maintenance support occupations for generating plants in Ohio and Pennsylvania. The maintenance and capital improvement work on these plants also supports the local economy by creating hundreds of well-paying union jobs for contractors during plant outages. In addition, these plants contribute millions each year in state and local tax revenues that support local schools, police and fire departments and other vital public services. The loss of jobs, tax revenue, and the ripple effect of such losses throughout the local economy, will have a severely detrimental impact on the region. The issuance of a rule preserving the continued operation of resilient baseload coal and nuclear power plants will maintain a reliable supply of electricity for the region's energyintensive economy in two ways. First, the preservation of certain plants will avoid the need to replace lost generation with imports and the associated construction of infrastructure to facilitate such importation. Preserving baseload coal and nuclear power plants will keep these needed, reliable facilities running close to home without the need to depend on distant resources, particularly during catastrophic events like severe storms, to fulfill our region's dynamic need for reliable electricity. Second, premature plant closures will deplete the 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. In short, allowing baseload coal and nuclear power plants to close prematurely will have an adverse impact on the reliability of the region's electricity supply and on the reliable operation of the regional electricity system. Rates for the sale of electricity that are inadequate to sustain the operation of base load generation facilities that provide reliability and resiliency support cannot be considered to be just and reasonable. Because of the loss of jobs, the significant reduction in payments to local governments, and the decline in electricity resource and grid reliability that would result from deactivation of the nuclear and coal-fired generating facilities in Ohio, it is essential that the FERC adopt a rule, such as that proposed by DOE, which will ensure that such generating facilities are fully compensated for their costs and will remain in operation. In order to mitigate the risk that such generating units may be deactivated prematurely, UWUA Local 350 strongly urges FERC to adopt the rule proposed by the DOE as promptly and comprehensively as possible. FERC has a sufficient record to act that will be further bolstered by the comments considered in this proceeding. FERC has thoroughly considered the impact of electric markets on the sustained operation of at-risk power plants and, as noted by the Secretary of the DOE, the time to act is now given the severe impacts to system reliability and resilience, and national security, attendant to the premature closure of crucial power plants. Any protracted delay in creating fully compensatory market rules will only exacerbate the problem of premature closures. In acting promptly, FERC should also direct the organized market operators to issue a rule that is not only compensatory (and based on the regulatory language of the Proposal) but comprehensive and enduring. The rules to be issued by operators of organized markets should be fair and transparent, and should ensure that critical power plants can continue to operate for the long-term and without the prospect of repeated re-examination and adjustment to their market compensation. The uncertainty that less than comprehensive and enduring market rules will engender will defeat the very purpose of preserving the extended operation of these muchneeded power plants. Respectfully submitted, Norm DeLong President UWUA Local 350 Fllad By: Fllad Data: Amid? Ha: Dump?un: lnfunnatian: 10/24/2017 ELibrary File List eLibrary (formerly FERRIS) Search \n E-mail this page File List Advanced Search New Dockets Accession Number: 20171016-5174 Docket Search Description: Comment of Laborers' Local 310 under RM18-1. Daily Search Request List Logon Help Type File Name Size PDF 1671208 No description given FERC Generated PDF Help - Accessible Login: Guest Doc Info BuildingLaborers310 comments to FERC.PDF 1672095 12507023.PDF Add to Request DownLoad Reset Help For any issues regarding FERC Online, please contact ferconlinesupport@ferc.gov or call 866-208-3676. Please include a current mail address, telephone number, and email address. https://elibrary.ferc.gov/idmws/file_list.asp?document_id=14610181 1/1 BUILDING UNION, LOCAL N0. 310 Affiliated with Laborers? International Union of North America AFL-CIO 3250 EUCLID AVENUE CLEVELAND, OHIO 44115-2599 PHONE: 216/881 -5901 FAX: 216/881-5928 TERENCE P. JOYCE, Business Manager MICHAEL J. KEARNEY, Seoretanr-ireasurer 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. COMMENTS OF THE BUILDING LOCAL 310 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 appropriately and fully for their costs of operation and will avoid premature retirement. AdOption of that rule will thus sustain the long-term Viability of critical power plants, preserve and create jobs, maintain electric reliability, and provide substantial economic bene?ts to the many hard? working Americans living throughout the region. The Building Laborers? Local 310 strongly supports the Proposal and shares the Secretary?s urgency that FERC act to direct operators of organized markets to issue the requested rule. ERC has the ability to act, and must act, without undue delay to avoid premature closure of crucial power plants and our members? loss of critical economic and reliability bene?ts. FERC has thoroughly examined how electric markets function and how those markets affect the continued operation of crucial power plants needed for reliability for some time. FERC has the requisite basis to act now. There is no time for delay. In addition to acting FERC should also direct organized market Operators to issue a comprehensive and enduring set of rules, based on the regulatory language of the Proposal, for the proper compensation of critical power plants. Protracted proceedings undertaken by organized market operators that fail to develop fair, compensatory and transparent rules will only engender market uncertainty and delay in providing suf?cient compensation to these facilities, thereby jeopardizing the operation of the very plants that the DOE seeks to maintain in operation. 1. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Terence P. Joyce Business Manager Building Laborers? Local 310 3250 Euclid Ave., Cleveland, OH 44115 216 881-5901 tjoyce@local310.com II. DESCRIPTION OF BUILDING LOCAL 310 Labor Union Building Construction DESCRIPTION OF BUILDING LOCAL 310?s INTEREST IN PROCEEDING The Building Laborers? Local 310 is a party to a collective bargaining agreement with the owners of baseload coal and nuclear power plants located in Cuyahoga, Lake and Geauga Counties of Ohio. Our members work on major infrastructure and industrial development projects that are dependent on the continued operation of the baseload coal and nuclear power plants. As a result, the wages, terms and conditions of employment of its members may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, the Building Laborers? Local 310 members have a direct and substantial interest in this proceeding. As well, the unique perspective of the Building Laborers? Local 310 and its members will only serve to enhance the record in this proceeding. IV. COMMENTS The communities where struggling baseload coal and nuclear power plants are located are dependent on the jobs and economic development opportunities the power plants provide. The recent decline in Ohio electric power industry, for example, has led to reductions in operations and capital improvement expenditures at numerous power production and manufacturing facilities across Ohio. This has led to extreme hardship for the thousands of union workers employed in this industry as well as their families. It is imperative that baseload coal and nuclear plants continue to operate in light of these dire circumstances. Baseload coal and nuclear plants in Ohio provide thousands of MWS of reliable power, and provide union jobs and economic opportunities to Building Laborers? Local 310 members. Building Laborers? Local #310 sends workers to both the Davis-Besse and Perry Nuclear Power Plants. These Power Plants employ approximately 1,400 people. These Power Plants have a temporary shutdown every 24 months in order to replace some of their fuel and to conduct routine maintenance and safety inspections. These outages can last anywhere from four to six weeks and requires the Power Plants to hire additional contract workers which includes members of Building Laborers? Local 310. This highly skilled workforce requires boilermakers, electricians, iron workers, pipe?tters and various other craft personnel to work around the clock to complete the work safely and ef?ciently. These jobs with overtime, pay wages far above the prevailing incomes of their respective communities. Also, in total, outside contractors, workers and plant personnel contribute nearly $25 million combined each year in state and local taxes to support schools, police and fire departments and other vital public services. The loss of jobs, tax revenue, and the ripple effect of such losses throughout the local economy, will have a severely detrimental impact on the region. The issuance of a rule preserving the continued operation of resilient baseload coal and nuclear power plants will maintain a reliable supply of electricity for the region?s energy-intensive economy in two ways. First, the preservation of certain plants will avoid the need to replace lost generation with imports and the associated construction of infrastructure to facilitate such importation. Preserving baseload coal and nuclear power plants will keep these needed, reliable facilities running close to home without the need to depend on distant resources, particularly during catastrophic events like severe storms, to ful?ll our region?s dynamic need for reliable electricity. Second, premature plant closures will deplete the stable of highly skilled (and speci?cally trained and experienced) employees, many of whom have lived in the region for several years and who take great pride in their work. With a depletion of this skilled and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less?skilled individuals, 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. In short, allowing baseload coal and nuclear power plants to close prematurely will have an adverse impact on the reliability of the region?s electricity supply and on the reliable operation of the regional electricity system. Rates for the sale of electricity that are inadequate to sustain the operation of base load generation facilities that provide reliability and resiliency support cannot be considered to be just and reasonable. Because of the loss of jobs, the signi?cant reduction in payments to local governments, and the decline in electricity resource and grid reliability that would result from deactivation of the nuclear and coal-?red generating facilities in Ohio, it is essential that the FERC adopt a rule, such as that proposed by DOE, which will ensure that such generating facilities are fully compensated for their costs and will remain in operation. In order to mitigate the risk that such generating units may be deactivated prematurely, the Building Laborers? Local 310 strongly urges FERC to adopt the rule proposed by the DOE as and comprehensively as possible. FERC has a suf?cient record to act that will be further bolstered by the comments considered in this proceeding. FERC has thoroughly considered the impact of electric markets on the sustained operation of at?risk power plants and, as noted by the Secretary of the DOE, the time to act is now given the severe impacts to system reliability and resilience, and national security, attendant to the premature closure of crucial power plants. Any protracted delay in creating fully compensatory market rules will only exacerbate the problem of pre-mature closures. In acting FERC should also direct the organized market operators to issue a rule that is not only compensatory (and based on the regulatory language of the Proposal) but comprehensive and enduring. The rules to be issued by Operators of organized markets should be fair and transparent, and should ensure that critical power plants can continue to operate for the long-term and without the prospect of repeated re-examination and adjustment to their market compensation. The uncertainty that less than comprehensive and enduring market rules will engender will defeat the very purpose of preserving the extended operation of these much-needed power plants. Re ectfullys ?We: Terence P. Joyc Business Manager Building Laborers? Local 310 FE RC 0 7? eLibrary (formerly FERRIS) E-rna 1 his gage File List A: cesslon Number: 20111013503?- Cummenl of ibaw 2?2 ur'der Type Flle Name Micros-oft We'd IBEW Luca 2F2 Labor Commerls nal No cescripl or given FERC Gen erated PDF 25E 33. PDF Dec I'fo Ade 1c -J.ec:..est IJcn'e'Lsacl Izeset Helu FellingI Muse FERG Onllna Please hduda a malt Slze 2? 77'0 WEB-36M. 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. RM18-1-000 COMMENTS OF THE INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS, LOCAL UNION 272 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 appropriately and fully for their costs of operation and will avoid premature retirement. Adoption of that rule will thus sustain the longterm viability of critical power plants, preserve and create jobs, maintain electric reliability, and provide substantial economic benefits to the many hard-working Americans living throughout the region. IBEW Local 272 strongly supports the Proposal and shares the Secretary's urgency that FERC act promptly to direct operators of organized markets to issue the requested rule. FERC has the ability to act, and must act, without undue delay to avoid premature closure of crucial power plants and our members' loss of critical economic and reliability benefits. FERC has thoroughly examined how electric markets function and how those markets affect the continued operation of crucial power plants needed for reliability for some time. FERC has the requisite basis to act now. There is no time for delay. In addition to acting promptly, FERC should also direct organized market operators to issue a comprehensive and enduring set of rules, based on the regulatory language of the Proposal, for the proper compensation of critical power plants. Protracted proceedings undertaken by organized market operators that fail to develop fair, compensatory and transparent rules will only engender market uncertainty and delay in providing sufficient compensation to these facilities, thereby jeopardizing the operation of the very plants that the DOE seeks to maintain in operation. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Vic Roppa President IBEW Local 272 838 Midland Avenue, Midland, PA 15059 724-601-3160 VRJR@comcast.net II. DESCRIPTION OF IBEW LOCAL 272 IBEW Local 272 is a progressive labor organization that represents individuals working in the baseload generation industry. III. DESCRIPTION OF IBEW LOCAL 272'S INTEREST IN PROCEEDING IBEW Local 272 is a party to a collective bargaining agreement with the owner of a large baseload coal power plant located in Pennsylvania. As a result, the wages, terms and conditions of employment of our members may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, IBEW Local 272 members have a direct and substantial interest in this proceeding. As well, the unique perspective of IBEW Local 272 and its members will only serve to enhance the record in this proceeding. IV. COMMENTS The communities where struggling baseload coal and nuclear power plants are located are dependent on the jobs and economic development opportunities the power plants provide. The recent decline in Pennsylvania's electric power industry, for example, has led to reductions in operations and capital improvement expenditures at numerous power production and manufacturing facilities across Pennsylvania. This has led to extreme hardship for the thousands of union workers employed in this industry as well as their families. It is imperative that baseload coal and nuclear plants continue to operate in light of these dire circumstances. Baseload coal and nuclear plants in Pennsylvania provide thousands of MWs of reliable power, and provide union jobs and economic opportunities to IBEW Local 272 members. The Bruce Mansfield generation station directly employs approximately 215 IBEW Local 272 members, and the maintenance and capital improvement work on this plant supports the local economy by creating hundreds of well-paying union jobs for contractors. In addition, this plant contributes millions each year in state and local tax revenues that support local schools, police and fire departments and other vital public services. The loss of jobs, tax revenue, and the ripple effect of such losses throughout the local economy, will have a severely detrimental impact on the region. The issuance of a rule preserving the continued operation of resilient baseload coal and nuclear power plants will maintain a reliable supply of electricity for the region's energyintensive economy in two ways. First, the preservation of certain plants will avoid the need to replace lost generation with imports and the associated construction of infrastructure to facilitate such importation. Preserving baseload coal and nuclear power plants will keep these needed, reliable facilities running close to home without the need to depend on distant resources, particularly during catastrophic events like severe storms, to fulfill our region's dynamic need for reliable electricity. Second, premature plant closures will deplete the 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. In short, allowing baseload coal and nuclear power plants to close prematurely will have an adverse impact on the reliability of the region's electricity supply and on the reliable operation of the regional electricity system. Rates for the sale of electricity that are inadequate to sustain the operation of base load generation facilities that provide reliability and resiliency support cannot be considered to be just and reasonable. Because of the loss of jobs, the significant reduction in payments to local governments, and the decline in electricity resource and grid reliability that would result from deactivation of the nuclear and coal-fired generating facilities in Pennsylvania, it is essential that the FERC adopt a rule, such as that proposed by DOE, which will ensure that such generating facilities are fully compensated for their costs and will remain in operation. In order to mitigate the risk that such generating units may be deactivated prematurely, IBEW Local 272 strongly urges FERC to adopt the rule proposed by the DOE as promptly and comprehensively as possible. FERC has a sufficient record to act that will be further bolstered by the comments considered in this proceeding. FERC has thoroughly considered the impact of electric markets on the sustained operation of at-risk power plants and, as noted by the Secretary of the DOE, the time to act is now given the severe impacts to system reliability and resilience, and national security, attendant to the premature closure of crucial power plants. Any protracted delay in creating fully compensatory market rules will only exacerbate the problem of premature closures. In acting promptly, FERC should also direct the organized market operators to issue a rule that is not only compensatory (and based on the regulatory language of the Proposal) but comprehensive and enduring. The rules to be issued by operators of organized markets should be fair and transparent, and should ensure that critical power plants can continue to operate for the long-term and without the prospect of repeated re-examination and adjustment to their market compensation. The uncertainty that less than comprehensive and enduring market rules will engender will defeat the very purpose of preserving the extended operation of these muchneeded power plants. Respectfully submitted, Vic Roppa President IBEW Local 272 FE RC ?1 ll "1 Human; {farmerly rm: ?y n: 9:31.: E-n'nail this gage File List Number: ENHDW-EDQE Desurlptign: Enmrne-nt of Lia-cal 2115 under Type Flle Name Elze FEHC 123992 ciescripi gin-en FE Fill [Fe-n Hated iJ-zn: I'fzu Pd: Uta-ruled Ileana-t Help Funny lama FEED Fianna mummum Phone: (419) 666-3350 (888) 666-3350 Fax: (419) 666-5545 Arie. 31111 Prnatinnal nf Min-hers LOCAL UNION NO. 245 ms LIME CITY ROAD ROSSFOFID, OHIO 43460 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. COMNIENTS OF THE INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS, LOCAL UNION 245 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 appropriately and fully for their costs of operation and will avoid premature retirement. Adoption of that rule will thus sustain the long-term viability of critical power plants, preserve and create jobs, maintain electric reliability, and provide substantial economic bene?ts to the many hard-working Americans living throughout the region. IBEW Local 245 strongly supports the Proposal and shares the Secretary?s urgency that FERC act to direct operators of organized markets to issue the requested rule. FERC has the ability to act, and must act, without undue delay to avoid premature closure of crucial power plants and our members? loss of critical economic and reliability bene?ts. FERC has thoroughly examined how electric markets ?mction and how those markets affect the continued operation of crucial power plants needed for reliability for some time. FERC has the requisite basis to act now. There is no time for delay. In addition to acting FERC should also direct organized market operators to issue a comprehensive and enduring set of rules, based on the regulatory language of the Proposal, for the proper compensation of critical power plants. Protracted proceedings undertaken by organized market operators that fail to develop fair, compensatory and transparent rules will only engender market uncertainty and delay in providing suf?cient compensation to these facilities, thereby jeopardizing the operation of the very plants that the DOE seeks to maintain in operation. 1. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Larry Tscheme Business Mgr. Financial Secretary IBEW Local 245 705 Lime City Road, Rossford, Ohio 43460 419?356-4542 Larry@IBEW245.com DESCRIPTION OF IBEW LOCAL 245 IBEW Local 245 is a progressive labor organization that represents individuals in the Utility, Generation, Construction, Government and Communications industries. DESCRIPTION OF IBEW LOCAL 245?s INTEREST IN PROCEEDING IBEW Local 245 is a party to a collective bargaining agreement with the owners of baseload coal and nuclear power plants located in Ohio. In addition to working in these plants, our members work on major infrastructure and industrial development projects that are dependent on the continued operation of the baseload coal and nuclear power plants. As a result, the wages, terms and conditions of employment of its members may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, IBEW Local 245 members have a direct and substantial interest in this proceeding. As well, the unique perspective of IBEW Local 245 and its members will only serve to enhance the record in this proceeding. IV. COMMENTS The communities where struggling baseload coal and nuclear power plants are located are dependent on the jobs and economic development opportunities the power plants provide. The recent decline in Ohio?s electric power industry, for example, has led to reductions in operations and capital improvement expenditures at numerous power production and manufacturing facilities across Ohio. This has led to extreme hardship for the thousands of union workers and nonunion workers employed in this industry as well as their families. It is imperative that baseload coal and nuclear plants continue to operate in light of these dire circumstances. Baseload coal and nuclear plants in Ohio provide thousands of MWs of reliable power, and provide many union jobs and economic opporttmities to IBEW Local 245 members. The Davis Besse and Bayshore generation stations directly employ approximately 240 IBEW Local 245 members, and the maintenance and capital improvement work on these plants supports the local economy by creating thousands of well-paying union jobs for contractors. In addition, these plants contribute millions each year in state and local tax revenues that support local schools, police and ?re departments and other vital public services. The loss of jobs, tax revenue, and the ripple effect of such losses throughout the local economy, will have a severely detrimental impact on the region. The issuance of a rule preserving the continued operation of resilient baseload coal and nuclear power plants will maintain a reliable supply of electricity for the region?s energy-intensive economy in two ways. First, the preservation of certain plants will avoid the need to replace lost generation with imports and the associated construction of infrastructure to facilitate such importation. Preserving baseload coal and nuclear power plants will keep these needed, reliable facilities running close to home without the need to depend on distant resources, particularly during catastrophic events like severe storms, to ful?ll our region?s dynamic need for reliable electricity. Second, premature plant closures will deplete the stable of highly skilled (and speci?cally trained and experienced) employees, many of whom have lived in the region for several years and who take great pride in their work. With a depletion of this skilled and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, 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. In short, allowing baseload coal and nuclear power plants to close prematurely will have an adverse impact on the reliability of the region?s electricity supply and on the reliable operation of the regional electricity system. Rates for the sale of electricity that are inadequate to sustain the operation of base load generation facilities that provide reliability and resiliency support cannot be considered to be just and reasonable. Because of the loss of jobs, the signi?cant reduction in payments to local governments, and the decline in electricity resource and grid reliability that would result from deactivation of the nuclear and coal??red generating facilities in Ohio, it is essential that the ERC adopt a rule, such as that proposed by DOE, which will ensure that such generating facilities are compensated for their costs and will remain in operation. In order to mitigate the risk that such generating units may be deactivated prematurely, IBEW Local 245 strongly urges FERC to adopt the rule proposed by the DOE as and comprehensively as possible. FERC has a suf?cient record to act that will be further bolstered by the comments considered in this proceeding. FERC has thoroughly considered the impact of electric markets on the sustained operation of at-risk power plants and, as noted by the Secretary of the DOE, the time to act is now given the severe impacts to system reliability and resilience, and national security, attendant to the premature closure of crucial power plants. Any protracted delay in creating compensatory market rules will only exacerbate the problem of pre-mature closures. In acting FERC should also direct the organized market operators to issue a rule that is not only compensatory (and based on the regulatory language of the Proposal) but comprehensive and enduring. The rules to be issued by Operators of organized markets should be fair and transparent, and should ensure that critical power plants can continue to operate for the long-term and without the prospect of repeated re-examination and adjustment to their market compensation. The uncertainty that less than comprehensive and enduring market rules will engender will defeat the very purpose of preserving the extended operation of these much-needed power plants. Resp fully submitted, cherne Business Manager and Financial Secretary IBEW Local 245 FE RC 0 7? eLibrary (formerly FERRIS) E-rna 1 his gage File List Accesslon Number: Cummenl of IBEW Lucal 235? under RIMS-1 Type Flle Name Micros-oft We'd IBEW Luca 235? .anc-r Commems 10.13.3EICX No cescripl or given FERC Gen erated PDF PD: iJcc I'fo Ade 1c -J.ec:..est IJcn'e'Lsacl Izeset Helu FellingI Muse FERG Onllna Please hduda a malt Slze 13353 WEB-36M. 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. RM18-1-000 COMMENTS OF THE INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS, LOCAL UNION 2357 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 and Pennsylvania will be compensated appropriately and fully for their costs of operation and will avoid premature retirement. Adoption of that rule will thus sustain the long-term viability of critical power plants, preserve and create jobs, maintain electric reliability, and provide substantial economic benefits to the many hard-working Americans living throughout the region. IBEW Local 2357 strongly supports the Proposal and shares the Secretary's urgency that FERC act promptly to direct operators of organized markets to issue the requested rule. FERC has the ability to act, and must act, without undue delay to avoid premature closure of crucial power plants and our members' loss of critical economic and reliability benefits. FERC has thoroughly examined how electric markets function and how those markets affect the continued operation of crucial power plants needed for reliability for some time. FERC has the requisite basis to act now. There is no time for delay. In addition to acting promptly, FERC should also direct organized market operators to issue a comprehensive and enduring set of rules, based on the regulatory language of the Proposal, for the proper compensation of critical power plants. Protracted proceedings undertaken by organized market operators that fail to develop fair, compensatory and transparent rules will only engender market uncertainty and delay in providing sufficient compensation to these facilities, thereby jeopardizing the operation of the very plants that the DOE seeks to maintain in operation. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Brian Fain President & Business Mgr. IBEW Local 2357 603 Hastings Rd. Mount Clare, WV 26408 304-709-2104 bfainibew@aol.com II. DESCRIPTION OF IBEW LOCAL 2357 IBEW Local 2357 is a progressive labor organization that represents individuals in the Utility, and Generation support occupations. III. DESCRIPTION OF IBEW LOCAL 2357'S INTEREST IN PROCEEDING IBEW Local 2357 is a party to a collective bargaining agreement with the owners of baseload coal and nuclear power plants located in Ohio and Pennsylvania. Our members work on major outages and support the overall maintenance work in these generation facilities. As a result, the wages, terms and conditions of employment of its members may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, IBEW Local 2357 members have a direct and substantial interest in this proceeding. As well, the unique perspective of IBEW Local 2357 and its members will only serve to enhance the record in this proceeding. IV. COMMENTS The communities where struggling baseload coal and nuclear power plants are located are dependent on the jobs and economic development opportunities the power plants provide. The recent decline in Ohio and Pennsylvania's electric power industry, for example, has led to reductions in operations and capital improvement expenditures at numerous power production and manufacturing facilities across these states. This has led to extreme hardship for the thousands of union workers employed in this industry as well as their families. It is imperative that baseload coal and nuclear plants continue to operate in light of these dire circumstances. Baseload coal and nuclear plants in Ohio and Pennsylvania provide thousands of MWs of reliable power, and provide union jobs and economic opportunities to IBEW Local 2357 members. These generation stations directly employ approximately 30 IBEW Local 2357 members, and the maintenance and capital improvement work on these plants supports the local economy by creating thousands of well-paying union jobs for contractors during outages. In addition, these plants contribute millions each year in state and local tax revenues that support local schools, police and fire departments and other vital public services. The loss of jobs, tax revenue, and the ripple effect of such losses throughout the local economy, will have a severely detrimental impact on the region. The issuance of a rule preserving the continued operation of resilient baseload coal and nuclear power plants will maintain a reliable supply of electricity for the region's energyintensive economy in two ways. First, the preservation of certain plants will avoid the need to replace lost generation with imports and the associated construction of infrastructure to facilitate such importation. Preserving baseload coal and nuclear power plants will keep these needed, reliable facilities running close to home without the need to depend on distant resources, particularly during catastrophic events like severe storms, to fulfill our region's dynamic need for reliable electricity. Second, premature plant closures will deplete the 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. In short, allowing baseload coal and nuclear power plants to close prematurely will have an adverse impact on the reliability of the region's electricity supply and on the reliable operation of the regional electricity system. Rates for the sale of electricity that are inadequate to sustain the operation of base load generation facilities that provide reliability and resiliency support cannot be considered to be just and reasonable. Because of the loss of jobs, the significant reduction in payments to local governments, and the decline in electricity resource and grid reliability that would result from deactivation of the nuclear and coal-fired generating facilities in Ohio, it is essential that the FERC adopt a rule, such as that proposed by DOE, which will ensure that such generating facilities are fully compensated for their costs and will remain in operation. In order to mitigate the risk that such generating units may be deactivated prematurely, IBEW Local 2357 strongly urges FERC to adopt the rule proposed by the DOE as promptly and comprehensively as possible. FERC has a sufficient record to act that will be further bolstered by the comments considered in this proceeding. FERC has thoroughly considered the impact of electric markets on the sustained operation of at-risk power plants and, as noted by the Secretary of the DOE, the time to act is now given the severe impacts to system reliability and resilience, and national security, attendant to the premature closure of crucial power plants. Any protracted delay in creating fully compensatory market rules will only exacerbate the problem of premature closures. In acting promptly, FERC should also direct the organized market operators to issue a rule that is not only compensatory (and based on the regulatory language of the Proposal) but comprehensive and enduring. The rules to be issued by operators of organized markets should be fair and transparent, and should ensure that critical power plants can continue to operate for the long-term and without the prospect of repeated re-examination and adjustment to their market compensation. The uncertainty that less than comprehensive and enduring market rules will engender will defeat the very purpose of preserving the extended operation of these muchneeded power plants. Respectfully submitted, Brian Fain President & Business Manager IBEW Local 2357 FE RC 0 7? WE eLibrary (formerly FERRIS) of: 2:1 mgg?L; E-rna this gage File List ACCESSION Number: 291710115943 Comment of Local 1413 uncar Type Flle Name 5le PDF FERC lirg PDF 1?3319 No cescripl or given FERC Generated PDF 121722 iJcc I'fo Ade 1c -J.ec:..est IJcn'e'Lsacl Izeset Helu FERG 0n||na_ WWUHJI ass-ma?a. Mums? 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. RM18-1-000 COMMENTS OF THE INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS, LOCAL UNION 1413 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 appropriately and fully for their costs of operation and will avoid premature retirement. Adoption of that rule will thus sustain the long?term viability of critical power plants, preserve and create jobs, maintain electric reliability, and provide substantial economic bene?ts to the many hard-working Americans living throughout the region. IBEW Local 1413 strongly supports the Pr0posal and shares the Secretary?s urgency that FERC act to direct operators of organized markets to issue the requested rule. FERC has the ability to act, and must act, without undue delay to avoid premature closure of crucial power plants and our members? loss of critical economic and reliability bene?ts. FERC has thoroughly examined how electric markets ?Jnction and how those markets affect the continued operation of crucial power plants needed for reliability for some time. FERC has the requisite basis to act now. There is no time for delay. In addition to acting FERC should also direct organized International Brotherhood of Electrical Workers market operators to issue a comprehensive and enduring set of rules, based on the regulatory language of the Proposal, for the proper compensation of critical power plants. Protracted proceedings undertaken by organized market operators that fail to develop fair, compensatory and transparent rules will only engender market uncertainty and delay in providing suf?cient compensation to these facilities, therebyjeopardizing the operation of the very plants that the DOE seeks to maintain in Operation. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Brad Goetz President Business Mgr. IBEW Local 1413 PO Box 122, Oak Harbor, Ohio 43449 419-205?2191 bngoetz@wcnet.org 11. DESCRIPTION OF IBEW LOCAL 1413 IBEW Local 1413 is a progressive labor organization that represents security professionals in the Generation industry. DESCRIPTION OF IBEW LOCAL 1413?s INTEREST IN PROCEEDING IBEW Local 1413 is a party to a collective bargaining agreement with the owners of baseload coal and nuclear power plants located in Ohio. As a result, the wages, terms and conditions of employment of our members may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, IBEW Local 1413 members have a direct and substantial interest in this proceeding. As well, the unique perspective of IBEW Local 1413 and its members will only serve to enhance the record in this proceeding. IV. COMMENTS The communities where struggling baseload coal and nuclear power plants are located are dependent on the jobs and economic deveIOpment Opportunities the power plants provide. The recent decline in Ohio?s electric power industry, for example, has led to reductions in operations and capital improvement expenditures at numerous power production and manufacturing facilities across Ohio. This has led to extreme hardship for the thousands of union workers employed in this industry as well as their families. It is imperative that baseload coal and nuclear plants continue to operate in light of these dire circumstances. Baseload coal and nuclear plants in Ohio provide thousands of MWs of reliable power, and provide union jobs and economic opportunities to IBEW Local 1413 members. The Davis Besse and Bayshore generation stations directly employ approximately 144 IBEW Local 1413 members, and the maintenance and capital improvement work on these plants supports the local economy by creating thousands of well-paying union jobs for contractors. In addition, these plants contribute millions each year in state and local tax revenues that support local schools, police and ?re departments and other vital public services. The loss of jobs, tax revenue, and the ripple effect of such losses throughout the local economy, will have a severely detrimental impact on the region. The issuance of a rule preserving the continued operation of resilient baseload coal and nuclear power plants will maintain a reliable supply of electricity for the region?s energy-intensive economy in two ways. First, the preservation of certain plants will avoid the need to replace lost generation with imports and the associated construction of infrastructure to facilitate such importation. Preserving baseload coal and nuclear power plants will keep these needed, reliable facilities running close to home without the need to depend on distant resources, particularly during catastrophic events like severe storms, to ful?ll our region?s dynamic need for reliable electricity. Second, premature plant closures will deplete the stable of highly skilled (and speci?cally trained and experienced) employees, many of whom have lived in the region for several years and who take great pride in their work. With a depletion of this skilled and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, 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. In short, allowing baseload coal and nuclear power plants to close prematurely will have an adverse impact on the reliability of the region?s electricity supply and on the reliable operation of the regional electricity system. Rates for the sale of electricity that are inadequate to sustain the operation of base load generation facilities that provide reliability and resiliency support cannot be considered to be just and reasonable. Because of the loss of jobs, the signi?cant reduction in payments to local governments, and the decline in electricity resource and grid reliability that would result from deactivation of the nuclear and coal-?red generating facilities in Ohio, it is essential that the FERC adopt a rule, such as that proposed by DOE, which will ensure that such generating facilities are compensated for their costs and will remain in operation. In order to mitigate the risk that such generating units may be deactivated prematurely, IBEW Local 1413 strongly urges FERC to adopt the rule proposed by the DOE as and comprehensively as possible. FERC has a sufficient record to act that will be further bolstered by the comments considered in this proceeding. FERC has thoroughly considered the impact of electric markets on the sustained operation of at-risk power plants and, as noted by the Secretary of the DOE, the time to act is now given the severe impacts to system reliability and resilience, and national security, attendant to the premature closure of crucial power plants. Any protracted delay in creating fully compensatory market rules will only exacerbate the problem of pre-mature closures. In acting FERC should also direct the organized market operators to issue a rule that is not only compensatory (and based on the regulatory language of the Proposal) but comprehensive and enduring. The rules to be issued by operators of organized markets should be fair and transparent, and should ensure that critical power plants can continue to operate for the long-term and without the prospect of repeated re-examination and adjustment to their market compensation. The uncertainty that less than comprehensive and enduring market rules will engender will defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, egg/es President Business Manager IBEW Local 1413 FE RC 7 ll 7 eLibrary {farmerly rwwv?emgav mm E-mail this gage File List Number: 291??!0115992' Desurlptinn: Enmme-nt of 29 under Type Flle Name Elze r-H-icr-cuS-nft IEEW Liz-cg 29 Lana' Saar-15 FltE- 23305 Ni:- ciescripi gin-en FE HE Gen Brat-2:5 1??33 Um: I'fzu Fad: 1c? Help Funny lawns FEED mllna. plasma windfall-Warm? WEB-MFG. 20171017-5092 FERC PDF (Unofficial) 10/17/2017 1:16:12 PM 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 INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS, LOCAL UNION 29 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 appropriately and fully for their costs of operation and will avoid premature retirement. Adoption of that rule will thus sustain the long-term viability of critical power plants, preserve and create jobs, maintain electric reliability, and provide substantial economic benefits to the many hard-working Americans living throughout the region. IBEW Local 29 strongly supports the Proposal and shares the Secretary's urgency that FERC act promptly to direct operators of organized markets to issue the requested rule. FERC has the ability to act, and must act, without undue delay to avoid premature closure of crucial power plants and our members' loss of critical economic and reliability benefits. FERC has thoroughly examined how electric markets function and how those markets affect the continued operation of crucial power plants needed for reliability for some time. FERC has the requisite 20171017-5092 FERC PDF (Unofficial) 10/17/2017 1:16:12 PM basis to act now. There is no time for delay. In addition to acting promptly, FERC should also direct organized market operators to issue a comprehensive and enduring set of rules, based on the regulatory language of the Proposal, for the proper compensation of critical power plants. Protracted proceedings undertaken by organized market operators that fail to develop fair, compensatory and transparent rules will only engender market uncertainty and delay in providing sufficient compensation to these facilities, thereby jeopardizing the operation of the very plants that the DOE seeks to maintain in operation. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Kenn Bradley Business Mgr. IBEW Local 29 986 Greentree Road, Pittsburgh, PA 15220 412-922-6969 kbradley@ibew29.org II. DESCRIPTION OF IBEW LOCAL 29 IBEW Local 29 is a progressive labor organization that represents individuals in the Utility, and Generation industries. III. DESCRIPTION OF IBEW LOCAL 29'S INTEREST IN PROCEEDING IBEW Local 29 is a party to collective bargaining agreements with the owners of baseload coal and nuclear power plants located in Pennsylvania. As a result, the wages, terms and conditions of employment of its members may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, IBEW Local 29 members have a direct and substantial interest in this proceeding. As well, the unique perspective of IBEW Local 29 and its members will only serve to enhance the record in this proceeding. 20171017-5092 FERC PDF (Unofficial) 10/17/2017 1:16:12 PM IV. COMMENTS The communities where struggling baseload coal and nuclear power plants are located are dependent on the jobs and economic development opportunities the power plants provide. The recent decline in Pennsylvania's electric power industry, for example, has led to reductions in operations and capital improvement expenditures at numerous power production and manufacturing facilities across Pennsylavania. This has led to extreme hardship for the thousands of union workers employed in this industry as well as their families. It is imperative that baseload coal and nuclear plants continue to operate in light of these dire circumstances. Baseload coal and nuclear plants in Pennsylvania provide thousands of MWs of reliable power, and provide union jobs and economic opportunities to IBEW Local 29 members. The Beaver Valley, Cheswick, and Brunot Island generation stations directly employ approximately 500 IBEW Local 29 members, and the maintenance and capital improvement work on these plants supports the local economy by creating thousands of well-paying union jobs for contractors. In addition, these plants contribute millions each year in state and local tax revenues that support local schools, police and fire departments and other vital public services. The loss of jobs, tax revenue, and the ripple effect of such losses throughout the local economy, will have a severely detrimental impact on the region. The issuance of a rule preserving the continued operation of resilient baseload coal and nuclear power plants will maintain a reliable supply of electricity for the region's energyintensive economy in two ways. First, the preservation of certain plants will avoid the need to replace lost generation with imports and the associated construction of infrastructure to facilitate such importation. Preserving baseload coal and nuclear power plants will keep these needed, 20171017-5092 FERC PDF (Unofficial) 10/17/2017 1:16:12 PM 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. In short, allowing baseload coal and nuclear power plants to close prematurely will have an adverse impact on the reliability of the region's electricity supply and on the reliable operation of the regional electricity system. Rates for the sale of electricity that are inadequate to sustain the operation of base load generation facilities that provide reliability and resiliency support cannot be considered to be just and reasonable. Because of the loss of jobs, the significant reduction in payments to local governments, and the decline in electricity resource and grid reliability that would result from deactivation of the nuclear and coal-fired generating facilities in Ohio, it is essential that the FERC adopt a rule, such as that proposed by DOE, which will ensure that such generating facilities are fully compensated for their costs and will remain in operation. In order to mitigate the risk that such generating units may be deactivated prematurely, IBEW Local 29 strongly urges FERC to adopt the rule proposed by the DOE as promptly and comprehensively as possible. FERC has a sufficient record to act that will be further bolstered by 20171017-5092 FERC PDF (Unofficial) 10/17/2017 1:16:12 PM the comments considered in this proceeding. FERC has thoroughly considered the impact of electric markets on the sustained operation of at-risk power plants and, as noted by the Secretary of the DOE, the time to act is now given the severe impacts to system reliability and resilience, and national security, attendant to the premature closure of crucial power plants. Any protracted delay in creating fully compensatory market rules will only exacerbate the problem of premature closures. In acting promptly, FERC should also direct the organized market operators to issue a rule that is not only compensatory (and based on the regulatory language of the Proposal) but comprehensive and enduring. The rules to be issued by operators of organized markets should be fair and transparent, and should ensure that critical power plants can continue to operate for the long-term and without the prospect of repeated re-examination and adjustment to their market compensation. The uncertainty that less than comprehensive and enduring market rules will engender will defeat the very purpose of preserving the extended operation of these muchneeded power plants. Respectfully submitted, Kenn Bradley Business Manager IBEW Local 29 20171017-5092 FERC PDF (Unofficial) 10/17/2017 1:16:12 PM Document Content(s) IBEW Local 29 Labor Comments 10.13.17.DOCX............................1-5 FE RC ?1 ll "1 Human; {farmerly arc; av n: E-n'nail this gage File List Number: WHEN-5132- Desurlptign: Enmrne-nt of Lia-cal 2116 under Type Flle Name Elze IEEW 29-6 mums-rue "Its. FE 3933953 Ni:- ciescripi gin-en FE Fill [Fe-n Hated 3233193 iJ-zn: I'fzu Pd: Uta-ruled Ileana-t Help Funny lama FEED Fianna mummum International Brotherhood of Electrical Workers Local Union N0. 246 - Established April 4, 1902 P.O. BOX188 626 N. Fourth Street Telephone (740) 282?7572 Fax (740) 282?4425 Steubenville, Ohio 43952 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. COMMENTS OF THE INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS, LOCAL UNION 246 (IBEW LU 246) 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 appropriately and fully for their costs of operation and will avoid premature retirement. Adoption of that rule will thus sustain the long-term viability of critical power plants, preserve and create jobs, maintain electric reliability, and provide substantial economic bene?ts to the many hard-working Americans living throughout the region. IBEW LU 246 strongly supports the Proposal and shares the Secretary?s urgency that FERC act to direct operators of organized markets to issue the requested rule. FERC has the ability to act, and must act, without undue delay to avoid premature closure of crucial power plants and our members? loss of critical economic and reliability bene?ts. FERC has thoroughly examined how electric markets function and how those markets affect the continued operation of crucial power plants needed for reliability for some time. FERC has the requisite basis to act now. There is no time for delay. In addition to acting FERC should also direct organized market operators to issue a comprehensive and enduring set of rules, based on the regulatory language of the Proposal, for the prOper compensation of critical power plants. Protracted proceedings undertaken by organized market operators that fail to develop fair, compensatory and transparent rules will only engender market uncertainty and delay in providing sufficient compensation to these facilities, thereby jeopardizing the operation of the very plants that the DOE seeks to maintain in operation. 1. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Kyle N. Brown Business Manager IBEW LU 246 626 North Fourth St., Steubenville, OH 43952 (740) 282?7572 union@ibew246.com II. DESCRIPTION OF IBEW Local 246 We are a labor organization, representing over two hundred and ?fty skilled electricians and their families in the Upper Ohio Valley. 111. DESCRIPTION OF IBEW LU 246?s INTEREST IN PROCEEDING IBEW LU 246 is a party to a collective bargaining agreement with the National Electrical Contractors Association, Steubenville Division, who service baseload coal and nuclear power plants located in Ohio and West Virginia. Our members work on major infrastructure and industrial development projects that are dependent on the continued operation of the baseload coal and nuclear power plants. As a result, the wages, terms and conditions of employment of its members may be directly affected by the actions taken by the ERC and operators of organized markets in this proceeding. Thus, IBEW LU 246 members have a direct and substantial interest in this proceeding. As well, the unique perspective of IBEW LU 246 and its members will only serve to enhance the record in this proceeding. IV. COMMENTS The communities where struggling baseload coal and nuclear power plants are located are dependent on the jobs and economic development opportunities the power plants provide. The recent decline in Ohio electric power industry, for example, has led to reductions in operations and capital improvement expenditures at numerous power production and manufacturing facilities across Ohio. This has led to extreme hardship for the thousands of union workers employed in this industry as well as their families. It is imperative that baseload coal and nuclear plants continue to operate in light of these dire circumstances. Baseload coal and nuclear plants in Ohio provide thousands of MWs of reliable power, and provide union jobs and economic opportunities to IBEW LU 246 members. The First Energy, W.H. Sammis Plant and the American Electric Power, Cardinal Plant directly employs approximately one thousand people, and the maintenance and capital improvement work on these plants supports the local economy by creating well-paying union jobs. In addition, the plants contribute millions each year in state and local tax revenues that support local schools, police and fire departments and other vital public services. IBEW LU 246 provides over one hundred construction and maintenance workers servicing these facilities. The loss of obs, tax revenue, and the ripple effect of such losses throughout the local economy, will have a severely detrimental impact on the region. The issuance of a rule preserving the continued operation of resilient baseload coal and nuclear power plants will maintain a reliable supply of electricity for the region?s energy-intensive economy in two ways. First, the preservation of certain plants will avoid the need to replace lost generation with imports and the associated construction of infrastructure to facilitate such importation. Preserving baseload coal and nuclear power plants will keep these needed, reliable facilities running close to home without the need to depend on distant resources, particularly during catastrophic events like severe storms, to ful?ll our region?s dynamic need for reliable electricity. Second, premature plant closures will deplete the stable of highly skilled Electricians, 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. In short, allowing baseload coal and nuclear power plants to close prematurely will have an adverse impact on the reliability of the region?s electricity supply and on the reliable operation of the regional electricity system. Rates for the sale of electricity that are inadequate to sustain the operation of base load generation facilities that provide reliability and resiliency support cannot be considered to be just and reasonable. Because of the loss of jobs, the significant reduction in payments to local governments, and the decline in electricity resource and grid reliability that would result from deactivation of the nuclear and coal??red generating facilities in Ohio, it is essential that the FERC adopt a rule, such as that proposed by DOE, which will ensure that such generating facilities are fully compensated for their costs and will remain in operation. In order to mitigate the risk that such generating units may be deactivated prematurely, IBEW LU 246 strongly urges FERC to adopt the rule proposed by the DOE as and comprehensively as possible. FERC has a suf?cient record to act that will be further bolstered by the comments considered in this proceeding. FERC has thoroughly considered the impact of electric markets on the sustained operation of at-risk power plants and, as noted by the Secretary of the DOE, the time to act is now given the severe impacts to system reliability and resilience, and national security, attendant to the premature closure of crucial power plants. Any protracted delay in creating fully compensatory market rules will only exacerbate the problem of pre-mature closures. In acting FERC should also direct the organized market operators to issue a rule that is not only compensatory, but comprehensive and enduring. The rules to be issued by operators of organized markets should be fair and transparent, and should ensure that critical power plants can continue to operate for the long-term and without the prospect of repeated re-examination and adjustment to their market compensation. The uncertainty that less than comprehensive and enduring market rules will engender will defeat the very purpose of preserving the extended operation of these much-needed power plants. Respectfully submitted, 77% Kyle N. Brown Business Manager IBEW Local Union 246 FE RC ?1 ll "1 Human; {farmerly rm: ?y n: 9:31.: E-n'nail this gage File List Number: 2nwm1E-5m1 Desurlptign: Enmrne-nts oi LDCIEI WT under Type Flle Name Elze IBEW Liz-ca Cummen?f?"DF 4135'?? Gamma-H15. c-f IEIEW Lat?Ell FE Fill [Fe-n Hated FIB-F 41332 Dec I'fzu Pd: Uta-ruled Ileana-t Help Funny lama FEED Fianna mummum jInternutional Profirrttroatt giertricat is i, ortterz Tura( 777 75 Pike Street o Middletown, PA 17057 Fax Number: (717) 944-4915 Office Number: (717) 944-0638 cfober 18, 2017 Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Re: Grid Resiliency Pricing Rule, Docket No. RM18-1-000 Dear Ms. Bose: Local 777 of the International Brotherhood of Electrical Workers ("Local 777") submits this letter in support of the Secretary of Energy's Proposed Grid Resiliency Pricing Rule ("Proposed Rule"), as published in the Federal Register on October 10, 2017. 82 Fed. Reg. 46940. Local 777 is the authorized collective bargaining representative for more than 300 of the 700 people who work at Three Mile Island Unit 1 ("TMI 1") in Middletown, PA. TMI 1 is a nuclear power plant with an electric generating capacity of 803 megawatts. The plant is licensed to operate by the Nuclear Regulatory Commission until 2034. Unfortunately, given the economics of the power markets under the existing pricing and resiliency policies of the Federal Energy Regulatory Commission ("FERC") and the PJM Interconnection (the Regional Transmission Organization overseeing the pricing and dispatch of TMI 1), TMI 1 is scheduled to cease operations in September 2019 -- 15 years ahead of schedule. While Local 777 is, of course, concerned about the jobs of its members, it also is vitally concerned about the future of nuclear power generation in this country. The nuclear power industry has an important role to play not just in the generation of electricity, but also in ensuring this country's national security. As the Secretary correctly noted in the preamble to the Proposed Rule, nuclear reactors are important sources of power 24 hours per day throughout the year. According to the plant's owner, Exelon Generation, during 2016 TMI 1 had an annual capacity factor of more than 96%. I This means that the plant can be relied on, day in and day out, regardless of weather conditions to reliably generate electricity. Moreover, the plant is not subject to temporary disruptions in fuel supplies due to inclement weather, natural disasters, or other events. As is the case for most nuclear reactors, TMI 1 needs 1 TMI 1 Fact Sheet, http://www.exeloncorp.com/locations/Documents/Three%20Mile%20Island%20Generating%20Station%20Fact%2 OS heet%20-%202017 .pdf to refuel only once every two years. Between refueling outages, the reactor does not require any access to outside fuel supplies. TMI l's most recent refueling outage ended on October 13, 2017, meaning that the plant is expected to run continuously until its expected permanent shut down on September 30, 2019. Local 777 fully supports the Secretary's citation to the letter from the North American Electric Reliability Corporation ("NERC") stating that nuclear generation has "high availability, low forced outages, and secured on-site fuel" allowing a reactor to be "operated in a manner independent of supply chain disruptions." Local 777 also agrees with NERC's warning that the premature retirement of a unit like TMI 1 "reduces resilience to fuel supply disruptions."2 The Secretary's reference to the Quadrennial Energy Review from January 2017 also is important. He is correct that "short-run markets may not provide adequate price signals to ensure long-term investments in appropriately configured capacity."3 In fact, the energy markets are seriously under-valuing the importance of baseload generation to the long-term reliability of the bulk power system. It is a fundamental principle of public utility economics that prices should be based on long-run marginal cost. This is essential because public utility assets have such long lives and provide a service that is essential not only to the long-term sustainability of the economy, but to public health and safety as well. For example, in his book, Principles of Public Utility Rates, Professor James Bonbright noted the importance of including capacity costs as part of the variable cost of utility assets.4 Yet, as the Secretary notes, the power markets today are not appropriately including capacity costs (and the value to the nation of that capacity) in power prices. Not mentioned by the Secretary, but also vitally important, is the critical nature of the nuclear power industry to this nation's security and military preparedness. The electric power industry provides one of the. most important career paths for veterans of the U.S. Navy's nuclear fleet. The Navy describes its nuclear-powered fleet as "the most formidable Fleet of nuclear-powered submarines and aircraft carriers on the planet." 5 If the nation's commercial nuclear power plants close, and if more plants are not constructed, then it will become increasingly difficult for the Navy to attract the talent needed to operate and maintain the submarines and aircraft carriers that help ensure our national security. In other words, the career path for members of the nuclear Navy will be destrOyed. Indeed, in 2014 the U.S. Department of Labor estimated that the 2 82 Fed, Reg. at 46943; citing NERC Letter to Secretary of Energy dated May 9, 2017. 82 Fed. Reg. at 46942-433, citing Transforming the Nation's Electricity System: The Second Installment of the Quadrennial Energy Review, Jan. 6, 2017. 3 James Bonbright, Principles of Public Utility Rates (New York NY 1961), p. 336 ("I conclude this chapter with the opinion, which would probably represent the majority position among economists, that the more significant marginal or incremental costs are those of a relatively long-run variety -- of a variety which treats even capital costs or 'capacity costs' as variable costs."). 5 U.S. Navy, Nuclear Power, https://www.navy.comicareers/nuclear-power.html. 2 number of jobs for nuclear engineers would decline by 4% by 2024,6 and that projection was prepared before the announced closing of TMI 1 and several other nuclear power plants. Finally, while not discussed in the Secretary's proposal, the effects of power plant emissions on the quality of life -- indeed on the very existence of life -- cannot be overlooked. For this reason, states like Illinois, New York, and Connecticut are creating special economic incentives for nuclear power plants because of their unique characteristic among large centralized power plants as zero-emission units. While these states are to be commended for recognizing the important economic and reliability contributions of nuclear power, piecemeal state actions are not the best approach to this problem. The bulk power market is an interstate (indeed, an international) market, and individual state solutions do not provide an optimal or uniform policy. There also is some question whether individual state zero-emission incentives will survive legal challenges that allege improper state interference in the interstate markets regulated by this Commission. While those challenges have failed in the district courts so far, competing power plant owners and others are continuing their challenges in the appellate courts, While Local 777 supports state efforts to use the zero-emission characteristics of nuclear generation to ensure the continued existence of nuclear power as an essential and highly reliable part of our energy future, a federal solution sanctioned by this Commission would be greatly preferred. The Secretary's Proposed Rule would provide that result -- the federal recognition of the importance to grid reliability, resiliency, and national security of having large baseload power plants with secure fuel supplies. Local 777 does not pretend to have the expertise in power markets to determine whether the Secretary's Proposed Rule is the perfect solution to these problems. It appears, however, that the proposal would make significant strides toward recognizing that nuclear generators play a vitally important role in the reliability, resiliency, safety, and security not only of the power grid, but of the country as a whole. Thank you for considering this perspective in your deliberations on these important issues. Sincerely, John H. Levengood President IBEW Local 777 U.S. Department of Labor, Bureau of Labor Statistics, Occupational Outlook Handbook, https://www.b1s.gov/ooh/architecture-and-engineeringinuclear-engineers.htm. 6 3 FE RC 0 7? eLibrary (formerly FERRIS) E-rna 1 his gage File List Accesslon Number: 2011101941016 CummenloleEW. Local 1194 under RM1B-1. Type Flle Name Micros-oft We'd IBEW Luca ?:194 Labor Comments 10,131? 9091' DOCK No a script or given FERC Gen erated PDF 25E iJcc I'fo Ade 1c -J.ec:..est IJcn'e'Lsacl Izeset Helu Slze 23365 FellingI Muse FERG OnllnE. plasma WEB-36M. October 19, 2017 Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: Grid Resiliency Pricing Rule FERC Docket No. RM18-1-000 COMMENTS OF THE INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS, LOCAL UNION 1194 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 and Pennsylvania will be compensated appropriately and fully for their costs of operation and will avoid premature retirement. Adoption of that rule will thus sustain the long-term viability of critical power plants, preserve and create jobs, maintain electric reliability, and provide substantial economic benefits to the many hard-working Americans living throughout the region. IBEW Local 1194 strongly supports the Proposal and shares the Secretary's urgency that FERC act promptly to direct operators of organized markets to issue the requested rule. FERC has the ability to act, and must act, without undue delay to avoid premature closure of crucial power plants and our members' loss of critical economic and reliability benefits. FERC has thoroughly examined how electric markets function and how those markets affect the continued operation of crucial power plants needed for reliability for some time. FERC has the requisite basis to act now. There is no time for delay. In addition to acting promptly, FERC should also direct organized market operators to issue a comprehensive and enduring set of rules, based on the regulatory language of the Proposal, for the proper compensation of critical power plants. Protracted proceedings undertaken by organized market operators that fail to develop fair, compensatory and transparent rules will only engender market uncertainty and delay in providing sufficient compensation to these facilities, thereby jeopardizing the operation of the very plants that the DOE seeks to maintain in operation. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Jaren Thompson Business Mgr. IBEW Local 1194 314 East Main Street, LaGrange, Ohio 44050 419-685-7543 IBEW 1194@gmail.com II. DESCRIPTION OF IBEW LOCAL 1194 IBEW Local 1194 is a progressive labor organization that represents individuals in the Utility, industry. III. DESCRIPTION OF IBEW LOCAL 1194'S INTEREST IN PROCEEDING IBEW Local 1194 is a party to a collective bargaining agreements with the owners of baseload coal and nuclear power plants located in Ohio and Pennsylvania. As a result, the wages, terms and conditions of employment of its members may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, IBEW Local 1194 members have a direct and substantial interest in this proceeding. As well, the unique perspective of IBEW Local 1194 and its members will only serve to enhance the record in this proceeding. IV. COMMENTS The communities where struggling baseload coal and nuclear power plants are located are dependent on the jobs and economic development opportunities the power plants provide. The recent decline in Ohio and Pennsylvania's electric power industry, for example, has led to reductions in operations and capital improvement expenditures at numerous power production and manufacturing facilities across these states. This has led to extreme hardship for the thousands of union workers employed in this industry as well as their families. It is imperative that baseload coal and nuclear plants continue to operate in light of these dire circumstances. Baseload coal and nuclear plants in these 2 states provide thousands of MWs of reliable power, and provide union jobs and economic opportunities to IBEW Local 1194 members. IBEW Local 1194 has approximately 275 members working in utility occupations in Ohio. In addition to direct labor in the generation sector, the maintenance and capital improvement work the plants in Ohio supports our local economies by creating thousands of well-paying union jobs for contractors. These plants also contribute millions each year in state and local tax revenues that support local schools, police and fire departments and other vital public services. The loss of jobs, tax revenue, and the ripple effect of such losses throughout the local economy, will have a severely detrimental impact on the region. The issuance of a rule preserving the continued operation of resilient baseload coal and nuclear power plants will maintain a reliable supply of electricity for the region's energyintensive economy in two ways. First, the preservation of certain plants will avoid the need to replace lost generation with imports and the associated construction of infrastructure to facilitate such importation. Preserving baseload coal and nuclear power plants will keep these needed, reliable facilities running close to home without the need to depend on distant resources, particularly during catastrophic events like severe storms, to fulfill our region's dynamic need for reliable electricity. Second, premature plant closures will deplete the 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. In short, allowing baseload coal and nuclear power plants to close prematurely will have an adverse impact on the reliability of the region's electricity supply and on the reliable operation of the regional electricity system. Rates for the sale of electricity that are inadequate to sustain the operation of base load generation facilities that provide reliability and resiliency support cannot be considered to be just and reasonable. Because of the loss of jobs, the significant reduction in payments to local governments, and the decline in electricity resource and grid reliability that would result from deactivation of the nuclear and coal-fired generating facilities in Ohio, it is essential that the FERC adopt a rule, such as that proposed by DOE, which will ensure that such generating facilities are fully compensated for their costs and will remain in operation. In order to mitigate the risk that such generating units may be deactivated prematurely, IBEW Local 1194 strongly urges FERC to adopt the rule proposed by the DOE as promptly and comprehensively as possible. FERC has a sufficient record to act that will be further bolstered by the comments considered in this proceeding. FERC has thoroughly considered the impact of electric markets on the sustained operation of at-risk power plants and, as noted by the Secretary of the DOE, the time to act is now given the severe impacts to system reliability and resilience, and national security, attendant to the premature closure of crucial power plants. Any protracted delay in creating fully compensatory market rules will only exacerbate the problem of premature closures. In acting promptly, FERC should also direct the organized market operators to issue a rule that is not only compensatory (and based on the regulatory language of the Proposal) but comprehensive and enduring. The rules to be issued by operators of organized markets should be fair and transparent, and should ensure that critical power plants can continue to operate for the long-term and without the prospect of repeated re-examination and adjustment to their market compensation. The uncertainty that less than comprehensive and enduring market rules will engender will defeat the very purpose of preserving the extended operation of these muchneeded power plants. Respectfully submitted, Jaren Thompson Business Manager IBEW Local 1194 FE RC ?1 ll "1 ELibl'al'y {farmerly .49. arc; av it in E-n'iail this gage File List Number: Enmme-nt of Lucal 3-59 uncle-r Type Flle Name Elze FEHC Ni:- ciescripi gin-en FE F13 Gen erateci EEFDF iJ-zi: I'fzu Pd: Hell:L Funny lawns FEED Fianna windfall-Warm? MERGE-MFG. October 19, 2017 Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: Grid Resiliency Pricing Rule FERC Docket No. RMl8?l?000 COMMENTS OF THE INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS. LOCAL UNION 459 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 will be compensated appropriately and fully for their costs of operation and will avoid premature retirement. Adoption of that rule will thus sustain the long- term viability of critical power plants, preserve and create jobs, maintain electric reliability, and provide substantial economic bene?ts to the many hard?working Americans living throughout the region. IBEW Local 459 strongly supports the Proposal and shares the Secretary?s urgency that FERC act to direct operators of organized markets to issue the requested rule. ERC has the ability to act, and must act, without undue delay to avoid premature closure of crucial power plants and our members? loss of critical economic and reliability bene?ts. FERC has thoroughly examined how electric markets function and how those markets affect the continued operation of crucial power plants needed for reliability for some time. ERC has the requisite basis to act now. There is no time for delay. In addition to acting FERC should also direct organized market Operators to issue a comprehensive and enduring set of rules, based on the regulatory language of the Proposal, for the proper compensation of critical power plants. Protracted proceedings undertaken by organized market operators that fail to develop fair, compensatory and transparent rules will only engender market uncertainty and delay in providing sufficient compensation to these facilities, thereby jeopardizing the operation of the very plants that the DOE seeks to maintain in operation. 1. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Paul Cameron Business Manager Financial Secretary IBEW Local 459 408 Broad St., Johnstown, PA 15906 814-535?7655 Paulibew459@gmail.com II. DESCRIPTION OF IBEW LOCAL 459 IBEW Local 45 9 is a progressive labor organization that represents approximately 1,850 individuals working in the utility and baseload generation industry in 111. DESCRIPTION OF IBEW LOCAL 459?s INTEREST IN PROCEEDING IBEW Local 459 is a party to collective bargaining agreements with owners of large baseload coal power plants located in As a result, the wages, terms and conditions of employment of our members may be directly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, IBEW Local 459 members have a direct and substantial interest in this proceeding. As well, the unique perspective of IBEW Local 459 and its members will only serve to enhance the record in this proceeding. IV. COMMENTS The communities where struggling baseload coal and nuclear power plants are located are dependent on the jobs and economic development opportunities the power plants provide. The recent decline in electric power industry, for example, has led to reductions in Operations and capital improvement expenditures at numerous power production and manufacturing facilities across This has led to extreme hardship for the thousands of union workers employed in this industry as well as their families. It is imperative that baseload coal and nuclear plants continue to operate in light of these dire circumstances. Baseload coal and nuclear plants in provide thousands of MWs of reliable power, and provide union jobs and economic opportunities to IBEW Local 459 members. The Keystone, Conemaugh, Homer City, Shawville and Seward generating stations produce approximately 6700 MW of power along with directly employing approximately 675 IBEW Local 459 members, and maintenance and capital improvement work on these plants supports the local economy by creating hundreds of well-paying union jobs for contractors. In addition, these plants contribute millions each year in state and local tax revenues that support local schools, police and fire departments and other vital public services. The loss of jobs, tax revenue, and the ripple effect of such losses throughout the local economy, will have a severely detrimental impact on the region. The issuance of a rule preserving the continued operation of resilient baseload coal and nuclear power plants will maintain a reliable supply of electricity for the region?s energy-intensive economy in two ways. First, the preservation of certain plants will avoid the need to replace lost generation with imports and the associated construction of infrastructure to facilitate such importation. Preserving baseload coal and nuclear power plants will keep these needed, reliable facilities running close to home without the need to depend on distant resources, particularly during catastrOphic events like severe storms, to ful?ll our region?s dynamic need for reliable electricity. Second, premature plant closures will deplete the stable of highly skilled (and speci?cally trained and experienced) employees, many of whom have lived in the region for several years and who take great pride in their work. With a depletion of this skilled and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less?skilled individuals, 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. In short, allowing baseload coal and nuclear power plants to close prematurely will have an adverse impact on the reliability of the region?s electricity supply and on the reliable operation of the regional electricity system. Rates for the sale of electricity that are inadequate to sustain the Operation of base load generation facilities that provide reliability and resiliency support cannot be considered to be just and reasonable. Because of the loss of jobs, the significant reduction in payments to local governments, and the decline in electricity resource and grid reliability that would result from deactivation of the nuclear and coal??red generating facilities in it is essential that the ERC adopt a rule, such as that proposed by DOE, which will ensure that such generating facilities are fully compensated for their costs and will remain in operation. In order to mitigate the risk that such generating units may be deactivated prematurely, IBEW Local 459 strongly urges FERC to adopt the rule proposed by the DOE as and comprehensively as possible. FERC has a sufficient record to act that will be further bolstered by the comments considered in this proceeding. ERC has thoroughly considered the impact of electric markets on the sustained operation of at-risk power plants and, as noted by the Secretary of the DOE, the time to act is now given the severe impacts to system reliability and resilience, and national security, attendant to the premature closure of crucial power plants. Any protracted delay in creating fully compensatory market rules will only exacerbate the problem of pre-mature closures. In acting FERC should also direct the organized market operators to issue a rule that is not only compensatory (and based on the regulatory language of the Proposal) but comprehensive and enduring. The rules to be issued by Operators of organized markets should be fair and transparent, and should ensure that critical power plants can continue to operate for the long?term and without the prOSpect of repeated re?examination and adjustment to their market compensation. The uncertainty that less than comprehensive and enduring market rules will engender will defeat the very purpose of preserving the extended operation of these much?needed power plants. Respectfully submitted, 5 . .. ,3 Zea-a?" :i 5/ . Paul Cameron Business Mgr. and Financial Secretary IBEW Local 459 FE RC 0 7? eLibrary (formerly FERRIS) E-rna 1 his gage File List Accesslon Number: 201110236113 Type Flle Name PDF BEW Loca Jnion FERC ing 6-1- PDF No cescripl or given FERC Gen erated PDF iJcc I'fo Ade 1c -J.ec:..est IJcn'e'Lsacl Izeset Helu Cummenl of IBEW Lucal Union 50 under RIMEH. Slze 298382 313007 FellingI Muse FERG OnllnE. plasma WEB-36M. October 23, 2017 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION ) Grid Reliability and Resiliency Pricing ) Docket No. RM18-1-000 ) ) COMMENTS OF THE INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS, LOCAL UNION 50 IN SUPPORT OF THE PROPOSED RESILIENCY RULE In accordance with the Federal Energy Regulatory Commission's ("FERC" or the "Commission") October 2, 2017 notice and the Commission Staff's October 4, 2017 notice, Local 50 of the International Brotherhood of Electrical Workers (Local 50) respectfully provides our initial comments on the Secretary of Energy's ("Secretary") September 28, 2017 proposed rulemaking (the "Proposed 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 will be compensated appropriately and fully for their costs of operation and will avoid premature retirement. Adoption of that rule will thus sustain the long-term viability of critical power plants, preserve and create jobs, maintain electric reliability, and provide substantial economic benefits to the many hardworking Americans living throughout the nation. We have grown increasingly concerned in recent years that well-intended public policy initiatives at both the federal and state level have lost sight of the first principle of the electric utility business: maintaining reliability at all times. This vital work of providing reliability at all times has provided well-paying, honorable work for our members for many decades. That is why we have been distressed to see the retirement of well running electric generation facilities, primarily coal, in regulated states and nationwide. We are also mindful of the ongoing threats facing the nuclear industry in nominally deregulated states (we refer to such states as nominally deregulated in view of the numerous public policy interventions to favor particular resources). The result of premature retirement of power plants has been loss of opportunity for hard working men and women in addition to reliability threats. IBEW Local 50 strongly supports the Proposal and shares the Secretary's urgency that FERC act promptly to direct operators of organized markets to issue the requested rule. FERC has the ability to act, and must act, without undue delay to avoid premature closure of crucial power plants and our members' loss of critical economic and reliability benefits. FERC has thoroughly examined how electric markets function and how those markets affect the continued operation of crucial power plants needed for reliability for some time. FERC has the requisite basis to act now. We were pleased that the Secretary's proposed rule has started an important conversation around pricing for resilience and reliability. We believe that inherent in such discussion is a greater focus on maintaining the fuel diversity that has benefitted our members, the nation's economy, and national security. We note that while this issue was often discussed, it was nowhere near the top of the energy policy agenda until the Secretary's proposed rule was issued. We are grateful to the Secretary for highlighting the importance of this issue and for moving it to the top of the agenda. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Brad Stevens President & Business Mgr. IBEW Local 50 1400 E. Nine Mile Road, Suite 50 Highland Springs, VA 23075 804-328-2972 brad.stevens@ibew50.org II. DESCRIPTION OF IBEW LOCAL 50 IBEW Local 50 is a progressive labor organization that represents more than 3,000 individuals employed by Dominion Energy, Southern Company, First Energy, and CraigBotetourt Electric Cooperative. These men and women keep our electrical grid operating 24 hours a day, seven days a week. Our members work in electric generation facilities of all types, as well as in transmission and distribution of electricity to some of our nation's most essential facilities, including the world's largest naval base, the Pentagon, and numerous other military, intelligence, and homeland security installations. Accordingly, we are mindful of the need to deliver around-the-clock electricity 365 days a year to keep our nation safe and secure, our economy functioning, and our homes heated, cooled, and lit. III. DESCRIPTION OF IBEW LOCAL 50'S INTEREST IN PROCEEDING IBEW Local 50 is party to collective bargaining agreements with owners whose portfolios include baseload coal and nuclear power plants located in Alabama, Georgia, North Carolina, Ohio, Pennsylvania, Virginia, and West Virginia. As a result, the wages, terms and conditions of employment of its members may be directly as well as indirectly affected by the actions taken by the FERC and operators of organized markets in this proceeding. Thus, IBEW Local 50 members have a direct and substantial interest in this proceeding. As well, the unique perspective of IBEW Local 50 and its members will only serve to enhance the record in this proceeding. IV. COMMENTS The communities where struggling baseload coal and nuclear power plants are located are dependent on the jobs and economic development opportunities the power plants provide. The reductions in operations and capital improvement expenditures at numerous power production and manufacturing facilities across the country has led to extreme hardship for the thousands of union workers employed in this industry as well as their families. It is imperative that baseload coal and nuclear plants continue to operate in light of these dire circumstances. Baseload coal and nuclear plants provide good paying union jobs and economic opportunities to IBEW Local union members. In addition to direct labor in the generation sector, the maintenance and capital improvement work at the plants supports the local economies by creating thousands of good paying union jobs for contractors. These plants also contribute significant and vital state and local tax revenues that support local schools, police and fire departments and other vital public services. The loss of jobs, tax revenue, and the ripple effect of such losses throughout local economies, will have a severely detrimental impact on the country. The issuance of a rule preserving the continued operation of resilient baseload coal and nuclear power plants will maintain a reliable supply of electricity for the region's energyintensive economy in two ways. First, the preservation of certain plants will avoid the need to replace lost generation with imports and the associated construction of infrastructure to facilitate such importation. Preserving baseload coal and nuclear power plants will keep these needed, reliable facilities running close to home without the need to depend on distant resources, particularly during catastrophic events like severe storms, to fulfill our dynamic need for reliable electricity. Second, premature plant closures will deplete the pool of highly skilled (and specifically trained and experienced) employees. 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 our ability to respond promptly to severe contingencies affecting the operation of these remaining plants in operation. In short, allowing baseload coal and nuclear power plants to close prematurely will have an adverse impact on the reliability of the nation's electricity supply and on the reliable operation of regional electricity systems. Rates for the sale of electricity that are inadequate to sustain the operation of base load generation facilities that provide reliability and resiliency support cannot be considered to be just and reasonable. Because of the loss of jobs, the significant reduction in payments to local governments, and the decline in electricity resource and grid reliability that would result from deactivation of nuclear and coal-fired generating facilities it is essential that FERC adopt a rule, such as that proposed by DOE, which will ensure that such generating facilities are fully compensated for their costs and will remain in operation. In order to mitigate the risk that such generating units may be deactivated prematurely, IBEW Local 50 strongly urges FERC to adopt the rule proposed by the DOE as promptly and comprehensively as possible. We believe that FERC has a sufficient record to act that will be further bolstered by the comments considered in this proceeding. FERC has thoroughly considered the impact of electric markets on the sustained operation of at-risk power plants and, as noted by the Secretary of the DOE, the time to act is now given the severe impacts to system reliability and resilience, and national security, attendant to the premature closure of crucial power plants. Any protracted delay in creating fully compensatory market rules will only exacerbate the problem of pre-mature closures. In acting promptly, we believe FERC should also direct the organized market operators to issue a rule that is not only compensatory (and based on the regulatory language of the Proposal) but comprehensive and enduring. The rules to be issued by operators of organized markets should be fair and transparent, and should ensure that critical power plants can continue to operate for the long-term and without the prospect of repeated reexamination and adjustment to their market compensation. The uncertainty that less than comprehensive and enduring market rules will engender will defeat the very purpose of preserving the extended operation of these much-needed power plants. We were pleased that the Secretary's proposed rule has started an important conversation around pricing for resilience and reliability. We believe that inherent in such discussion is a greater focus on maintaining the fuel diversity that has benefitted our members, the nation's economy, and national security. We note that while this issue was often discussed, it was nowhere near the top of the energy policy agenda until the Secretary's proposed rule was issued. We are grateful to the Secretary for highlighting the importance of this issue and for moving it to the top of the agenda. We urge the Commission to act with the utmost dispatch to work with the Secretary and other policy makers to preserve the around-the-clock resources that power our nation and employ our members. We view the Secretary's action and the Commission's deliberations as bolstering rather than competing with state specific action (such as Virginia's recent decision to encourage life extensions of existing nuclear units). On behalf of our members we stress the need for prompt action, we emphasize the importance of this issue for the day-to-day functioning of our 21st century society, and we encourage the Commission to keep its focus on the big picture needed to address this issue rather than on the vested interests of any particular stakeholder who may argue for delay or inaction. There is a price to doing nothing. That price is less security for our nation, less prosperity for our economy, and fewer opportunities to the men and women who keep our society running each and every day. For these reasons we urge prompt action. Thank you for considering our comments. Respectfully submitted, Brad Stevens President & Business Manager IBEW Local 50