From: Jon McKinney Sent: Tuesday, July 30, 2019 4:55 PM Subject: Letterto FERC Good afternoon, We?re working to urge FERC to act on an issue that is important to the nation?s coal and nuclear fleets and to the electricity grid. Some 19 months ago, FERC opened a resilience docket titled "Grid Reliability and Resilience Pricing and Grid Resilience in Regional Transmission Organizations and Independent System Operators? but has done very little since then with regard to the docket. We believe that fuel security provided by the coal and nuclear fleets will make the grid more resilient, but coal and nuclear retirements continue to mount while we wait for FERC to act on the docket. Given the importance of public utility commissioners, we hope that you and other commissioners will send a letter to FERC requesting that the Commission make a decision and issue an order as expeditiously as possible with regards to the resilience docket. The attached sample letter provides additional information. The letter does not tell FERC what to do, other than make a decision and issue an order. We would appreciate your willingness to send a letter quickly. Please let me know if you plan to send a letter. If you have any questions or concerns, you can call or email me. Jon McKinney WV Commissioner Emeritus 304-561-8647 From: McCabe, Brooks Sample Commissioners DRAFT to FERC July 2019 The Honorable Neil Chatterjee Chairman Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Dear Mr. Chairman: I am/We are writing to request that FERC make a decision and issue an order in an expeditious manner for the docket titled Grid Reliability and Resilience Pricing and Grid Resilience in Regional Transmission Organizations and independent System Operators Grid Reliability and Resilience Docket?) that FERC opened almost 19 months ago.i FERC opened this docket to examine reliability and resilience on January 8, 2018. noting that it ?must remain vigilant with respect to resilience challenges, because affordable and reliable electricity is vital to the country?s economic and national security". As part of the proceeding, FERC directed to respond to a series of questions regarding resilience. On March 8, 2018, FERC issued an order granting further time to consider responses to those questions, as well as other stakeholder comments.ii In the meantime, substantial baseload retirements, especially coal-fired units, and the evolution of the electric power sector are bringing increased attention to grid resilience and fuel security. Nationwide, 40 percent (126,000 megawatts of the nation?s coal ?eet has retired or announced plans to By the end of 2020, some 67,000 MW of coal-fired generating capacity in footprints will have retired.? This total includes more than 10,000 MW that have announced intentions to retire this year and in 2020.v The four regions with the most coal retirements through 2020 are PJM (36,200 MW), MISO (14,800 MW), ERCOT (5,800 MW) and SPP (5,000 In addition, 20 percent of nuclear units (21 of 105) have retired or announced plans to retire by 2030, amounting to over 17,000 MW of capacity. While we appreciate the Commission?s efforts to examine challenges related to the reliability and resilience of the bulk power system, we are not aware of any further action, other than soliciting comments, the Commission has taken with respect to the 19-month old Reliability and Resilience Docket. Request /We request that FERC makes a decision on the docket and issue an order in a timely manner. If you have any questions, please contact or Sincerely, CC: Commissioner Cheryl A. LaFleur Commissioner Richard Glick Commissioner Bernard L. McNamee i Order Terminating Rulemaking Proceeding, initiating New Proceeding, and Establishing Additional Procedures, Grid Resilience in Regional Transmission Organizations and Independent System Operators, 162 FERC 1] 61,012 (2018). ii Order Granting Rehearing for Further Consideration, Docket No. RM18?1-oo1 and AD18-7-oo1 (2018). i" America?s Power, Retirements of Coal-Fired Electric Generating Units as of June 30, 2019, lbid. lbid. lbid. Global Market Intelligence generating unit database, queried July 29, 2019. From: Jon McKinney Sent: Wednesday, August 07, 2019 10:57 AM To: Lane, Charlotte Subject: Meeting on August 14th Hi. This is to confirm our meeting with you at ~4:00 on August 14th at the PSC offices. Michelle Bloodworth CEO of America's Power and Paul Bailey Chief Policy Officer of America's Power will be attending with me. We have meetings with Austin Caperton at 1:30 and with Mike Hall/Bray Cary at 3:00. The purpose of the meeting is to introduce you to Michelle and Paul, discuss email i sent asking you to request FERC to make a decision on the open resilience docket, discuss West Virginia being a early mover on the new Affordable Clean Energy rule and to provided information related to ACE and a study on levelized cost of electricity. You are welcome to invite whomever you want from your staff. America's Power is the only national trade organization whose sole mission is to advocate at the federal and state level on behalf of coal-fueled electricity and the coal fleet. Membership is comprised of electricity generators (AEP), coal producers, railroads, barge operators, and equipment manufacturers involved in generating electricity from coal. Good to talk to you again and look fon/vard to seeing you. Jon McKinney 304-561-8647 From: Lane, Charlotte Sent: Wednesday, August 7, 2019 12:25 PM To: Jon McKinney Subject: RE: Meeting on August 14th Thank you?looking forward to seeing you next week From: Jon McKinney Sent: Wednesday, August 07, 2019 10:57 AM To: Lane, Charlotte Subject: Meeting on August 14th Hi. This is to confirm our meeting with you at on August 14th at the PSC offices. Michelle Bloodworth CEO of America's Power and Paul Bailey Chief Policy Officer of America's Power will be attending with me. We have meetings with Austin Caperton at 1:30 and with Mike Hall/Bray Cary at 3:00. The purpose of the meeting is to introduce you to Michelle and Paul, discuss email sent asking you to request FERC to make a decision on the open resilience docket, discuss West Virginia being a early mover on the new Affordable Clean Energy rule and to provided information related to ACE and a study on levelized cost of electricity. You are welcome to invite whomever you want from your staff. America's Power is the only national trade organization whose sole mission is to advocate at the federal and state level on behalf of coal-fueled electricity and the coal fleet. Membership is comprised of electricity generators (AEP), coal producers, railroads, barge operators, and equipment manufacturers involved in generating electricity from coal. Good to talk to you again and look forward to seeing you. Jon McKinney 304-561 -8647 From: Jon McKinney Sent: Monday, August 26, 2019 5:48 PM To: Lane, Charlotte Subject: Re: Letter to FERC requesting that they move Docket AD18-7 to a high priority Thank you. Jon Sent from my iPhone On Aug 26, 2019, at 5:15 PM, Lane, Charlotte wrote: This Letter went out today. From: Lane, Cha rlotte Sent: Monday, August 26, 2019 5:16 PM To: Jon McKinney Subject: FW: Letter to FERC requesting that they move Docket to a high priority Attachments: to FERC requesting that they move Docket to a high priority.pdf This Letter went out today. public Service Commisson of West Virginia Chariotte Ra. Lorre Chairman 201 Brooks Street, RD. Box 312 Charleston West Virginia 25323 Auguat 26, 2019 The Honorable Neil Chaiterjee, C?l-iairmah The Honorable Cheryl A. LaFleur: Commissioner The Honorable Richard Gliek, Commissioner The ?li-lonorable Bernard L. MoNamee, Commissioner Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Re: ?Request that PIERCE move Docket 8-7 to a high priority Dear Commissioners: The Public Service Commission of West Virginia (PSC WV) is acutely aware of the importance of reliability and resilience of electricity supply. We are also aware of the pressures on the FERC emanating from your efforts to rely on a workably power supply market while also assuring a reliable and resilient mix of generation resources. You are faced with the unenviable task of, on one hand, :l?ostering a competitive market by allowing it to work ouiside the. historical regulatory oversight model while, on the other hand, assuring a reliable, always~availablei wholesale electricity supply. "if the market was truly competitive, individual supply-aide participants should operate free- of regulatory mandates and bear the resultsa positive or negative from the market reoponse to their decisions. But the need for reliability and resilience of power supply is too critical to the public health and welfare, and to the US. economy, to simply sit back and let the market determine the reliability and resilience it wishes to offer. In September 20l7, the Secretary of Energy suggested a Rulemahing that would address resilience from the standpoint of on-site fuel supply. We understand that the FERG did not believe that the proposed Rulemaking was the appropriate proceeding for considering the resilience of power supply related to (in-site fuel supplies. Instead. FERC opened docket 8?7 to ?holistically examine the resilience oli?thc. bulk power system.? The had hoped for a more immediate ruling focused on line] security that would have assured the preservation of a reasonable balance between the FERC-preferred Telephone: (3011} 3120-0305 Federal Energy Regulatory Commission August 26, 2019 Page 2 approach and an approach that would require or encourage the level of fuel-secure power supply that is necessary to meet the public interest. But, we understood the problems liaising the FERC and hoped that there could be :1 quick turnaround in ALD18-7, at least with regard to the resilience aspect of a secure, ion-site generation fuel supply. it has been nearly two years since the Secretary of Energy submitted a Notice of Proposed Rnlema-king to FERC and twenty months sine-c ALD18-7 was initiated in January 2018. From the initiation of to around July 2018, there were numerous responses to the questions posed by FERC and reply comments to these responses. Since July 2018, however, there has been little activity in the Docket other than a few motions to update information of parties. While we await further action in ADI 8-7, fuel-secure electric generating facilities that; have on-site fuel stockpiles providing months of generation capability continue to be retired. Front 2010 to 2017g leading up to the Secretary ol?linergy Proposed Rnlemaking, approximately 53,000 Megawatts (MW) of coal-?red capacity were retired. For the period 2018 through 2025, actual and planned retirements total another 32,000 MW. Most of the individual generation units retired from 3.1010 to 2017 were older, smaller units with an average age ofabout 55 years and. average unit capacity ofnbout 125 MW, More recent retirements are newer and much larger units. In 201. 8, the capacity of retired units was 350 with an average age of46 years.{ We are concerned that retirements of old, less ef?cient coal-?red units that some argue were so inef?cient that retirement was a given are over and we are now seeing premature retirements 01? more ef?cient super~critical units that should. have 10 to 15 years of remaining life. We are also concerned that, in addition to losses of fuel~secure coal??red plants! retirements of nuclear plants, which have even greater on-site lire! capability than most coal-fired plants, are slated to increase. From 2013 through 2018, approximately 5000 MW of nuclear capacity was retired. From 2019 through 2025. another 11,000 MW of nuclear capacity has been announced as retiring.2 I US. Energy lnl?onnation, July 9? 20l9, More LLS. Coal?Fired Power Plants are Decommissionintl as Retirements Continue. Web Article: accessed August 23., 2019 at - -- Phi-3213173931.: 2 US. Energy March 2019, Despitejllosuree us. Nuclear 83791;. Federal Energy Regulatory Commission August 26. 2019 Page 3 The does not believe that the possibility of fuel supply interruptions is so remote that it should not enter into your consideration of an appropriately resilient generation mix. We have had ?rst-hand experience with threats to generation capability due to Fuel supply interruptions. These fuel supply interruptions, some due to extreme weather conditions and some due to interruptions at the supplier level, sometimes lasted for several weeks or several months. They went largely unnoticed by the general public in this state because generation at the coal-tired power plants in West Virginia continued during these interruptions due to ample supplies of on-site fuel. While they have not occurred often, we are concerned that widespread. unexpected fuel interruptions could occur again and they could not be handled, even with implementation of demand-side responses, without inventories of on~site fuel supplies at a suf?cient number of power plants. We are writing to urge the .l?l'iRC to move and particularly consideration of Fuel supply security as it relates to resilience of our power supply markets, to a high priority and consider the need for mechanisms and market rules to assure not just a low-cost, but also a reliable, resilient, moi?secure power supply mix so that if future unexpected fuel supply interruptions occur, they will not result in an inability to maintain electric service at the level required for the public health and safety. Please feel free to contact me at the number or email address provided on In}: letterhead, or you may directly contact our advisori David Ellisi at 304?382-3836, dellispsginmuaiteom. if you or your staff have any questions or require any information from the perspective of a State Regulatory Commission charged by our State Legislature to, (among, other things, "assure the awailnbility of adequate, economical and reliable utility services throughout the state.? Thank you for your prompt consideration of our request. Respectfully, ?4km? Witt-M17 ?r a Charlotte R. 1.21116 Chairman The Honorable Jim Governor of West Virginia Brooks McCabe, in, Commissioner, Renee A. Larrick. Commissioner, David J. Ellis, Consultant