Jason Margerum
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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 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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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
Jason Margerum 1086sc