| Docket Number | Docket Name | Company |
|---|---|---|
| UM 2274 | PGE REQUEST FOR WAIVER OF 2023 RFP PROCESS | PORTLAND GENERAL ELECTRIC |
| Comment Number | Created Date | Email Received Date | Company Name | Comment Type | Source Type | First Name | Last Name | Nearest City | Comment | |
|---|---|---|---|---|---|---|---|---|---|---|
| UM 2274-1 | 12/19/2023 8:41:46 AM | PORTLAND GENERAL ELECTRIC | General Comment | Web | Marshall | McGrady | PORTLAND | The Oregon Association of Electrical Workers and IBEW Local 48 strongly supports the labor language in PGE’s 2023 All Source RFP. While this language goes beyond the minimum labor standards put in place by House Bill 2021, it ensures that PGE energy projects maintain the highest standards for labor and are more in line with the current federal guidelines on energy projects. Working under a Project Labor Agreement (PLA) ensures labor harmony and guarantees that the local hire and apprenticeship goals that are necessary to be compliant with HB 2021 are met. A PLA provides standardized wages, benefits, overtime pay, working conditions and work rules for a project resulting in overall easier project management. PLAs ensures that projects see a dependable stream of qualified and skilled workers for a project and that the labor costs of the construction project are predictable. Project Labor Agreement also falls in line with current Federal requirements. Current guidelines from the Federal Government require the use of a PLA for projects over $35 million dollars for the following reasons: In expanding the use of PLAs on large Federal construction contracts, the new final rule promotes economy and efficiency in Federal procurement by: • Eliminating the risk of delay associated with labor unrest; • Ensuring parties agree to dispute resolution procedures and mechanisms for labor-management cooperation on matters like safety; • Making clear that PLAs may include other provisions designed to support workers from underserved communities and small businesses; • Helping ensure a steady supply of skilled workers for Federal construction projects; and • Promoting competition on Government contracts by allowing all contractors—including those who are non-union—to bid on contracts that require PLAs PGE’s commitment to high road labor standards is evident and the over 10,000 members of the OSAEW and the 5500 members of IBEW Local 48 strongly support these standards. | ||
| UM 2274-10 | 12/19/2023 1:50:58 PM | PORTLAND GENERAL ELECTRIC | Support Docket | Web | Shawn | Lenczowski | PORTLAND | On behalf of Bricklayers and Allied Craftworkers local #1 OR/WA/ID/MT and our partners, I am submitting comment in support of minimum bidder requirement that the projects be built under a Project Labor Agreement (PLA), as it is in accordance with Oregon HB 2021 and HB 4059. With the important benefits these projects will bring to Oregon and our transition to a clean energy economy, there is no time to delay. House Bill 2021includes labor standards that were refined in HB 4059 (2022) to clarify those were minimum standards and that a utility could, in fact, require more. HS 4059 makes clear that PLAs meet the minimum requirements of HB 2021/HB 4059; the use or requirement of PLAs are not considered more stringent since they are the minimum requirements. A PLA ensures workers earn family-sustaining wages and benefits, prioritizes worker safety, includes apprenticeship utilization and workforce equity requirements, and requires local hire prioritization. A PLA also ensures that all parties are on the same page with respect to how the project will be built, including processes and remedies for dispute resolution. Building the number of projects required to decarbonize the electric sector on the timeline required necessitates a coordinated and efficient process. A PLA serves exactly that function. PLAs offer flexibility and more certainty to meet workforce demands. As we decarbonize the electric sector, we must ensure that we do so in a way that is equitable and inclusive and provides opportunities for those who have been most impacted by the impacts of climate change. This will require intentional efforts to build the clean energy workforce through the utilization of apprenticeship and pre apprenticeship programs. Unions already have these programs built into their operating models and can scale in size depending on need. We should be leveraging models that are working to build the future workforce we will need. In conclusion, we support PGEs All Source contract language as it is in accordance with HB 2021/HB 4059, which again, added language to further conclude the use and requirements of PLAs were in accordance with the law and were seen as minimum standards. These projects present an opportunity to help Oregon meet its clean energy goals and create shared prosperity with long-term community benefits. We all have an obligation to ensure the energy transition to renewable technology is a just transition that supports Oregon workers and their families, and that can be best accomplished with Union labor and Project Labor Agreements. | ||
| UM 2274-11 | 12/19/2023 2:07:35 PM | PORTLAND GENERAL ELECTRIC | Support Docket | Web | Travis | Eri | PORTLAND | The International Brother of Electrical Workers (IBEW) Local 125 represents approximately 4,000 members working in the utility industry throughout the Pacific Northwest. As Business Manager and on their behalf, I am submitting comments strongly supporting the labor language in PGE’s 2023 All Source RFP. While this language goes beyond the base levels put in place by HB 2021, it ensures that PGE energy projects maintain the highest standards for labor and are more in line with the current federal guidelines on energy projects. The IBEW has never believed minimum standards were the goal on anything. For us, minimum means a starting point which is exactly what House Bill 2021 provided. Project Labor Agreements (PLA) ensure labor harmony and guarantee that the local hire and apprenticeship goals that are necessary to be in compliance with HB 2021 are met. PLAs provide standardized wages, benefits, overtime pay, working conditions and work rules for a project resulting in overall easier project management. A PLA is a tool that contributes to a qualified and skilled workforce which meets project demands. However, PLAs should not eliminate exclusions which address work covered under a collective bargaining agreement. While there are some organizations who will advocate for the removal of labor standards, we object. By labor standards, Oregon’s decarbonization of the electric sector can stay on track. The IBEW has been instrumental in supporting these efforts, and we want to ensure project developers do not build projects outside of our state because they are incentivized to do so if there are not PLAs. If we are truly working to ensure an inclusive and equitable electric sector, we must not ignore the impacts to those most impacted by climate change. Thus, our concerted and intentional efforts to build a clean energy workforce through apprenticeship and pre-apprenticeship programs are necessary. Let’s leverage models and resources that will build the future workforce. IBEW Local 125 supports expanding the use of PLAs because there will be a steady supply of skilled workers, decreased likelihood of labor unrest, and healthy competition on a level playing field for both union and non-union contractors. We support PLAs except in situations where work is work covered within the scope of IBEW Local 125 and done traditionally by our members. Even before the federal government announced all of its infrastructure programs, PGE has been committed to labor standards. IBEW Local 125 shares that same focus and strongly supports the labor standards proposed by PGE. We seek your support of these standards to ensure Oregon continues its transition to a clean energy future. | ||
| UM 2274-12 | 12/19/2023 2:25:15 PM | PORTLAND GENERAL ELECTRIC | General Comment | Web | Lorne | Bulling | BEAVERTON | December 19, 2023 To: Oregon Public Utility Commission Re: Support for the Minimum Bidder Requirements in Portland General Electric’s (PGE) 2023 All-Source Request for Proposals (RFP) On behalf of the Ironworkers Local 29 and our partners, I am submitting comment in support of minimum bidder requirement that the projects be built under a Project Labor Agreement (PLA), as it is in accordance with Oregon HB 2021 and HB 4059. With the important benefits these projects will bring to Oregon and our transition to a clean energy economy, there is no time to delay. House Bill 2021 includes labor standards that were refined in HB 4059 (2022) to clarify those were minimum standards and that a utility could, in fact, require more. HB 4059 makes clear that PLAs meet the minimum requirements of HB 2021/HB 4059; the use or requirement of PLAs are not considered more stringent since they are the minimum requirements. A PLA ensures workers earn family-sustaining wages and benefits, prioritizes worker safety, includes apprenticeship utilization and workforce equity requirements, and requires local hire prioritization. A PLA also ensures that all parties are on the same page with respect to how the project will be built, including processes and remedies for dispute resolution. Building the number of projects required to decarbonize the electric sector on the timeline required necessitates a coordinated and efficient process. A PLA serves exactly that function. PLAs offer flexibility and more certainty to meet workforce demands. As we decarbonize the electric sector, we must ensure that we do so in a way that is equitable and inclusive and provides opportunities for those who have been most impacted by the impacts of climate change. This will require intentional efforts to build the clean energy workforce through the utilization of apprenticeship and pre-apprenticeship programs. Unions already have these programs built into their operating models and can scale in size depending on need. We should be leveraging models that are working to build the future workforce we will need. In conclusion, we support PGEs All Source contract language as it is in accordance with HB 2021/HB 4059, which again, added language to further conclude the use and requirements of PLAs were in accordance with the law and were seen as minimum standards. These projects present an opportunity to help Oregon meet its clean energy goals and create shared prosperity with long-term community benefits. We all have an obligation to ensure the energy transition to renewable technology is a just transition that supports Oregon workers and their families, and that can be best accomplished with Union labor and Project Labor Agreements. Thank you, Lorne Bulling Ironworkers Local 29 | ||
| UM 2274-13 | 12/19/2023 2:30:07 PM | PORTLAND GENERAL ELECTRIC | General Comment | Web | Jeff | Gritz | PORTLAND | The Oregon & Southern Idaho District Council of Laborers (“OSIDCL”) hereby submit these comments on the Staff Report of Portland General Electric Company’s (“PGE”) Draft Final All-Source Request for Proposals (“RFP”). OSIDCL represents over 4,000 members in the state, including workers who build and maintain PGE facilities. PGE’s RFP includes a provision mandating union labor for construction activities, and inclusion of a Project Labor Agreement (“PLA”) in any related engineering, procurement, and construction agreements. The Staff Report adopts a recommendation by OSSIA to remove the PLA mandate. We urge the Commission to reject staff’s recommendation, and permit PGE to retain its PLA requirement for all construction activities. PLAs are a proven workforce development solution in the construction industry. Public and private entities have successfully used PLAs to build critical infrastructure projects for decades. Because major construction projects require multiple employers and trades, PLAs help to standardize working terms and conditions for all labor employed on a project. By mandating all subcontractors adhere to the terms, PLAs promote efficiency, labor-management cooperation, and compliance with employment and labor laws. In addition, PLAs have broader community implications. PLAs ensure workers earn family-sustaining wages and benefits, prioritize worker safety, include apprenticeship utilization and workforce equity requirements, and require local hire prioritization. Building the number of projects required to decarbonize the electric sector on the timeline required necessitates a coordinated and efficient process. A PLA serves exactly that function. Parties opposed to the use of PLAs offer no proof that a PLA is inconsistent with the public interest. There is evidence however that on projects where construction workers lack the protections of a PLA or collective bargaining agreement, workers suffer. The OR Labor Commissioner determined in 2019 that wind farm construction workers had been abused on the Montague Wind Farm in eastern OR. The general contractor, RES Americas, did not commit to firm local hiring goals or wage standards. Instead, the project became a source of controversy when the OR Bureau of Labor & Industries investigated the project and found multiple violations of Oregon wage and hour laws. (see: Case No. 14-20, Final Order, Jan. 29, 2020). Workers on the project noted a lack of restroom facilities and water, and threats and intimidation by RES management. Following the law is a bare minimum- PGE should be allowed to create high quality jobs. OSSIA and staff take a position that PGE should not be allowed to go further than the law mandates. However, PGE has long used its management discretion to decide when and where to use PLAs in its procurement decisions on traditional energy infrastructure. For example, a national PLA for maintenance activities is used on PGE gas plants. Prior to the shutdown of Trojan Coal Plant, it was also maintained under a PLA. Indeed, PGE has had a PLA for power plant maintenance activities for 40 years. In addition, PGE’s Responsible Contractor Policy requires the employment of its in-house workforce, IBEW Local 125. PGE’s robust labor standards are not questioned in other areas of operation, so why should construction workers on clean energy projects be held to a lower standard? Moreover, nothing in HB 2021 or HB 4059 prohibits the use of a PLA. HB 4059 makes clear that PLAs meet the minimum requirements of HB 2021/HB 4059. The use or requirement of PLAs are not considered more stringent because they are the minimum requirements. PLAs provide a hedge against IRA non-compliance. The IRA provides bonus production and tax credits for projects that meet statutory labor standards that are five times greater than the base credit. But, IRA also provides significant penalties for non-compliance. The Treasury Department’s proposed regulations, however, waive penalty payments for failures to meet IRA’s labor requirements if the taxpayer has a PLA in place that meets those requirements. And although we believe PLAs ensure all applicable labor requirements are met because they bind all subcontractors to these terms, the very existence of a PLA can serve as a hedge against inadvertent non-compliance. Multiple utilities in other states, including Indiana Michigan Power, NV Energy, Appalachian Power, and Xcel Minnesota, have PLA or union labor mandates in their RFPs. Oregon should lead not only in climate goals, but also support utilities to leverage clean energy investments to create high quality jobs. We support PGE’s RFP as it aligns with HB 2021/HB 4059, which again, added language to conclude the use and requirements of PLAs were consistent with state law and considered minimum standards. These projects present an opportunity to help OR meet its climate goals and create shared prosperity. PLAs ensure the transition occurs equ | ||
| UM 2274-14 | 12/19/2023 2:31:53 PM | PORTLAND GENERAL ELECTRIC | General Comment | Web | Jeff | Gritz | PORTLAND | The Oregon & Southern Idaho District Council of Laborers (“OSIDCL”) hereby submit these comments on the Staff Report of Portland General Electric Company’s (“PGE”) Draft Final All-Source Request for Proposals (“RFP”). OSIDCL represents over 4,000 members in the state, including workers who build and maintain PGE facilities. PGE’s RFP includes a provision mandating union labor for construction activities, and inclusion of a Project Labor Agreement (“PLA”) in any related engineering, procurement, and construction agreements. The Staff Report adopts a recommendation by OSSIA to remove the PLA mandate. We urge the Commission to reject staff’s recommendation, and permit PGE to retain its PLA requirement for all construction activities. PLAs are a proven workforce development solution in the construction industry. Public and private entities have successfully used PLAs to build critical infrastructure projects for decades. Because major construction projects require multiple employers and trades, PLAs help to standardize working terms and conditions for all labor employed on a project. By mandating all subcontractors adhere to the terms, PLAs promote efficiency, labor-management cooperation, and compliance with employment and labor laws. In addition, PLAs have broader community implications. PLAs ensure workers earn family-sustaining wages and benefits, prioritize worker safety, include apprenticeship utilization and workforce equity requirements, and require local hire prioritization. Building the number of projects required to decarbonize the electric sector on the timeline required necessitates a coordinated and efficient process. A PLA serves exactly that function. Parties opposed to the use of PLAs offer no proof that a PLA is inconsistent with the public interest. There is evidence however that on projects where construction workers lack the protections of a PLA or collective bargaining agreement, workers suffer. The OR Labor Commissioner determined in 2019 that wind farm construction workers had been abused on the Montague Wind Farm in eastern OR. The general contractor, RES Americas, did not commit to firm local hiring goals or wage standards. Instead, the project became a source of controversy when the OR Bureau of Labor & Industries investigated the project and found multiple violations of Oregon wage and hour laws. (see: Case No. 14-20, Final Order, Jan. 29, 2020). Workers on the project noted a lack of restroom facilities and water, and threats and intimidation by RES management. Following the law is a bare minimum- PGE should be allowed to create high quality jobs. OSSIA and staff take a position that PGE should not be allowed to go further than the law mandates. However, PGE has long used its management discretion to decide when and where to use PLAs in its procurement decisions on traditional energy infrastructure. For example, a national PLA for maintenance activities is used on PGE gas plants. Prior to the shutdown of Trojan Coal Plant, it was also maintained under a PLA. Indeed, PGE has had a PLA for power plant maintenance activities for 40 years. In addition, PGE’s Responsible Contractor Policy requires the employment of its in-house workforce, IBEW Local 125. PGE’s robust labor standards are not questioned in other areas of operation, so why should construction workers on clean energy projects be held to a lower standard? Moreover, nothing in HB 2021 or HB 4059 prohibits the use of a PLA. HB 4059 makes clear that PLAs meet the minimum requirements of HB 2021/HB 4059. The use or requirement of PLAs are not considered more stringent because they are the minimum requirements. PLAs provide a hedge against IRA non-compliance. The IRA provides bonus production and tax credits for projects that meet statutory labor standards that are five times greater than the base credit. But, IRA also provides significant penalties for non-compliance. The Treasury Department’s proposed regulations, however, waive penalty payments for failures to meet IRA’s labor requirements if the taxpayer has a PLA in place that meets those requirements. And although we believe PLAs ensure all applicable labor requirements are met because they bind all subcontractors to these terms, the very existence of a PLA can serve as a hedge against inadvertent non-compliance. Multiple utilities in other states, including Indiana Michigan Power, NV Energy, Appalachian Power, and Xcel Minnesota, have PLA or union labor mandates in their RFPs. Oregon should lead not only in climate goals, but also support utilities to leverage clean energy investments to create high quality jobs. We support PGE’s RFP as it aligns with HB 2021/HB 4059, which again, added language to conclude the use and requirements of PLAs were consistent with state law and considered minimum standards. These projects present an opportunity to help OR meet its climate goals and create shared prosperity. | ||
| UM 2274-15 | 12/19/2023 3:00:51 PM | PORTLAND GENERAL ELECTRIC | General Comment | Web | Mike | Alldritt | HEPPNER | Hello my name is Mike Alldritt. I am writing this message to be in support of PGE‘s language that they have in their RFP process. I represent 1300 journeywomen and journeymen along with apprentices in the entire state of Oregon 5 1/2 counties in Southwest Washington Has been a great partner and asset to the state of Oregon and the building trades when it comes to training our future workforces to complete the tasks that we need to complete within our own state with our own people I am in favor of PGE’s language. | ||
| UM 2274-16 | 12/19/2023 4:38:03 PM | PORTLAND GENERAL ELECTRIC | Support Docket | Web | Scott | Schaefer | PORTLAND | As we transition from a carbon based to a carbon neutral economy, there has always been promises made to the working class of just transition. Are we going to just transition or provide a just transition for the workforce? The building of this Infrastructure requires a highly skilled and trained workforce that the Unions have already heavily invested in the apprenticeship programs and further Journey level worker trainings to meet the needs of the Local and National economies, in building this new Green Infrastructure. Without an achievable plan of local hire, there will be no building of the workforce and the ability to maintain and sustain this infrastructure, it will be decimated through the economy without this workforce. This is critical infrastructure that keeps are cities moving and flowing, healthy and safe. We cannot gamble with this on a possible opportunity that maybe saving of a few dollars and risk local and national safety. A project labor agreement ensures that all parties are on the same page with respect to how the project will be built, including processes and remedies for dispute resolution, apprenticeship utilization, and local hiring. Building the amount of projects required to decarbonize the electric sector on the timeline required necessitates a coordinated and efficient process. A PLA serves exactly that function. With decarbonization of the electric sector, we must be intentional, equitable and inclusive to this workforce and provide opportunities for those impacted by climate change. Scott Schaefer, Western States Regional Council of Carpenters | ||
| UM 2274-17 | 12/19/2023 2:26:17 PM | PORTLAND GENERAL ELECTRIC | General Comment | Web | Jason | Fussell | PORTLAND | December 19, 2023 To: Oregon Public Utility Commission Re: Support for the Minimum Bidder Requirements in Portland General Electric’s (PGE) 2023 All-Source Request for Proposals (RFP) On behalf of the Ironworkers Local 29 and our partners, I am submitting comment in support of minimum bidder requirement that the projects be built under a Project Labor Agreement (PLA), as it is in accordance with Oregon HB 2021 and HB 4059. With the important benefits these projects will bring to Oregon and our transition to a clean energy economy, there is no time to delay. House Bill 2021 includes labor standards that were refined in HB 4059 (2022) to clarify those were minimum standards and that a utility could, in fact, require more. HB 4059 makes clear that PLAs meet the minimum requirements of HB 2021/HB 4059; the use or requirement of PLAs are not considered more stringent since they are the minimum requirements. A PLA ensures workers earn family-sustaining wages and benefits, prioritizes worker safety, includes apprenticeship utilization and workforce equity requirements, and requires local hire prioritization. A PLA also ensures that all parties are on the same page with respect to how the project will be built, including processes and remedies for dispute resolution. Building the number of projects required to decarbonize the electric sector on the timeline required necessitates a coordinated and efficient process. A PLA serves exactly that function. PLAs offer flexibility and more certainty to meet workforce demands. As we decarbonize the electric sector, we must ensure that we do so in a way that is equitable and inclusive and provides opportunities for those who have been most impacted by the impacts of climate change. This will require intentional efforts to build the clean energy workforce through the utilization of apprenticeship and pre-apprenticeship programs. Unions already have these programs built into their operating models and can scale in size depending on need. We should be leveraging models that are working to build the future workforce we will need. In conclusion, we support PGEs All Source contract language as it is in accordance with HB 2021/HB 4059, which again, added language to further conclude the use and requirements of PLAs were in accordance with the law and were seen as minimum standards. These projects present an opportunity to help Oregon meet its clean energy goals and create shared prosperity with long-term community benefits. We all have an obligation to ensure the energy transition to renewable technology is a just transition that supports Oregon workers and their families, and that can be best accomplished with Union labor and Project Labor Agreements. Thank you, Jason Fussell Business Manager Ironworkers Local 29 | ||
| UM 2274-18 | 5/30/2024 2:08:34 PM | OTHER | Oppose Docket | Web | Jeanie | Braun | WILSONVILLE | Waiver request: OAR 860-025-0030(3) I am opposed to the proposed amendments to the Clackamas County Zoning and Development Ordinance (ZDO) that would adopt a comprehensive definition of ‘utility facility’, clarify the types of utility lines that must be underground, and outright allow utility facilities inside the right of way and utility lines outside the right of way. To not require PGE to obtain a Conditional Use permit under current county law would be a complete abdication of the county's obligation to the public. This is proposed rule change is obviously has PGE’s backing. As you know, PGE is planning to construct of a new 115kV high voltage power line from Rosemont substation along Stafford Road to the new Tonquin substation.. The proposal to change to CUP or conditional use permit process would push this project through to replace 40’ tall 15kV 100’-150’ power poles in our rural residential neighborhood. If this passes, there would be no opportunity for public comment. The property owners and surrounding community concerns and questions would be ignored and eliminated. Many community members are upset does allows a large corporation like PGE to bulldoze their way through and change the zoning requirement rules. At minimum there needed to be consideration to continue the standard CUP process for larger and more complicated projects, which of course, the community believes the Tonquin project would easily qualify. One of the main considerations for a non-conforming permit is the permit requestor needs to prove there is no major impact to the alteration of the character of the neighborhood. Why would this consideration be made by the County when all other major zoning changes are requiring a permit? This due process is would be eliminated and circumvent the current rules. This major change needs to be considered from more than one standpoint. There will be little transparency, public notice or comments on the changes to the County right of way our onto private property behind the right of way even though the negative impacts will be significant. PGE’s Tonquin project along our road along Stafford as well as other major projects in Clackamas County will have a major impact on and drastically change the neighborhood. The project will change aesthetics/destruction of trees, use Stafford Road as a highway bypass to I205 and I5, increase the danger of wrecks and pole damage and significantly devalue property owners home values Ther is mass community opposition to the high voltage lines, lines near buildings, and safety concerns with the increased fire danger in an unprotected rural area. The public has a right to know why these changes were really being considered. There has been no real discussion about the short and long term impact of this potentially dangerous policy change. There is a reason these policies were originally instituted and the rationale that the county doesn’t have the necessary resources isn’t enough to warrant such a dramatic change. The question asked at the last planning meeting by one of the commissioners was the right one – if the county had the necessary resources would these changes be made? I recommend that effective immediately, due to these obvious highly questionable actions, that the commissioners request a complete withdrawal of this policy change proposal and investigate all the circumstances why the current policy wasn’t being either understood or complied with and then why a new policy change was immediately being proposed by the county that would expedite PGE’s current Tonquin and all future projects without any oversight. Please pass on my comments (to all the other commissioners), expressing my opposition of this change to rubber stamp all overhead and underground utilities both within and outside of the right of way without any public discourse and without any consideration to the size, complexity and scope of new projects. | ||
| UM 2274-2 | 12/19/2023 10:56:46 AM | PORTLAND GENERAL ELECTRIC | Oppose Docket | Web | OR AFL-CIO | PORTLAND | With a diverse membership made up of construction workers and environmental regulators, linemen and pulp and paper workers, nurses and manufacturing workers, education employees and public transit workers, the Oregon AFL-CIO has a commitment to decarbonizing the electric sector in a way that is equitable, inclusive and supports and strengthens jobs for Oregonians. The Oregon Labor Movement has been engaged in the passage and implementation of Oregon HB 2021 (passed in 2021) directing Oregon to create a demand for 100% clean energy by 2040, joining California and Washington. This bill also includes minimum floors around registered apprenticeship and apprenticeship utilization requirements, workforce equity goals, responsible contractor requirements, prevailing wage, healthcare, and retirement benefit requirements, and project labor agreement requirements for projects above 10 megawatt. In 2022 we worked to help make clear that these are in fact minimums and a utility could require more than these standards Consequently, we are very concerned when these minimums are eroded, and are particularly concerned that the PUC staff recommendation removes the minimum requirement that projects be built with union labor and utilize a project labor agreement. Simply put, the high-road standards that unions require fundamentally boost wages of both represented and non-represented workers, improve safety of the workplace, boost worker and family health outcomes, and help close wage gaps for Black and Latinx workers. A project labor agreement ensures that all parties are on the same page with respect to how the project will be built, including processes and remedies for dispute resolution, apprenticeship utilization, and local hiring. Building the amount of projects required to decarbonize the electric sector on the timeline required necessitates a coordinated and efficient process. A PLA serves exactly that function. HB 2021 labor standards also do not apply outside the State of Oregon. The only way that PGE resources built outside the state are held to the same standards as projects built in Oregon is to use RFP requirements that ensure the competitiveness of proposed projects located in Oregon. If project developers can build projects with lesser standards outside the state, they will be incentivized to do so. Decarbonizing the electric sector will require intentional efforts to build the clean energy workforce through the utilization of apprenticeship and pre-apprenticeship programs. Unions already have these programs built into their operating models and have the ability to scale in size depending on need. We should be leveraging models that are working to build the future workforce we will need. We ask that ensuring high-road jobs-- those that are long-term, safe and family-supporting jobs – through PLAs and done by union labor, in alignment with HB 2021 will be specifically required as our state continues to move to dial on decarbonization, racial justice, equitable economic mobility, and community wealth creation . | |||
| UM 2274-3 | 12/19/2023 11:20:04 AM | PORTLAND GENERAL ELECTRIC | General Comment | Web | Brian | Noble | PORTLAND | International Association of Sheet Metal, Air, Rail, Transportation Workers NWRC of SMART, Local 16 2379 N.E. 178th AVE. PORTLAND, OREGON 97230-5957 PHONE: (503) 254-0123 • FAX: (503) 254-0157 December 19, 2023 To: Oregon Public Utility Commission Re: Support for the Minimum Bidder Requirements in Portland General Electric’s (PGE) 2023 All-Source Request for Proposals (RFP) On behalf of Northwest Regional Council of SMART, LU 16 and our partners, I am submitting comment in support of minimum bidder requirement that the projects be built under a Project Labor Agreement (PLA), as it is in accordance with Oregon HB 2021 and HB 4059. With the important benefits these projects will bring to Oregon and our transition to a clean energy economy, there is no time to delay. House Bill 2021 includes labor standards that were refined in HB 4059 (2022) to clarify those were minimum standards and that a utility could, in fact, require more. HB 4059 makes clear that PLAs meet the minimum requirements of HB 2021/HB 4059; the use or requirement of PLAs are not considered more stringent since they are the minimum requirements. A PLA ensures workers earn family-sustaining wages and benefits, prioritizes worker safety, includes apprenticeship utilization and workforce equity requirements, and requires local hire prioritization. A PLA also ensures that all parties are on the same page with respect to how the project will be built, including processes and remedies for dispute resolution. Building the number of projects required to decarbonize the electric sector on the timeline required necessitates a coordinated and efficient process. A PLA serves exactly that function. PLAs offer flexibility and more certainty to meet workforce demands. As we decarbonize the electric sector, we must ensure that we do so in a way that is equitable and inclusive and provides opportunities for those who have been most impacted by the impacts of climate change. This will require intentional efforts to build the clean energy workforce through the utilization of apprenticeship and pre-apprenticeship programs. Unions already have these programs built into their operating models and can scale in size depending on need. We should be leveraging models that are working to build the future workforce we will need. In conclusion, we support PGEs All Source contract language as it is in accordance with HB 2021/HB 4059, which again added language to further conclude the use and requirements of PLAs were in accordance with the law and were seen as minimum standards. These projects present an opportunity to help Oregon meet its clean energy goals and create shared prosperity with long-term community benefits. We all have an obligation to ensure the energy transition to renewable technology is a just transition that supports Oregon workers and their families, and that can be best accomplished with Union labor and Project Labor Agreements. Thank you, Brian Noble Regional Manager NWRC of SMART, LU 16 | ||
| UM 2274-4 | 12/19/2023 12:04:43 PM | PORTLAND GENERAL ELECTRIC | Support Docket | Web | Nate | Stokes | GLADSTONE | On behalf of International Union of Operating Engineers Local 701 I would like to comment on the labor provisions of the RFP process. The Operating Engineers Local 701 is in full support of minimum bidder requirement that the projects be built under a Project Labor Agreement (PLA), as it is in accordance with Oregon HB 2021 and HB 4059. With the important benefits these projects will bring to Oregon and our transition to a clean energy economy, there is no time to delay. House Bill 2021 includes labor standards that were refined in HB 4059 (2022) to clarify those were “minimum” standards and that a utility could, in fact, require more. HB 4059 makes clear that PLAs meet the “minimum” requirements of HB 2021/HB 4059; the use or requirement of PLAs are not considered more stringent since they are the “minimum” requirements. A PLA ensures workers earn family-sustaining wages and benefits, prioritizes worker safety, includes apprenticeship utilization and workforce equity requirements, and requires local hire prioritization. A PLA also ensures that all parties are on the same page with respect to how the project will be built, including processes and remedies for dispute resolution. Building the number of projects required to decarbonize the electric sector on the timeline required necessitates a coordinated and efficient process. A PLA serves exactly that function. PLAs offer flexibility and more certainty to meet workforce demands. As we decarbonize the electric sector, we must ensure that we do so in a way that is equitable and inclusive and provides opportunities for those who have been most impacted by the impacts of climate change. This will require intentional efforts to build the clean energy workforce through the utilization of apprenticeship and pre-apprenticeship programs. Unions already have these programs built into their operating models and can scale in size depending on need. We should be leveraging models that are working to build the future workforce we will need. In conclusion, we support PGEs All Source contract language as it is in accordance with HB 2021/HB 4059, which again added language to further conclude the use and requirements of PLAs were in accordance with the law and were seen as minimum standards. These projects present an opportunity to help Oregon meet its clean energy goals and create shared prosperity with long-term community benefits. We all have an obligation to ensure the energy transition to renewable technology is a just transition that supports Oregon workers and their families, and that can be best accomplished with Union labor and Project Labor Agreements. Thank you, Nate Stokes Assistant Business Manager | ||
| UM 2274-5 | 12/19/2023 1:33:32 PM | PORTLAND GENERAL ELECTRIC | Support Docket | Web | Robert | Camarillo | OREGON CITY | The Oregon State Building and Construction Trades Council (OSBCTC) is a statewide umbrella organization comprised of 31 member Unions, representing tens of thousands of Union skilled trades workers in a wide array of crafts around and across the state. OSBCTC's affiliates are leaders in the nation in establishing apprenticeship programs that are the gold-standard in both construction quality and worker safety. Together, we work and advocate for local jobs that provide family-sustaining wages, ample hours, and safe working conditions; diversifying the workforce through our privately funded world-class registered training and apprenticeship programs; funding for major infrastructure projects and more. On behalf of the OSBCTC, I am submitting comment in support of minimum bidder requirement that the projects be built under a Project Labor Agreement, as it is in accordance with Oregon HB 2021 and HB 4059. With the passage of HB 2021(2021) and HB 4059 (2022), our state advanced high road labor standards for all large-scale renewable projects. House Bill 2021 includes labor standards that were refined in HB 4059 (2022) to clarify those were minimum standards and that a utility could, in fact, require more. HB 4059 makes clear that PLAs meet the minimum requirements of HB 2021/HB 4059; the use or requirement of PLAs are not considered more stringent since they are the minimum requirements. House Bill 2021 passed prior to the passage of the Bipartisan Infrastructure Law, the Inflation Reduction Act, and the CHIPS Act. With the rapid influx of projects that will need to be built over the next several years combined with the impacts of the other policies mentioned, that minimum is no longer sufficient. Furthermore, HB 2021 labor standards do not apply outside the State of Oregon. The only way that PGE resources built outside the state are held to the same standards as projects built in Oregon is to use RFP requirements that ensure the competitiveness of proposed projects located in Oregon. If project developers can build projects with lesser standards outside the state, they will be incentivized to do so. PGE’s 2023 All Source RFP has the potential to create thousands of family-sustaining careers, bolstering a skilled and diverse workforce that will help build the transition to a clean energy economy. In addition, it will promote long-term energy security while improving safety throughout Oregon. Utilizing a project delivery tool such as a Project Labor Agreement (PLA) ensures projects are built on time, safely, and on budget while also ensuring that fair wages and benefits are paid to all workers on the projects, that all workers have safe and healthy working conditions, that contractors prioritize the hiring of local and diverse workers from local communities and the region, and that state registered apprentices are hired to help continue growing Oregon and the region’s skilled workforce for the future. Further, PLAs remove potential barriers small and disadvantaged businesses often face when bidding on non-PLA projects. The Oregon State Building Trades Unions has always had the capacity to meet all of Oregon’s construction demands. Our model and approach are set to meet the demand, change lives for the better, and uplift communities for generations. There is no other workforce development infrastructure in the construction industry that can expand or contract based on the market demands. We should be leveraging models that are working to build the future workforce we will need. We will continue growing our capacity in the years ahead – but only if there are enough working hours available. Right now, there are waitlists for many of our apprenticeship programs because there is more interest in construction jobs from workers than there are jobs and apprenticeships available here in Oregon. As we decarbonize the electric sector, we must ensure that we do so in a way that is equitable and inclusive and provides opportunities for those who have been most impacted by the impacts of climate change. Our affiliates and partners clearly understand that this is our chance to provide opportunities to the next generation of skilled trades professionals and our programs are recruiting and retaining more building tradespeople, especially more women, workers of color, indigenous workers, veterans and the justice-involved among our ranks. We all have an obligation to ensure the energy transition to renewable technology is a just transition that supports Oregon workers and their families, and that can be accomplished with Union labor and use of Project Labor Agreements. Oregon’s Building Trades members we represent, the apprentices who earn while they learn, and future apprentices stand ready to get to work on clean energy jobs. | ||
| UM 2274-6 | 12/19/2023 1:46:21 PM | PORTLAND GENERAL ELECTRIC | Support Docket | Web | Drew | Lindsey | TANGENT | On behalf of Local 280 and our partners, I am submitting comment in support of minimum bidder requirement that the projects be built under a Project Labor Agreement (PLA}, as it is in accordance with Oregon HB 2021 and HB 4059. With the important benefits these projects will bring to Oregon and our transition to a clean energy economy, there is no time to delay. House Bill 2021 includes labor standards that were refined in HB 4059 (2022) to clarify those were minimum standards and that a utility could, in fact, require more. HB 4059 makes clear that PLAs meet the minimum requirements of HB 2021/HB 4059; the use or requirement of PLAs are not considered more stringent since they are the minimum requirements. A PLA ensures workers earn family-sustaining wages and benefits, prioritizes worker safety, includes apprenticeship utilization and workforce equity requirements, and requires local hire prioritization. A PLA also ensures that all parties are on the same page with respect to how the project will be built, including processes and remedies for dispute resolution. Building the number of projects required to decarbonize the electric sector on the timeline required necessitates a coordinated and efficient process. A PLA serves exactly that function. PLAs offer flexibility and more certainty to meet workforce demands. As we decarbonize the electric sector, we must ensure that we do so in a way that is equitable and inclusive and provides opportunities for those who have been most impacted by the impacts of climate change. This will require intentional efforts to build the clean energy workforce through the utilization of apprenticeship and pre-apprenticeship programs. Unions already have these programs built into their operating models and can scale in size depending on need. We should be leveraging models that are working to build the future workforce we will need. In conclusion, we support PGEs All Source contract language as it is in accordance with HB 2021/HB 4059, which again added language to further conclude the use and requirements of PLAs were in accordance with the law and were seen as minimum standards. These projects present an opportunity to help Oregon meet its clean energy goals and create shared prosperity with long-term community benefits. We all have an obligation to ensure the energy transition to renewable technology is a just transition that supports Oregon workers and their families, and that can be best accomplished with Union labor and Project Labor Agreements. | ||
| UM 2274-7 | 12/19/2023 1:42:30 PM | PORTLAND GENERAL ELECTRIC | Support Docket | Web | Garth | Bachman | PORTLAND | On behalf of the International Brotherhood of Electrical Workers Local Union 48 and our partners, I am submitting comment in support of minimum bidder requirement that the projects be built under a Project Labor Agreement (PLA), as it is in accordance with Oregon HB 2021 and HB 4059. With the important benefits these projects will bring to Oregon and our transition to a clean energy economy, there is no time to delay. House Bill 2021 includes labor standards that were refined in HB 4059 (2022) to clarify those were minimum standards and that a utility could, in fact, require more. HB 4059 makes clear that PLAs meet the minimum requirements of HB 2021/HB 4059; the use or requirement of PLAs are not considered more stringent since they are the minimum requirements. A PLA ensures workers earn family-sustaining wages and benefits, prioritizes worker safety, includes apprenticeship utilization and workforce equity requirements, and requires local hire prioritization. A PLA also ensures that all parties are on the same page with respect to how the project will be built, including processes and remedies for dispute resolution. Building the number of projects required to decarbonize the electric sector on the timeline required necessitates a coordinated and efficient process. A PLA serves exactly that function. PLAs offer flexibility and more certainty to meet workforce demands. As we decarbonize the electric sector, we must ensure that we do so in a way that is equitable and inclusive and provides opportunities for those who have been most impacted by the impacts of climate change. This will require intentional efforts to build the clean energy workforce through the utilization of apprenticeship and pre-apprenticeship programs. Unions already have these programs built into their operating models and can scale in size depending on need. We should be leveraging models that are working to build the future workforce we will need. In conclusion, we support PGEs All Source contract language as it is in accordance with HB 2021/HB 4059, which again, added language to further conclude the use and requirements of PLAs were in accordance with the law and were seen as minimum standards. These projects present an opportunity to help Oregon meet its clean energy goals and create shared prosperity with long-term community benefits. We all have an obligation to ensure the energy transition to renewable technology is a just transition that supports Oregon workers and their families, and that can be best accomplished with Union labor and Project Labor Agreements. | ||
| UM 2274-8 | 12/19/2023 1:45:23 PM | PORTLAND GENERAL ELECTRIC | Support Docket | Web | Geoffrey | Kossak | PORTLAND | December 19, 2023 To: Oregon Public Utility Commission Re: Support for the Minimum Bidder Requirements in Portland General Electric’s (PGE) 2023 All-Source Request for Proposals (RFP) On behalf of The Cement Masons Local 555 and our partners, I am submitting comment in support of minimum bidder requirement that the projects be built under a Project Labor Agreement (PLA), as it is in accordance with Oregon HB 2021 and HB 4059. With the important benefits these projects will bring to Oregon and our transition to a clean energy economy, there is no time to delay. House Bill 2021 includes labor standards that were refined in HB 4059 (2022) to clarify those were minimum standards and that a utility could, in fact, require more. HB 4059 makes clear that PLAs meet the minimum requirements of HB 2021/HB 4059; the use or requirement of PLAs are not considered more stringent since they are the minimum requirements. A PLA ensures workers earn family-sustaining wages and benefits, prioritizes worker safety, includes apprenticeship utilization and workforce equity requirements, and requires local hire prioritization. A PLA also ensures that all parties are on the same page with respect to how the project will be built, including processes and remedies for dispute resolution. Building the number of projects required to decarbonize the electric sector on the timeline required necessitates a coordinated and efficient process. A PLA serves exactly that function. PLAs offer flexibility and more certainty to meet workforce demands. As we decarbonize the electric sector, we must ensure that we do so in a way that is equitable and inclusive and provides opportunities for those who have been most impacted by the impacts of climate change. This will require intentional efforts to build the clean energy workforce through the utilization of apprenticeship and pre-apprenticeship programs. Unions already have these programs built into their operating models and can scale in size depending on need. We should be leveraging models that are working to build the future workforce we will need. In conclusion, we support PGEs All Source contract language as it is in accordance with HB 2021/HB 4059, which again, added language to further conclude the use and requirements of PLAs were in accordance with the law and were seen as minimum standards. These projects present an opportunity to help Oregon meet its clean energy goals and create shared prosperity with long-term community benefits. We all have an obligation to ensure the energy transition to renewable technology is a just transition that supports Oregon workers and their families, and that can be best accomplished with Union labor and Project Labor Agreements. Thank you, Geoff Kossak Business Manager Cement Masons Local 555 | ||
| UM 2274-9 | 12/19/2023 1:50:00 PM | PORTLAND GENERAL ELECTRIC | Oppose Docket | Web | Ranfis | Giannettino Villatoro | PORTLAND | Subject: UM2274: Support use of Project Labor Agreements as minimum requirements of HB 2021/4059 Dear Oregon PUC Commissioner Megan Decker, Commissioner Letha Tawney, BlueGreen Alliance is guided by the principle that we can no longer choose between good jobs and a clean and safe environment—that the actions we take to create quality jobs and to protect working people and the environment must go hand in hand, and that together, we will build a clean, thriving, and fair economy. We thank the Oregon PUC for the opportunity to comment on UM2247, and express support for PGE’s inclusion of labor provision in its draft all source RFP and disagree is OPUC staff for its recommended omission. Below our key points for our support. 1. HB 4059 makes clear, the inclusion of HB 2021/HB 4059 in Utility RFP for competitive bids are in fact a requirement. 2. HB 4059 (see section 1(7)(a)) makes clear nothing prohibits the inclusion of labor standards in addition to HB 2021/HB 4059 labor standards. HB 4059 Language: (7) Nothing in this section: (a) Prohibits the inclusion of labor standards in addition to those required by subsection (2) of this section in contracts that are subject to this section; or 3. HB 4059 (see section 1(7)(b)) makes clear that Project Labor Agreements (PLA’s) meet the minimum requirements of HB 2021/HB 4059; the use or requirement of PLAs are not considered more stringent since they are the minimum requirements. Language from HB 4059: (7) Nothing in this section: (a) Prohibits the inclusion of labor standards in addition to those required by subsection (2) of this section in contracts that are subject to this section; or (b) Prohibits a person from using a project labor agreement to meet the minimum requirements of subsection (2) of this section. Further more: 1. Project Labor Agreements (PLAs) offer more flexibility than stringent HB 2021/HB 4059 apprenticeship, workforce equity, anti-harassment, prevailing wage requirement, employer-provided health and retirement benefit, and developer requirement that all contractors and subcontractors demonstrate 7 years of history of compliance of state and federal laws. 2. Project Labor Agreements (PLAs) offer flexibility and more certainty of workforce supply in the face of workforce supply shortages. 3. PLA’s allow for the use of non-union contractors, and offers inclusion and promotion of disadvantaged businesses 4. Federal guidance on inflation reduction act suggests PLA’s provide the most certainty for attaining 30% production tax credits and are not subject to proactive (See- https://home.treasury.gov/news/press-releases/jy1708) 5. Projects with PLA’s vs projects without PLAs do not show no demonstrably delta on overall project costs. See blog from the Economic Policy Institute: https://www.epi.org/blog/project-labor-agreements-on-federal-construction-projects-will-benefit-nearly-200000-workers/ In conclusion, we support PGEs All Source contract language as it is in accordance with Hb 2021/HB 4059, which again, added language to further conclude the use and requirements of PLAs were in accordance with the law and were seen as minimum standards of the law. We additionally support the policy to support the use of all union labor on projects with is permitted in HB 2021/HB 4059. Respectfully, Ranfis Giannettino Villatoro Oregon Policy Manager BlueGreen Alliance Rvillatoro@bluegreenalliance.org |