FE RC ll 7 eLibrary {farmerly Wag rm: EV E-mail this gage File List Number: Comment oi FimtEnargy Corp. under Filed) Type Flle Name Elze LIMITED IS-F JEFF 25?? mmn'ie "Its tn: FE Ni:- cie script-cur given FE HE Gen Brat-2:3 PIS-F ??405 Um: I'fa min: 1-: mas-t Funny lama FEED mllna. plasma mammawm? MERGE-MM. 10/24/2017 error You don't have permission to access this document. This document (eLibrary accession no. 20171017-5082) is Privileged. The public may file a FOIA request under 18 C.F.R. 388.108. https://elibrary.ferc.gov/idmws/common/FN_error.asp?flag=18&fileNetID=32462021&pageNumber=&AccNum=20171017%2D5082 1/1 20171016-5082 FERC PDF (Unofficial) 10/16/2017 10:06:51 AM October 16, 2017 Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: Grid Resiliency Pricing Rule FERC Docket No. RM18-1-000 COMMENTS OF THE UNITED WAY OF JEFFERSON COUNTY 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. The UNITED WAY OF JEFFERSON COUNTY 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 the loss of critical economic and reliability benefits. Without these critical units, UNITED WAY OF JEFFERSON COUNTY will be challenged to support the health, education and financial stability of our community. There is 20171016-5082 FERC PDF (Unofficial) 10/16/2017 10:06:51 AM 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: KATE SEDGMER EXECUTIVE DIRECTOR UNITED WAY OF JEFFERSON COUNTY PO BOX 1463, 511 N. FOURTH ST. STEUBENVILLE, OH 43907 740-284-9000 KATESEDGMER@UNITEDWAY-JC.ORG II. DESCRIPTION OF UNITED WAY OF JEFFERSON COUNTY [Insert generic description of organization] III. DESCRIPTION OF UNITED WAY OF JEFFERSON COUNTY INTEREST IN PROCEEDING The UNITED WAY OF JEFFERSON COUNTY is a non-profit entity located in Ohio. Our organization advances the health, education and financial stability of every person in our community. The continued operation of the baseload coal and nuclear power plants translates into safer and more prosperous communities. Thus, the UNITED WAY OF JEFFERSON COUNTY members have a direct and substantial interest in this proceeding. As well, the unique perspective of the UNITED WAY OF JEFFERSON COUNTY and its members will only serve to enhance the record in this proceeding. 20171016-5082 FERC PDF (Unofficial) 10/16/2017 10:06:51 AM 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 at numerous power production and manufacturing facilities across Ohio This continued decline will impact UNITED WAY OF JEFFERSON COUNTY ability to bring positive impacts to the 60,000 residents in the region, including support for the health, education and financial stability of our communities. Baseload coal and nuclear plants in Ohio provide economic opportunities to our community. If possible, please describe economic impact of the plants in state or region: For example, First Energy contributes over $15,000 each year to our organization that supports services provided to our communities, including sexual assault and domestic violence services, health and mental health services, drug and alcohol presentation for youth and adults, and food to over 1,000 families every month. 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, 20171016-5082 FERC PDF (Unofficial) 10/16/2017 10:06:51 AM 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 provide services to our community. 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, the UNITED WAY OF JEFFERSON COUNTY 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 pre-mature 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 20171016-5082 FERC PDF (Unofficial) 10/16/2017 10:06:51 AM 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, KATE SEDGMER EXECUTIVE DIRECTOR UNITED WAY OF JEFFERSON COUNTY 20171016-5082 FERC PDF (Unofficial) 10/16/2017 10:06:51 AM Document Content(s) UNITED WAY OF JEFFERSON COUNTY comments to FERC.DOCX..................1-5 FE RC 0 7? WE eLibrary (formerly FERRIS) of: 2:1 mgg?L; E-rna this gage File List ACCESSION Number: 291710115953 Comment of Unilac We}; of Beaver anar Type Flle Name 5le PDF U1i1ed Way of Beaver Commens?DE No script or given FERC Gen erated PDF 31333 no: I'fo Ade 1c -J.ec:..est IJcn'e'Lsacl Izeset Helu FERG 0n||na_ WWUHJI ass-ma?a. Mums? October 16, 2017 Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: Grid Resiliencv Pricing Rule FERC Docket No. RM18-1-000 COMMENTS OF THE UNITED WAY OF BEAVER COUNTY 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 Beaver County, will be compensated appropriately and fully for their costs of operation and will avoid premature retirement. Adeption 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 United Way of Beaver County of 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 the loss of critical economic and reliability bene?ts. Without these critical units, the UW of BC will be challenged to support the health, education and ?nancial stability of our community. 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: Michael J. Rubino Executive Director United Way of Beaver County 3582 Brodhead Rd Suite 205, Monaca PA 15061 724-774-3210 rubino@unitedwaybeaver.org II. DESCRIPTION OF UNITED WAY OF BEAVER COUNTY Local area non-pro?t organization dedicated to working with the business, professional and residential community to raise and distribute funds to human service agencies to help those less fortunate in Beaver County PA. DESCRIPTION OF THE UNITED WAY OF BEAVER INTEREST IN PROCEEDING The United Way of Beaver County is a non-pro?t entity located in the western PA county of Beaver. Our organization advances the health, education and ?nancial stability of every person in our community. The continued operation of the baseload coal and nuclear power plants translates into safer and more prosperous communities. Thus, the clients of the UW of BC have a direct and substantial interest in this proceeding. As well, the unique perspective of the UW of BC 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, charity and economic development opportunities the power plants provide. The recent decline in W. electric power industry, for example, has led to reductions in operations at numerous power production and manufacturing facilities across the tri-state area. This continued decline will impact the United Way of Beaver County?s ability to bring positive impacts to Beaver County residents in the region, including support for the health, education and ?nancial stability of our communities. Baseload coal and nuclear plants in W. PA provide economic opportunities to our community. The employees and corporate donations of the First Energy Nuclear Power Plant and the Bruce Mans?eld Coal Generation Plant make up almost 15% of the annual donations of the United Way of Beaver County. In dollars that is approximately $120,000 annually to help provide aid to thousands of people in Beaver County PA. These plants also provide help with food drives and ?day of Caring? volunteers that could not be replaced easily. 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, 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, Michael J. Rubino 9 Executive Director United Way of Beaver County FE RC Fill l'l eLibrary (formerly FERRIS) it tbs! cm E-rna 7| lnis gage File List Accession Number: Desarlplion: Cummente at Executive Direclol Geer M. Young re the Grid Resiliency.I Pricing Rule under Type File Name Size FERC Gen erated PDF HIIp-An?ulhh 12512119 PDF 20158? Ln?h: aunt All Image Range From To HI hone Page 1 33559 page 2 32-121 pa ge 3 213.39 mm 2327'5 Pa 9 2?333 ucc I'fo Mic 1c -J.ecLest Ileset Help Funny ramming FERC Onllne. pleene 20171024-0012 FERC PDF (Unofficial) 10/24/2017 .l.i Tgg~il 6~~~2 ~ I iVF,Pj E~i 223 North Mercer Street, Suite 101, New Castle, Pennsylvania 16101 Phone: 724.658.8528 Fax: 724.658.6384 Email: uwlawctyecomcast.net Websita: www.uwlawcty.org Please like us on Facebook President Sara A. Dudssh October 18, 2017 Vice-President Wayne J. Alexander Ssm B. Biasucci Gerald D. Prestopine Federal Energy Regulation Commission Attn: Kimberly Bose, Secretary Becretaty Christy L. Verenski . I Rm18-1 Assistant Secretary Debbie Currie 888 First Street Washington, Treasurer Jason Shaffer rtt NE DC roy 7 20426 g-d4n r~' RE: Comments on Rulemaking (RM 18-1) Bxesutlve Direstor Gsyle M. Young I/I ~ co Board of Directors Sherie Babb Barbara Bernardi Richard Galisno C/t Dear SeCretary BOSe: am attaching our FERC Docket No. RM18-1-000 in response to the Grid Resiliency Pricing Rule. We strongly support keeping First Energy/Penn Power in our community because they provide stability to our community. United Way experienced a loss of Doug Mclltrot Sydney McKnight $400,000 dOllarS OVer the laSt 20 yearS leaVing the United Way Campaign in COrpOrate ",,"d'",D',",;k ,,and employee giving. The Lawrence County community cannot sustain the loss of the M Bradley olsomn+Jrn Esq.type of revenue and community impact that the employees bring to our area. Charles Jackson Josh Lamancusa, Esq. Joanne Preston John Sarandrea I We urge you to make sure our community is compensated appropriately and fully for their costs of operation and will avoid retirement of First Energy. We understand if this would happen it would take our poverty rate to that of a third-world country. Terri Stramba Harold Taylor Frank Telesr Howard Thompson Enpernus Dr. Mabel Paige If you need more information or have additional questions, please feel free or 724.658.8528. me at aavlevounawuwlawctv.ora to contact Sincerely yours, .Young Executive Direct Gayl Enclosure United Way Mission: To increase the organized capacity of people to care for one another. Ampy el ate os 1 nmlslmdan d smn6et'l~an tmybe obhilnnlh pm PA Sap m ant ol stet byoalllnp loll I e Shin Mnnwm la 1 IM leymnp. Seplnmtla decanal Imply e donlement' 20171024-0012 FERC PDF (Unofficial) 10/24/2017 Re~ Sss rgi v~~v ~ I lfdF..i' dg geee4y ddsfnradsda 223 North Mercer Street, Suite 101, New Castle, Pennsylvania 16101 Phone: 724.658.8528 Fax: 724.658.6394 Email: uwlawctyglcomcsst.net Website: www.uwlawcty.org Please like us on Facabook President Sara A. Dudash Vice-President Wayne J. Alexander Sam B. Biasucci Gerald D. Prestopine October 17, 2017 Secretary Christy L. Verenski Assistant Sscretsrf Debbie Currie Federal Energy Regulatory Commission Secretary of the Commission Treasurer Jason Shaffer Executive Director Gayle M. Young 888 First Street, NE Washington, DC 20424 i Board of Directors Sherie Babb Barbara Bernsrdi Re: Richard Galiano Cathy loanilli Charles Jackson Josh Lamancusa, Esq. Drew McDowss Doug Mclltrot Sydney McKnight Jason Medure, Esq. Judge Dominick Motto Bradley Olson, Jr., Esq. Joanne Preston John Sarsndrea Terri Stramba Harold Taylor Frank Telesz Howard Thompson Emeritus Dr. Mabel Paige Grid Resiliencv Pricma Rule FERC Docket No. RM18-1-000 COMMENTS OF THE UNITED WAY OF LAWRENCE COUNTY IN SUPPORT OF THE PROPOSED RESILIENCY RULE of Energy On September 28, 2017, the Department (mDOEm) issued the "Grid Resiliency Pricing Rule" (the "Proposal" ) directing the Federal Energy Regulatory (mFERCm) to adopt Commission a rule requiring operators of organized markets to "ensure that certain reliability and resiliency attributes are fully valued." Such a rule, as contemplated of electric generation sources by the regulatory of the language Proposal, will ensure that existing nuclear snd coal-fired electric generating stations in Western Pennsylvania of operation will be compensated and will avoid premature sustain the long-term viability maintain electric reliability, hard-working appropriately retirement. Adoption and fully for their costs of that of critical power plants, preserve and provide substantial rule will thus and create jobs, economic benefits to the many Americans living throughout the region. United Way Mission: To increase the organized capacity of people to care for one another. 'Amsnofsl mnsmlnndenme anddne I mmmedo ~beomd maomebennnmmnmemofnenebrmends afnnndsbnr edsamsseoerbbobu.bann Io doesnms nbe dmsemenb' 20171024-0012 FERC PDF (Unofficial) 10/24/2017 The United Way of Lawrence County or UWLC strongly supports the Proposal and shares the Secretary's urgency that FERC act promptly of to direct operators 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 the loss of critical economic will be challenged community. and reliability benefits. Without these critical units, UWLC to support the health, education and financial stability rules, based on the regulatory of critical power language plants. Protracted that fail to develop engender market uncertainty of the and enduring fair, compensatory undertaken by organized and transparent of market rules will only and delay in providing sufficient compensation to these of the very plants that the DOE seeks to maintain in operation. COMMUNICATIONS All communications, set Proposal, for the proper compensation proceedings facilities, thereby jeopardizing the operation I. our There is no time for delay. In addition to acting promptly, FERC should also direct organized market operators to issue a comprehensive operators of correspondence, and documents related to this proceeding should be directed to the following person: Gayle M. Young Executive Director United Way of Lawrence County 223 North Mercer Street New Castle, PA 16101 724.658.8528 gayleyounguwlawcty.org 20171024-0012 FERC PDF (Unofficial) 10/24/2017 II. DESCRIPTION OF UNITED WAY OF LAWRENCE COUNTY The United way of Lawrence County is a fundraising established in 1923 as a volunteer-driven organization. It was organization that raises funds for various non-profit programs in Lawrence County. The funds raised through the campaign stay in our community to make sure services are available for families in need. United Way has evolved over time and is recognized as a leader/convener in our community. III. DESCRIPTION OF UNITED WAY OF LAWRENCE COUNTY'S INTEREST IN PROCEEDING The United Way of Lawrence County is a non-profit close to the Ohio border. Our organization Pennsylvania education and financial stability operation of the prosperous entity located in Western of every advances person in our community. the health, The continued baseload coal and nuclear power plants translates into safer and more communities. interest in this proceeding. Thus, the UWLC members have a direct and substantial As well, the unique perspective of the UWLC 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 plants provide. the power The recent decline in Lawrence County electric power industry, for example, has led to reductions manufacturing opportunities in operations at numerous power production facilities across Lawrence County and Western Pennsylvania]. and This 20171024-0012 FERC PDF (Unofficial) 10/24/2017 continued decline will impact United Way of Lawrence County's ability to bring positive impacts to the 85,000 residents in the region, including support for the health, education and financial stability of our communities. Baseload coal and nuclear plants in Western Pennsylvania opportunities to our community. These companies employ This would have a catastmphic many families provide economic affect in our area. in our area and our median income is currently at $39,000 and this would be reduced which would affect the poverty level for Lawrence County. For example, Penn Power, New Castle Location contributes close to $40,000 each year to our organization that supports services provided to our communities. Penn Power/ First Energy provides leadership to the United Way of Lawrence County and our Lawrence County Economic Development organization. Their leadership and increase leadership the ability enhances support for community revenue, and the ripple effect to generate enrichment of such losses new businesses programs. throughout The loss of jobs, tax 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 20171024-0012 FERC PDF (Unofficial) 10/24/2017 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 this skilled and experienced group of workers, and the possible replacement workers with more distant and perhaps less-skilled individuals, of jobs, of these we will see a direct and adverse impact on our ability to provide services to our community. the loss of Because the significant reduction in payments to local governments, of and the decline in electricity resource and grid reliability that would result Irom deactivation of the nuclear and coal-fired generating facilities in Western 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 prematurely, units may be deactivated the UWLC 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 risk power plants and, as noted by the Secretary given the severe impacts to system reliability of the DOE, of at- the time to act is now and resilience, and national security, 20171024-0012 FERC PDF (Unofficial) 10/24/2017 attendant to the premature closure creating fully compensatory of crucial power plants. Any protracted delay in market rules will only exacerbate the problem of pre- mature closures. In acting promptly, FERC should also direct the organized market operators to issue a rule that is not only compensatory Proposal) but comprehensive (and based on the regulatory language and enduring. The rules to be issued by operators organized markets should be fair and transparent, and adjustment to their market compensation. than comprehensive purpose of preserving and enduring of and should ensure that critical power plants can continue to operate for the long-term and without the prospect re-examination of the of repeated The uncertainty that less market rules will engender will defeat the very of these power plants. the extended operation much-needed Respectfully submitted, hg . Young, Ex utive Direct Gayl United Way of Lawrence County 20171024-0012 FERC PDF (Unofficial) 10/24/2017 Document Content(s) 14722693.tif..........................................................1-7 FE RC ?1 ll "1 eLibrery {fermerly rm: ?y n: 9:31.: E-n'nail this gage File List Number: BUNCH-513E- Desurlptign: Eemrnent el Penn-Hermureet Develepmenl. Cerperetien under attache-5| letter. Type Flle Marne Elze ri'lliCF'EIS'Cl'I-t We'd FNDC e-l Sue-pert - 10 15 ?1113'3'5 Ni:- er' git-en FE Flt: [Fen ereteci iJec I'fe Fade 1e -teeL-eet Berra-Lead Help October 13, 2017 Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: Grid Resiliency Pricing Rule FERC Docket No. RM18-1-000 COMMENTS OF THE PENN-NORTHWEST DEVELOPMENT CORPORATION 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 Mercer County 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. The Penn-Northwest Development Corporation ("PNDC") 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 the loss of critical economic and reliability benefits. Without these critical units, PNDC will be challenged to support the health, education and financial stability of our community. 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: Randy P. Seitz President/CEO Penn-Northwest Development Corporation 39 Chestnut Avenue Sharon, PA 16146 724-662-3705 rpseitz@penn-northwest.com II. DESCRIPTION OF PENN-NORTHWEST DEVELOPMENT CORPORATION As Mercer County's lead economic development agency, Penn-Northwest Development Corporation (PNDC) strives to benefit our region and make our community a better place. Penn-Northwest's business is to ensure the businesses throughout Mercer County succeed, thereby ensuring the economic vitality of our region. We serve as a strategic partner to help new and existing businesses Make it in! Mercer County. PNDC was established in 1985 as a 501 (c)(3) private, non-profit, economic development corporation. Our mission is to attract new business and industrial investment, provide outreach and retention services to support the retention and expansion of value added business and industry, and provide coordination and support services for economic development in the Mercer County, PA region. Since we started, PNDC has participated in more than 400 Development, Expansion, Retention and Community projects, resulting in the creation of nearly 10,000 new jobs and the retention of over 15,000 jobs. The last 32 years of Economic and Community Development activity has resulted in over $1 billion in public/private investment in the County. III. DESCRIPTION OF PENN-NORTHWEST DEVELOPMENT CORPORATION'S INTEREST IN PROCEEDING The Penn-Northwest Development Corporation is a non-profit entity located in Mercer County, Pennsylvania. Our organization advances the health, education and financial stability of every person in our community. The continued operation of the baseload coal and nuclear power plants translates into safer and more prosperous communities. Thus, the PNDC members have a direct and substantial interest in this proceeding. As well, the unique perspective of the PNDC 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 Mercer County electric power industry, for example, has led to reductions in operations at numerous power production and manufacturing facilities across Mercer County and throughout Pennsylvania. This continued decline will impact PNDC's ability to bring positive impacts to nearly 115,00 residents in the County, and nearly 550,000 people in the region, including support for the health, education and financial stability of our communities. Baseload coal and nuclear plants in the larger Mercer County region provide economic opportunities to our community. 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 fulfill our region's dynamic need for reliable electricity. Second, premature plant closures will deplete the stable of highly skilled (and specifically trained and experienced) employees, many of whom have lived in the region for several years and who take great pride in their work. With a depletion of this skilled and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, we will see a direct and adverse impact on our ability to provide services to our community. 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 the Mercer County region, 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 PNDC 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 pre-mature 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 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. Respectfully submitted, Randy P. Seitz President/CEO Penn-Northwest Development Corporation FE RC ?1 ll "1 Human; {farmerly rm: ?y n: 9:31.: E-n'nail this gage File List Number: 201r1mr-51:u3 Desurlptign: Enmrne-nt of Ernawa County Imp-rmmenl. Corporation under Type Flle Marne EIEE FE RC Tami-war 9255'? Hi:- ciescripi gin-en FE Fill [Fe-n Hated EIEECIE iJ-zn: I'fzu Pd: Umn-?Lnad Ileana-t Help Funny lama FEED Fianna mummum 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 OTTAWA COUNTY IMPROVEMENT CORPORATION IN SUPPORT OF THE PROPOSED RESILIENCY RULE I have been representing the Ottawa County Improvement Corporation for more than 12 years and have worked at the state and regional level in economic development capacities where retaining businesses and attracting new business has become my specialty. Over my 15+ year career, I have seen dramatic changes in Ohio's economy and of the Northwest Ohio regional economy, which is fueled by a robust manufacturing and industrial base. I can tell you firsthand that the relationship between the strength of a state's and region's economy, and the need for a resilient and reliable electricity grid, are deeply interconnected. Without an electricity grid that can withstand external interferences and compromises, economic prosperity in this nation will surely come to a standstill. This critical linkage between a resilient and reliable grid and economic prosperity has become even more crucial given the recent catastrophic events such as severe storms, the Polar Vortex and the rise of international tensions that threaten to compromise our nation's prosperity. Now, more than ever, it is essential that all prudent steps be taken to ensure that our region's economy and electricity grid are sufficiently bolstered to withstand such events. It is with background that I write with a sense of urgency to address a recent proposal issued by the Department of Energy ("DOE") that most of my constituents and I whole-heartedly support. On September 28, 2017, the DOE issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to ensure that certain reliability and resiliency attributes of electric generation sources with at least a 90-day fuel supply are fully valued. Such a rule, as contemplated by the regulatory language of the Proposal, will ensure that existing baseload nuclear and coal-fired electric generating stations, which are the foundational pieces of our country's electricity grids, will be compensated appropriately and fully for their costs of operation and will avoid premature retirement. Adoption of that rule will sustain the regional economy, enhance reliability and resiliency, assist in reducing harmful emissions and maintaining air quality standards, and help avert the financial distress affecting certain coal and nuclear power plants, including one nuclear plant located in Ottawa County, Ohio. It is my fear that this plant, and others, may be retired prematurely if the Proposal is not adopted. Because of these reasons, and many others,, I strongly support the DOE Proposal and share 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 my community's 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. Additionally, FERC has conducted several technical studies and issued numerous reports reflecting the concerns over preserving the reliability and resiliency characteristics of our country's baseload plants. Without a doubt FERC has the requisite basis to act now. There is no time for 2 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 baseload power plants with a minimum of 90-day supply of fuel onsite. 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 and further jeopardizing the stability of our community's economic base. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Jamie N. Beier Grant Director Ottawa County Improvement Corporation 8043 W. State Route 163, #100 Oak Harbor, OH 43449 (419) 707-0164 jbgrant@ocic.biz II. DESCRIPTION OF OTTAWA COUNTY IMPROVEMENT CORPORATION AND INTEREST IN PROCEEDING The Ottawa County Improvement Corporation is a non-profit economic and workforce development agency located in Ottawa County, Ohio and is responsible for business retention & expansion efforts, new business attraction and workforce development services to businesses and individuals in the community. The Davis Besse Nuclear Power Station owned by FirstEnergy Corporation is located in my county, and provides over 1,500 direct and indirect jobs for my employment base alone, as well as millions of dollars in tax revenues that support local governments. The premature retirement of Davis Besse Nuclear Power Station due to the failure 3 of wholesale power markets in valuing key attributes, such as resiliency, will have a direct and dire impact on jobs and tax base in the community I represent. Therefore I, in my official capacity as Director have a direct and substantial interest in this proceeding. III. COMMENTS A. The Premature Retirement of the Davis Besse Nuclear Power Station Will Have a Significant Economic Impact in Ottawa County, Ohio Residents of Ottawa County and throughout Northern Ohio not only work at our plant, but they also work for companies that supply an array of goods and services to the generation facilities that are at risk of closure. In addition, they are employed on major infrastructure and industrial development projects that are dependent on the continued operation of the baseload nuclear power plant. Ohio's two nuclear power plants are responsible for a GDP impact of $510 million annually to our economy. As a result, the wages, and continued and future employment opportunities will be directly affected by the closure of these plants. Simply put, closure of Davis Besse Nuclear Power Station will all but decimate Ottawa County, Ohio's economy. A majority of our employment base will evaporate, our residential communities will become ghost towns, and an overall dramatic decline in our economy will be felt immediately. All due to a notable decline in the electric power industry that currently does not offer a balanced portfolio that reflects the true value of all energy generation attributes. It is imperative that baseload coal and nuclear plants continue to operate in light of these dire circumstances. Not only do these coal and nuclear plants provide jobs and economic opportunities for my community, they also generate significant tax revenues that benefit the municipal entities throughout my region. These entities provide essential services to the community such as education, fire protection and police. If these generation facilities are forced to retire, an already weak recovery will be hampered, more people will lose their jobs, municipal 4 services will deteriorate, and more families will suffer economic pain and burdens. The impact on the region's economy will be severe. B. Resilient Nuclear Power Plants Support Reliability In addition to helping to avert an economic catastrophe, the issuance of a rule preserving the continued operation of resilient baseload nuclear power plants will maintain a reliable supply of electricity for the region's energy-intensive economy in two ways. First, the preservation of certain plants will avoid the need to replace lost generation with imports and the associated construction of infrastructure to facilitate such importation (costs which are born fully by the customer). Preserving baseload nuclear power plants will keep these needed, reliable facilities running close to home without the need to depend on distant resources, particularly during catastrophic events like severe storms, to fulfill our region's dynamic need for reliable electricity. Second, premature plant closures will deplete the stable of highly skilled (and specifically trained and experienced) employees, many of whom have lived in the region for several years and who take great pride in their work. With a depletion of this skilled and experienced group of workers, and the possible replacement of these workers with more distant and perhaps less-skilled individuals, utilities will see a direct and adverse impact on their ability to maintain the generation facilities that continue to operate and, as important, their ability to respond promptly to severe contingencies affecting the operation of these remaining plants in operation. In short, allowing baseload nuclear power plants to close prematurely will have an adverse impact on the reliability of the region's electricity supply and on the reliable operation of the regional electricity system. C. The Proposed Rule Will Preserve the Environmental Benefits of Zero-Emission Nuclear Power Plants In addition to providing a dependable source of electricity and critical economic support, nuclear-fueled generating stations are beneficial to the environment. The reliance on nuclear 5 generation capacity prevents the emission of hundreds of millions of tons of greenhouse gases such as carbon dioxide, sulfur dioxide, and nitrous oxide that might otherwise be produced if natural gas-fired and coal-fired generation was used instead to maintain the reliability of the interstate power grid. Operators of other types of emission-free generating facilities, such as wind and solarpowered facilities, receive substantial financial support through production tax credits and compensation for renewable energy credits that is not available to most nuclear-fueled generators. Although both New York and Illinois have recognized the environmental benefits to be derived from continued reliance on nuclear-fueled generating facilities, and provide financial support to maintain operation of those generation facilities in their states through the sale of Zero Emission Credits, the State of Ohio has not yet established a similar means of compensating nuclear power plants for their environmental attributes. This is an opportune time for the FERC to implement a policy that adequately values baseload electricity generation with a minimum of 90-days onsite fuel as more states look to bring out-of-market subsidies into the overall pricing equation. The Proposal for the FERC to require operators of organized markets to compensate owners of nuclearpowered generating stations fully for the costs of owning and operating their generation facilities would put all such emission-free, reliable and resilient generating stations on an even footing and help to protect the bulk power supply system from disruptions. D. The Commission Must Act Posthaste to Prevent the Premature Retirement of Resilient Baseload Nuclear Power Plants In order to mitigate the risk that such generating units may be deactivated prematurely, I strongly urge FERC to adopt the rule proposed by the DOE as 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 6 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 baseload power plants. Any protracted delay in creating fully compensatory market rules will only exacerbate the problem of pre-mature 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 much-needed power plants. Respectfully submitted, Jamie N. Beier Grant Director Ottawa County Improvement Corporation 7 FE RC eLibrary (formerly a4?- raggov uv E-ma 'l lnis gage File List Accession Number: 20111023-0921 F'aasar'ts County Development Authority comments re he proposed Grid Resiliency Prio' n9 Ru 5 under Rum-1. Type File Name Size Gen eratec' PDF ?25] 3335115?: 151712 Range From To ?ll hone mg ?2-39 rig 22445 2142? mg 2.320 Pa 5 Pa e3 Dc: l'fo Adc 1c -lec:..est Ursa?Lead lZeset Funny Issues ramming FERG OnllnE. plasma WEB-36M. Midwaammallmuaphmammam?addm. 20171023-0021 FERC PDF (Unofficial) 10/23/2017 I'LEASANTS g,+C O U N T y WVW% MDI c It Your FuLurc PLEASANTS COUNTY DEVELOPMENT AUTHORITY PO. Box eey eos.e84.1 trit 309 Second Street St, Marys, V/V I ax: ere.ese.rzess yetye EmaiL rcda@frontierNet.net October 17, 2017 IatNN, pe Federal Energy Regulation Commission &R ATTN: Kimberly Bose, Secretary 888 First Street NE g&reI C,CD~ l% .CD Washington, DC 20426 Dear Ms. Bose, Enclosed are the comments of the Pleasants County Development AuthodIty the proposed Grid Resiliency Pricing Rule, FERC Docket No. RM18-1-000. Thank you. Sincerely, ('LL(td IftrrItott Carl A. Guthrie Executive Director Pleasants County Development 304.684.1220 peda @frontiemet.net Authority regarding 20171023-0021 FERC PDF (Unofficial) 10/23/2017 t'LEASANTS g..+C O 'w 'm 'm % o'eve% Marte It Your Futu re PLEASANTS COLINTY DEVELOPMI.NT ALITHORITY BO. Box 333 3oeeee.ieeo 309 Second Street St. Mao, VVV Fax: 3Ce.eee.leee eeteo Email: peda@I'rontierNeonet. October 17, 2017 Federal Energy Regulatory Commission Secretary of the Commission 888 First Street, NE Washington, DC 20426 Re: Grid Resiliencv Pricina Rule FERC Docket No. RM18-1-000 COMMENTS OF THE PLEASANTS COUNTY DEVELOPMENT AUTHORITY 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 adopt a rule requiring resiliency attributes operators of electric by the regulatory language of organized ("FERC")to markets to "ensure that certain reliability generation sources are fully valued." Such a rule, as contemplated of the Proposal, will ensure that existing nuclear and coal-fired electric generating stations in Pleasants County, West Virginia will be compensated appropriately for their costs of operation and will avoid premature sustain the long-term viability of critical power retirement. Adoption of that the region. and fully rule will thus plants, preserve and create jobs, maintain electric reliability, and provide substantial economic benefits to the many hard-working throughout and Americans living 20171023-0021 FERC PDF (Unofficial) 10/23/2017 The Pleasants County Development and shares the Secretary's ("PCDA") strongly supports the Proposal Authority urgency that FERC act promptly to direct opemtors 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 the loss of critical economic and reliability benefits. Without these critical units, Pleasants County Development Authority will be challenged to support the health, education and financial stability of our community. 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 the proper compensation of critical of rules, based on the regulatory language power plants. Protracted proceedings undertaken market operators that fail to develop fair, compensatory market uncertainty and delay in providing jeopardizing the operation L of the of the and transparent sufficient compensation Proposal, for by organized rules will only engender to these facilities, thereby very plants that the DOE seeks to maintain in operation. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Carl A. Guthrie Executive Director Pleasants County Development Authority 304.684.1220 ncdalRfrontiernet.net 20171023-0021 FERC PDF (Unofficial) 10/23/2017 DESCRIPTION OF PLEASANTS COUNTY DEVELOPMENT H. AUTHORITY The Authority was formed in 1988 shortly after the Quaker State Refinery announced the closure of the local plant. Our mission is to increase job opportunities for our local workforce as well as increase the tax base for our county which will improve the quality IH. of life for all our citizens. DESCRIPTION OF PLEASANTS COUNTY DEVELOPMENT AUTHORITY'S INTEREST IN PROCEEDING The Pleasants County Development West Virginia. Our organization person in our community. Authority is a non-profit entity located in Pleasants County, advances the health, education and financial stability The continued operation translates into safer and more prosperous of the communities. baseload coal and nuclear power plants Thus, the PCDA members have a direct interest in this proceeding. As well, the unique perspective and substantial of every of the PCDA 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 recent decline in Northern opportunities the power plants provide. Ohio River Valley electric power industry, reductions in operations at numerous power pmduction and manufacturing The for example, has led to facilities across West Virginia. This continued decline will impact PCDA's ability to bring positive impacts to the Over 7,500 residents in the region, including support for the health, education and financial stability of our communities. 20171023-0021 FERC PDF (Unofficial) 10/23/2017 Baseload coal and nuclear plants in West Virginia provide economic opportunities community. The First Energy/Pleasants Power Station not only employs 640 individuals, to our but also contributes over $5 million dollars in county tax revenue which supports education and other vital services for our residents. The loss throughout of jobs, tax revenue, and the ripple effect the local economy, will have a severely detrimental The issuance of a rule preserving economy in two ways. First, the preservation generation importation. with imports and the associated of resilient baseload coal of electricity for the region's of certain such losses impact on the region. the continued operation nuclear power plants will maintain a reliable supply of and energy-intensive plants will avoid the need to replace lost construction of infrastructure to facilitate such 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 catastmphic events like severe storms, to fulfill our region's dynamic need for reliable electricity. Second, premature plant closures will deplete the stable trained and experienced) employees, many of whom individuals, of these of this skilled and experienced group of workers with more distant and perhaps less-skilled we will see a direct and adverse impact on our ability to provide services to our of of jobs, community. Because governments, and the decline in electricity resource and grid reliability deactivation skilled (and specifically have lived in the region for several years and who take great pride in their work. With a depletion workers, and the possible replacement of highly of the the loss the significant nuclear and coal-fired generating reduction in payments to local that would result from facilities in the Ohio River Valley, 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. 20171023-0021 FERC PDF (Unofficial) 10/23/2017 In order to mitigate the risk that such generating units may be deactivated prematurely, FERC to adopt the rule proposed the PCDA strongly urges comprehensively as possible. FERC has a sufficient record to act that will be further bolstered by the comments considered of the DOE, FERC has thoroughly in this proceeding. electric markets on the sustained operation by the DOE as promptly of at-risk power considered the impact and of plants and, as noted by the Secretary the time to act is now given the severe impacts to system reliability and resilience, and national security, attendant to the premature delay in creating fully compensatory closure of crucial power plants. Any protracted market rules will only exacerbate the problem of pre-mature closutes. In acting promptly, FERC should also direct the organized market operators to issue a rule that is not only compensatory comprehensive and enduring. The rules to be issued by operators fair and transparent, long-term (and based on the regulatory of of organized the Proposal) but markets should be and should ensure that critical power plants can continue to operate for the and without the prospect compensation. language The uncertainty of repeated re-examination that less than comprehensive engender will defeat the very purpose of preserving and adjustment and enduring the extended operation 4$UXtL market rules will of these power plants. ('QlL to their market Carl A. Guthrie Executive Director Pleasants County Development Authority much-needed 20171023-0021 FERC PDF (Unofficial) 10/23/2017 Document Content(s) 14721060.tif..........................................................1-6 FE RC 0 7? WE eLibrary (formerly FERRIS) 9 . A - zb?wwjerog E-ma 1 his gage File List Accesslon Number: 201110235041 Comment of CLEVELAND BRANCH NAACP .Jndel RM1E-1. Type Flle Name SIZE rs icroSo?I We'd e'eelawc: Brarm NAACP FERC 27979 Co"me1ts Basket RMI DOCK No cess?ipior' given FERC Generate: PDF 173-3 'Jcc I'fo mic: 1c 42:: .?est Lima-Load Ileset FellingI Issues milling FERG OnllnE. plasma mummgosu ass-ma?a. October 20, 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 CLEVELAND BRANCH NAACP 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. The Cleveland Branch NAACP ("Cleveland NAACP") 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 the loss of critical economic and reliability benefits. Without these critical units, Cleveland NAACP will be challenged to support the economic, social, educational and political rights of all persons in our community. 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: Danielle L. Sydnor Chair Economic Development Committee Cleveland Branch NAACP 16400 Miles Ave. 216-231-6260 sydnordanielle@gmail.com II. DESCRIPTION OF CLEVELAND BRANCH NAACP The mission of the National Association for the Advancement of Colored People is to ensure the political, educational, social, and economic equality of rights of all persons and to eliminate race based discrimination. III. DESCRIPTION OF CLEVELAND BRANCH NAACP'S INTEREST IN PROCEEDING The Cleveland Branch NAACP is a non-profit, 501(c)(4), entity located in Ohio. Our focus is on improving the social welfare of the community by ensuring the economic, social, educational and political rights of all persons. The continued operation of the baseload coal and nuclear power plants translates into safer and more prosperous communities. Thus, the Cleveland NAACP members have a direct and substantial interest in this proceeding. As well, the unique perspective of the Cleveland NAACP 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 at numerous power production and manufacturing facilities across Ohio. This continued decline will impact Cleveland NAACP's ability to bring positive impacts to the many residents in the region, including support for the health, education and financial stability of our communities. Baseload coal and nuclear plants in Ohio provide economic opportunities to our community. First Energy contributes $25,000 each year to our organization, and also supports other organizations like the United Way, Salvation Army, Habitat for Humanity and Red Cross. This financial support allows us to continue providing voter education and registration efforts, financial literacy, and health and wellness initiates to the community. 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 provide services to our community. 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, the Cleveland NAACP 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 pre-mature 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, Danielle L. Sydnor Chair Economic Development Committee Cleveland Branch NAACP eLibrary (formerly.r FERRIS) .49. d: v1. aim E-"na his gage File List ACCESSION Number: 201710235152 Comment of Leadership Ashlabula Counly under Rh?13-1. Type Flle Name 5le L?icraS-oft 'u?Jo'd LEAD Estig Ask-lat-Jla Dov-meats FEDOCX 32232 No script or given FERC Gen eratec? PDF 15391 Dec I'fo Ade 1c -J.ec:..est Danni?Luau lie-set Help Flal'lmz.I lawns FERG Onllna. plasma ass-ma?a. October 20, 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 LEADERship Ashtabula County 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 Northeast 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 benefits to the many hard-working Americans living throughout the region. LEADERship Ashtabula County 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 the loss of critical economic and reliability benefits. Without these critical units, LEADERship Ashtabula County will be challenged to support the health, education and financial stability of our community. 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: Laura E. Jones Executive Director Leadership Ashtabula County PO Box 643 Ashtabula, OH 44005 440-813-9053 laura@leadershipac.org II. DESCRIPTION OF LEADERship Ashtabula County Community LEADERship and Educational Organization III. DESCRIPTION OF LEADERship Ashtabula County's INTEREST IN PROCEEDING LEADERship Ashtabula County is a non-profit entity located in Ashtabula, Ohio. Our organization advances the health, education and financial stability of every person in our community. The continued operation of the baseload coal and nuclear power plants translates into safer and more prosperous communities. Thus, the LEADERship Ashtabula County members have a direct and substantial interest in this proceeding. As well, the unique perspective of LEADERship Ashtabula County 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 at numerous power production and manufacturing facilities across Northeast Ohio. This continued decline will impact LEADERship Ashtabula County's ability to bring positive impacts to the Northeast Ohio residents in the region, including support for the health, education and financial stability of our communities. Baseload coal and nuclear plants in Northeast Ohio provide economic opportunities to our community. For example, FirstEnergy contributes dollars each year to our organization that supports services provided to our communities, including entrepreneurship programs for youth, leadership programs for hundreds of high school students, community programing, Leadership development for our corporate and nonprofit, government and educational leaders. 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 provide services to our community. 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 Northeast 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, LEADERship Ashtabula County 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 pre-mature 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, Laura Jones Executive Director LEADERship Ashtabula County FE RC ?1 ll "1 eLibrery {fermerly rm: ?y n: 9:31.: E-n'nail this gage File List Number: 2e1e1e1 9-5932 Desurlptign: Eemrne-nte el Area Chamber of Commerce eneler [Errenee-uelj.r ?led: Type Flle Heme Elze ?uet Er ere'y FERE Ni:- er' gin-en FE Fill [Fen ereteci 213mg iJec I'fe Fade 1e Help lumen FEED mllne. mummum 10/24/2017 error You don't have permission to access this document. This document (eLibrary accession no. 20171017-5082) is Privileged. The public may file a FOIA request under 18 C.F.R. 388.108. https://elibrary.ferc.gov/idmws/common/FN_error.asp?flag=18&fileNetID=32462021&pageNumber=&AccNum=20171017%2D5082 1/1 FE RC ?1 ll "1 eLibrery {fermerly rm: ?y n: 9:31.: E-n'nail this gage File List Number: 291?1023-5153 Desurlptign: Eemrne-nt of Pleasente Area Chamber Elf Commerce under Type Flle Heme Elze FEHC Ni:- gin-en FE Fill [Fen erateci Dec I'fe Fade 1e Umn-?Leed Help lumen FEED mllne. Fianna mummum 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 PLEASANTS AREA CHAMBER OF COMMERCE IN SUPPORT OF THE PROPOSED RESILIENCY RULE On September 28, 2017, the Department of Energy ("DOE") issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to "ensure that certain reliability and resiliency attributes of electric generation sources are fully valued." Such a rule, as contemplated by the regulatory language of the Proposal, will ensure that existing nuclear and coal-fired electric generating stations in West Virginia will be compensated 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. The Pleasants Area Chamber of Commerce 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 the loss of critical economic and reliability benefits. Without these critical units, we believe First Energy will be challenged to support the health, education and financial stability of our community. 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: Jody Murphy Executive Director Pleasants Area Chamber of Commerce 309 Second St. St. Marys, WV 26170 304-684-9909 pleasantschamber@frontiernet.net II. Description of Pleasants Area Chamber of Commerce The Pleasants Chamber is a 501(c)3 organization devoted to the promotion, growth and development of the Pleasants Area business community and climate. III. Description of Pleasants Area Chamber of Commerce's Interest in Proceeding The Pleasants Chamber is a non-profit entity located in Pleasants County, West Virginia. Our organization advances the health, education and financial stability of every person in our community. To that end, we remain keenly vigilant on legislation and policies that may have a negative effect on our coal-fired Pleasants Power Station; a station that employs more than 240 people. This plant is one of the largest private employers in our county. The continued operation of the baseload coal and nuclear power plants translates into safer and more prosperous communities. Thus, our Chamber, our community has a direct and substantial interest in this proceeding. As well, the unique perspective of the Pleasants Chamber 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 West Virginia electric power industry, for example, has led to reductions in operations at numerous power production and manufacturing facilities across our state and region - effecting both West Virginia and Ohio. This continued decline will impact the Pleasants Chamber's ability to bring positive impacts to our members and residents in the region, including support for the health, education and financial stability of our communities. Baseload coal and nuclear plants in West Virginia provide economic opportunities to our community. Again, our coal-fired plant is one of the largest private employers in the county, paying millions in taxes and supporting an array of community and charitable causes. 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 provide services to our community. 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 the Mid-Ohio Valley 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 Pleasants Chamber 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 pre-mature 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, Jody Murphy Executive Director Pleasants Area Chamber of Commerce FE RC ?1 ll "1 Human; {farmerly rm: ?y n: 9:31.: E-n'nail this gage File List Number: Desurlptign: Ja?arEc-n Col; Tn-wnahip- Assn-cialjnn under Type Flle Name Elze JeHerac-n CEILIFIW Ass-aciatic-PIFDF 135315 ciescripi gin-en FE Fill [Fe-n Hated FEE-F 161650 iJ-zn: I'fzu Pd: Uta-ruled Ileana-t Help October 18, 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 FROM THE JEFFERSON COUNTY (OHIO) TOWNSHIP ASSOCIATION IN SUPPORT OF THE PROPOSED RESILIENCY RULE I have been representing the Jefferson County Township Association (JCTA) for the last 17 years. In that time, I have seen dramatic changes in the economy of Jefferson County. The recession of 2001 had a devastating effect on residents and the area is still lagging behind as reflected in the August 2017 Jefferson County unemployment rate of 7.0, significantly behind the 5.4 Ohio and the 4.3 US rates. Understanding that all portions of the state are not equally well off, the important connection between the strength of a region's economy and the need for a robust and reliable electricity grid to maintain that economy and help it grow is critical. Now, more than ever, it is essential that all available steps be taken to ensure that Jefferson County's economy and electrical grid are sufficient to withstand any catastrophic interruption to the electrical network. It is with this background that I write with a sense of urgency to address a recent proposal issued by the Department of Energy ("DOE") that most of my constituents and I whole-heartedly support. On September 28, 2017, the DOE issued the "Grid Resiliency Pricing Rule" (the "Proposal") directing the Federal Energy Regulatory Commission ("FERC") to adopt a rule requiring operators of organized markets to "ensure that certain reliability and resiliency attributes of electric generation 1 Submitted by: Terry Bell, VP-JCTA; 740.317.5693; ram2k@frontier.com 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, including those in Jefferson County will be compensated appropriately and fully for their costs of operation and will avoid premature retirement. Adoption of that rule will: 1. Sustain the regional economy 2. Enhance reliability and resiliency of the electric grid 3. Assist in reducing harmful emissions The rule adoption would avert the premature closing and financial distress caused by the closing of the W. H. Sammis Plant, in the Southeastern Region of Ohio and primarily Jefferson County, if the Proposal is not adopted. Hence, I strongly support the Proposal and share the Secretary's urgency that FERC act promptly to direct operators of organized markets to issue the requested rule. FERC 1. Must act now 2. Should issue a comprehensive and enduring set of rules for the proper compensation of critical power plants Delaying proceedings will put at risk the plants that the DOE seeks to maintain and keep in operation. I. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following person: Terry Bell Vice President Jefferson County Township Association 1060 County Highway 54 Richmond, Ohio 43944 2 Submitted by: Terry Bell, VP-JCTA; 740.317.5693; ram2k@frontier.com 740.317.5693 C ram2k@frontier.com II. DESCRIPTION OF JEFFERSON COUNTY TOWNSHIP ASSOCIATION AND INTEREST IN PROCEEDING Terry Bell, Vice President JCTA, is an appointed official in Jefferson County representing 14 townships and is responsible for 1. Working as part of a leadership team consisting of JCTA Officers 2. Providing information to JCTA officers and trustees on local / state issues 3. Presenting testimony to state legislators on behalf of JCTA officers and trustees 4. Promoting issues related to JCTA and townships through print / visual media The W. H. Sammis Power Plant, owned by FirstEnergy Corporation, is located in my district, and provides 400 direct, 140 FTE indirect construction jobs. Through the multiplier effect, an additional 520 jobs are generated for residents of Jefferson and surrounding counties in the tristate area, as well as $5.5 million dollars in tax revenues that support local governments (2014). The premature retirement of W. H. Sammis Power Plant due to the failure of wholesale power markets in valuing key attributes, such as resiliency, will have a direct impact on jobs and the tax base in the community I represent. Therefore, in my official capacity as JCTA Vice President, the 14 townships and I have a direct and substantial interest in this proceeding. III. COMMENTS A. The Premature Retirement of W. H. Sammis Power Plant Will Have a Significant Economic Impact in Jefferson County 3 Submitted by: Terry Bell, VP-JCTA; 740.317.5693; ram2k@frontier.com Operations at the W. H. Sammis Power Plant directly and indirectly support an estimated 1,100 jobs. Economic implications for a negative relationship between job losses and per capita income is high for residents and those who work for companies that supply an array of goods and services to the generation facilities that are at risk of closure. The 2014 dollar value of the economic impact W. H. Sammis Power Plant on the regional economy in Ohio, West Virginia and Pennsylvania is 1. $585.62 million dollars-annual economic impact on tristate area 2. $45.9 million dollars-annual income for direct / indirect employees in the tristate area 3. $5.5 million dollars-property, sales and income tax revenues / tristate area It is no secret that the economy of Jefferson County and Eastern Ohio has struggled for many years. Should FERC delay action on adopting the "Grid Resiliency Pricing Rule" (the "Proposal"), the stage would be set for an economic catastrophe for my constituents directly affected by the closure of these plants. Simply put, the lost jobs caused by closure of the W. H. Sammis Power Plant will weaken the local economy and will cause a ripple effect for the remaining manufacturing jobs in Jefferson County. For example, the recent decline in the electric power industry has led to reductions in operations, lost jobs, decreased tax revenues and decreased capital improvement expenditures at numerous power production and manufacturing facilities across Jefferson County, West Virginia and Pennsylvania. This has led to extreme financial hardship for the 66,704 residents and families in Jefferson County including my constituents directly or indirectly employed in this industry. It is imperative that W. H. Sammis Power Plant, a baseload coal plant, continues to operate in light of these dire circumstances. Not only does this coal and other plants provide jobs and economic opportunities for my constituents, they provide a tax base that supports education, fire protection and police. If the "Sammis" facility is forced to retire, the per capita income of the county will decrease, 4 Submitted by: Terry Bell, VP-JCTA; 740.317.5693; ram2k@frontier.com more people will lose their jobs, municipal services will deteriorate and more families will suffer economic pain and burdens. The impact of the closing of W. H. Sammis Power Plant on the region's economy would be severe. B. Resilient W. H. Sammis Power Plant Power Plants Support Reliability In addition to helping to avert an economic catastrophe, the issuance of a rule preserving the continued operation of resilient baseload coal power plants will maintain a reliable supply of electricity for the region's energy-intensive economy by: 1. Avoiding the need to replace lost generation with imports and having reliable facilities running close to home 2. Depleting the pool of highly skilled (and specifically trained and experienced) employees In short, allowing baseload coal power plants to close prematurely will have an adverse impact on the reliability of the region's workforce, electrical supply and on the reliable operation of the regional electricity system. C. The Proposed Rule Will Preserve the Environmental Benefits of Zero-Emission Nuclear Power Plants In addition to providing a dependable source of electricity and critical economic support, nuclear-fueled generating stations are beneficial to the environment. The reliance on nuclear generation capacity prevents the emission of hundreds of millions of tons of greenhouse gases such as carbon dioxide, sulfur dioxide, and nitrous oxide that might otherwise be produced if natural gas-fired and coal-fired generation was used instead to maintain the reliability of the interstate power grid. Operators of other types of emission-free generating facilities, such as wind and solar-powered facilities, receive substantial financial support through production tax credits and compensation for renewable energy credits that is not available to most nuclear-fueled generators. Although both New 5 Submitted by: Terry Bell, VP-JCTA; 740.317.5693; ram2k@frontier.com York and Illinois have recognized the environmental benefits to be derived from continued reliance on nuclear-fueled generating facilities, and provide financial support to maintain operation of those generation facilities in their states through the sale of Zero Emission Credits, the State of Ohio has not yet established a similar means of compensating nuclear power plants for their environmental attributes. The Proposal for the FERC to require operators of organized markets to compensate owners of nuclear-powered generating stations fully for the costs of owning and operating their generation facilities would put all such emission-free generating stations on an even footing. More importantly, it would recognize the value of the reliability and resiliency attributes of nuclear-fueled generating stations that help to protect the bulk power supply system from disruptions. D. The Commission Must Act Posthaste to Prevent the Premature Retirement of Resilient Baseload Coal Power Plants In order to mitigate the risk that such generating units may be deactivated prematurely, I strongly urge FERC to adopt the rule proposed by the DOE as promptly and comprehensively as possible. FERC has a sufficient record to act that will be further reinforced 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, 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 6 Submitted by: Terry Bell, VP-JCTA; 740.317.5693; ram2k@frontier.com 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. What isn't considered in the effect of FERC's inactivity provided in sections C. & D. and what MUST be considered is the very real and extensive human aftermath that will result in the severe economic hardships for the residents of Jefferson County and Eastern Ohio. Respectfully submitted, Terry Bell Vice President Jefferson County Township Association 7 Submitted by: Terry Bell, VP-JCTA; 740.317.5693; ram2k@frontier.com