Daniel Hendrix
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Sign Our Comment to FERC
The Federal Energy Regulatory Commission (FERC) is seeking comments on its Proposed Policy Statement clarifying how the Commission will treat project-area wage standards in computing the labor cost component of jurisdictional cost-of-service rates. The draft policy statement is the results of more than 18 months of collaboration between FERC staff and LIUNA leadership and, if adopted, will create tremendous opportunities for pipeline contractors and unions to secure more and better jobs since they could receive full cost reimbursement for projects that are included in rates.
Help us voice support for this proposal that would help create good jobs for union craftsmen, thousands of whom are Local 798 members. Add your name to our comment below that we will submit to FERC before the comment period ends on December 26 -- We plan on preparing our submission on Thursday, December 21!
RE: Docket No. PL24-1-000; Project-Area Wage Standards in the Labor Cost Component of Cost-of-Service Rates
Dear Mr. Commissioners:
I am writing in response to the Commission's Notice of a Proposed Policy Statement clarifying how it will treat project-area wage standards in computing the labor cost component of jurisdictional cost-of-service rates. After review of the proposed sources of measurement, I believe the Commission should view collectively bargained rates as the only metric for project-area wages when an operator certifies the employment of union labor.
I applaud the Commission’s initiative to update the sources it will consider in determining project-area wage standards. I also share LIUNA’s primary concerns with using a “blended wage rate”, which is not a metric used in any other Government body or anywhere else within the construction industry, to determine cost reimbursements to operators. Of the four sources the Commission has proposed to accept, wage and fringe benefit rates in applicable collective bargaining agreements or project labor agreements are the most reliable source to determine local labor standards because these rates represent the compensation and benefit levels for the personnel actually performing the work.
Key reasons why I support collectively bargained rates as the only metric for project-area wages include:
- Collectively bargained rates reflect the wages and benefits skilled tradespeople actually receive on pipeline projects. Local 798 members, specifically, hone our craft over several years, which enables us to provide the highest quality service to pipeline operators. If an operator decides to use union labor, such as from our Local, the Commission can easily validate the exact wages and benefits.
- In the case of pipeline projects that span multiple states or years, collective bargaining agreements already have state-specific rates, and annual wage increases established, preventing the need for further clarification.
- The United Association is one of four signatories to the National Pipeline Agreement, which covers construction, installation, double jointing, rebeveling, treating, insulation, reconditioning, testing, relaying or relocation of cross-country pipelines or any segments thereof.
- Finally, it is important to remember that pipeline construction is highly specialized and involves much greater skill and training levels mandated by PHMSA. A “blended wage rate”, in particular, inherently ignores this fact and dis-incentivizes operators from using union contractors & the associated labor, denying our nation’s most dedicated and highly trained union craftsmen good jobs.
Due to the reasons discussed above, I strongly believe that collectively bargained rates should be the only metric for project-area wages when an operator certifies the employment of union labor. Further, the Commission should also only consider Davis-Bacon and state prevailing wages if they have been recently updated, and reflect actual wages workers received, such as collectively bargained rates. Along those same lines, construction cost models or databases should only be relied upon if the labor cost inputs are based on actual area wages and benefits, not national averages or averages for the general construction industry.
I appreciate the opportunity to make my voice heard on this issue, and I hope the Commission considers this comment as it discusses the sources of data it uses to determine project-area wage standards for the dedicated craftsmen that build and maintain our nation’s pipeline infrastructure.
Signed,
[Signers below]
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Sign Our Comment
Over the course of two weeks in September, we prepared submissions - with more than 2,300 comments - to the Illinois Commerce Commission (ICC) and Iowa Utilities Board (IUB), as they accepted public comments on permits for the Mt. Simon Hub project, a pipeline proposed by Wolf Carbon Solutions and Archer Daniels Midland Company that will stretch from eastern Iowa into Illinois. Specifically, the project is seeking from the Illinois Commerce Commission a "Certificate of Authority to Construct and Operate a Carbon Dioxide Pipeline and when Necessary to take Interests in Property as Provided by the Law of Eminent Domain"; and from the Iowa Utilities Board a Hazardous Liquid Pipeline permit.
Thank you to all who signed our comment for submission! If you signed after September 21, we may include your name in future submissions to state and federal regulators to support this project.
Dear Secretary:
On behalf of United Association of Journeymen and Apprentices of the Plumbing and Pipe Fitting Industry of the United States and Canada (UA) and our more than 300,000 members, I want to express our continued support for the Mt. Simon Hub and encourage a thorough review and timely approval of this important project. We believe that Wolf Carbon Solutions’ Mt. Simon Hub will be integral to job creation, environmental improvement and long-term economic growth of our region.
As a proud UA member, I am excited at the prospect of playing a central role in making this project a reality. With the potential to create more than 2,700 construction jobs, generate over $478 million in wages and salaries and to contribute upwards of $75 million in state and local taxes for our state, the Mt. Simon Hub presents an extraordinary economic opportunity both for our union members and Illinois and Iowa overall.
The hardworking men and women of the UA will bring their extensive construction experience to bear to ensure that the Mt. Simon Hub is built to rigorous specifications and in compliance with strict federal and state standards. At the UA, we adhere to our Standard of Excellence in every project we work on. This Standard is made up of three pillars: safety, quality and productivity, each of which are essential to making our laborers the best-trained and highly-skilled in the world. Furthermore, we boast a five-year apprenticeship program that was the first nationally registered program recognized by the Department of Labor in the United States.
With the possibility of major economic and environmental benefits, my fellow union members and I are excited by the opportunity that the Mt. Simon Hub presents, and we urge you to approve Wolf Carbon Solutions’ application. Thank you for your consideration.
Signed,
**By signing this petition, I agree to share my name on Pipeliners Local 798's submission to the Illinois Commerce Commission (RE: Docket No. 23-0475) and to the Iowa Utilities Board (Docket No. HLP-2022-0002)**
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Sign Our Petition to the Army Corps
The U.S. Army Corps of Engineers announced in March 2023 that it extended its environmental review of Enbridge Energy's Line 5 Straits Tunnel Project. The project's Environmental Impact Statement was previously set to be finished by late this year but now will be issued no earlier than Spring 2025.
While Local 798 members are supportive of a comprehensive permitting process that ensures opportunity for review and comment, we are disappointed with the extended timeline on this project's already thorough environmental impact analysis. Join us in sending a message to the Army Corps in support of a swift review so construction can finally move forward.
Dear Secretary:
I stand with Pipeliners Local 798 in expressing disappointment in the U.S. Army Corps's decision to extend its environmental review of Enbridge Energy's Line 5 Straits Tunnel Project. The permitting process for Line 5 already ensured extensive opportunity for review and comment, through which Enbridge repeatedly demonstrated a commitment to maintaining the highest level of safety and environmental responsibility.
Enbridge's proactive dedication to safety includes diligent 24/7 monitoring of the Straits crossing, regular inspections and operating the line at less than 25 percent of its maximum design capabilities to minimize stress on the pipeline steel and enhance safety. In November 2017, the company formally entered into an agreement with the state of Michigan outlining seven actions Enbridge was taking to protect the state’s water bodies within the project footprint. The following year, Enbridge announced another agreement with the state of Michigan that put in place enhanced inspection and operations protocols for the project. In the years that followed, Enbridge has continued to work closely with landowners, tribal leaders and safety experts to ensure the safest and most efficient pipeline operation.
There are several reasons why I believe the Line 5 Straits Tunnel Project deserves swift approval from the Army Corps and other decision makers, including:
- Enbridge has a proactive inspection program to monitor the fitness of Line 5, including evaluating the pipe’s interior inch by inch every five years using in-line inspection tools that provide detail on par with MRIs in the medical industry;
- All products that enter the pipeline are inspected and treated to prevent corrosion, and the system is operated at a low pressure to minimize stress on the pipe – all in an effort to protect the pipeline and the Straits;
- Over the past several years, Enbridge has paid tens of millions of dollars in property taxes in the state for its energy infrastructure projects, which has been invested in schools, roads and bridges and other important public services;
- The Line 5 Straits Tunnel Project will create good jobs for the local workforce, many of whom include Local 798 members.
The permitting process for Line 5 already ensured more than adequate opportunity for review and comment, through which Enbridge has demonstrated a clear plan with the project to help ensure an uninterrupted supply of reliable, affordable energy to Michigan and the region. This is why I ask the Army Corps to efficiently complete this review and approve necessary permits without any further delay.
Signed,
[Names Below]
**Local 798 may submit this petition to state and federal regulators and other decision makers to support Line 5.**
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Sign Our Comment to FERC
The Delta Lateral Project will expand natural gas capacity of Kern River Gas Transmission's existing transmission system in Utah while supporting good jobs for local craftsmen.
In December 2021, Local 798 submitted the below petition with 2,080 signatures to the Federal Energy Regulatory Commission regarding the project’s draft Environmental Impact Statement. In February 2022, FERC released the final DEIS. In anticipation of more public comment periods ahead, please sign this petition that we will submit to other regulators and decision makers in support of Delta Lateral.
Dear Secretary Bose:
I stand with Pipeliners Local 798 in support of Kern River Gas Transmission Company's Delta Lateral Project. This important project will enable Kern River to meet rising natural gas demands in the area and will support good jobs for local craftsmen, including Local 798 members.
In its draft EIS, FERC found the project’s environmental impacts would be reduced to “less-than-significant levels”due to the minimization and mitigation measures proposed by Kern River and recommended by the Commission. Project leaders remain committed to these mitigation efforts and continue to collaborate with stakeholders and environmental experts to develop the most responsible and efficient development plan. I see no reason to alter this review in the final EIS.
Overall, I support the Delta Lateral Project for the following reasons:
- Project leaders have consistently collaborated with stakeholders and environmental experts to ensure it meets or exceeds federal safety standards while developing the most efficient and responsible pipeline route;
- Delta Lateral is a critical part of the region’s energy infrastructure network and its carbon reduction strategy, as it is designed to provide firm transportation service for the Intermountain Power Project (IPP) in Utah, which is working towards installing gas-fired generating units capable of using hydrogen, and developing hydrogen production and long-term storage capabilities;
- Local 798 recognizes Kern River’s history of designing, constructing and operating safe and reliable pipeline systems. The company has demonstrated this same commitment with Delta Lateral.
Due to the reasons discussed above, I support the Delta Lateral Project and urge the swift approval of necessary permits.
Signed,
[Names below]
**Local 798 will submit this petition to state and federal regulators and other decision makers to support the Delta Lateral Project.**
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Pledge To Be An Energy Voter
With the right leadership and vision, we can ensure all Americans benefit from our nation’s emergence as an energy leader. It’s time to fulfill our bright energy future; it’s time to vote for candidates that support Local 798 jobs and the work that we do.
Join Local 798 by signing the petition and becoming an Energy Voter.
I understand the urgent need for clean, affordable and domestically sourced energy in my community, across my state and in throughout the nation. That is why I stand with political candidates and elected officials who show their support for an energy pipeline network that will safely and efficiently transport the nation’s abundant supply of domestic natural gas and oil supplies.
America is leading the world in oil and natural gas production. Working together, we can do even more. Producing, refining and transporting more domestic oil and natural gas will mean more abundant energy – and that means more affordable energy for American families and businesses.
We know there is enough potential domestic energy to serve all residential, business and industrial needs across the country. Yet, support for critical energy infrastructure is lacking among our political leaders.
To support my livelihood, my family and my community, I will enter the voting booth informed about how political leaders stand on the issue of energy infrastructure development. I will do my part to help elect leaders who recognize the tremendous benefits of and need to grow our energy transportation network and who support the union workforce that will build it.
Sincerely,
American Energy Industry Supporter
Daniel Hendrix 536047sc