February 4, 2008

Comments to the Public Service Commission

Public Hearing- South Oak Creek Air Quality Controls

My name is Mark Maierle. I am the Business Manager of Operating Engineers Local 317. Our union members operate and maintain the power plant equipment used by We Energies to produce electricity and reduce emissions. We are dedicated to being a highly trained and productive workforce that helps We Energies meet the reliability needs of ratepayers and reduce emissions. The efforts of our union with We Energies are focused on the appropriate staffing of our plants, providing comprehensive training to maximize performance, and enhancing workplace safety and productivity.

While keeping high skilled, family supporting jobs at Oak Creek is obviously very important to us, I also want to emphasize how important protecting the environment is to our members, and explain some of the things we do to achieve that. Because we are a skilled trade, training based organization, we created a Power Engineering program that is offered at Milwaukee Area Technical College’s South Campus. This program can be used to help train power plant operators and mechanics to do the best job of operating power generation equipment efficiently and keeping the equipment in peak condition. Investing in this type of training results in lower cost generation, higher productivity and reduced emissions.

We also understand the importance of energy conservation, and to that end we include course work in energy conservation in our Power Engineering program. This is so important to us that we have taken a leadership role in the development of the new Energy Conservation and Advanced Manufacturing center at MATC. While I was on the MATC District Board, I served with local business leaders on the Steering Committee for the ECAM project.

Local 317 members are proud of our commitments to performance excellence, comprehensive power plant training, energy conservation, clean air and water, workplace diversity and family supporting employment. Today I speak from all of these perspectives in support of the proposed Air Quality Control System enhancements for Oak Creek South.

Conservation and renewable energy are important so that we can minimize the environmental impact of electric generation. We all need to continue these efforts. But the demand for base load electricity will continue to grow. As a region, we are working to attract and assist businesses that use electricity to operate the equipment needed for their manufacturing operations. Our ability to provide affordable, reliable, clean energy is therefore very important to the communities served by We Energies.

The new Air Quality Control System proposed for Oak Creek Power Plant will allow We Energies to fulfill the commitment to reduce emissions by more than 65 percent across their system. Without these controls, the Oak Creek units will be prematurely retired in the year 2012.

Oak Creek Units 5-8 produce 25% of We Energies electric generation. Shutting down the generating units at Oak Creek in 2012 will result in higher costs for electricity and stop-gap measures to meet increased demand.

Installing AQCS and continuing to operate Oak Creek Power Plant will save ratepayers over $600 million compared to alternative methods of meeting electrical demand in the years beyond 2012. These additional emission controls at Oak Creek will significantly help We Energies to control SO2, NOx, and mercury emissions.

Approving AQCS, and thus reducing emissions from the Oak Creek generating units, will postpone the need of the Public Service Commission to approve additional new base load construction, preserve employment and hold down rates. These improvements will help enable Oak Creek to continue providing electricity for the effective life span of these units that have served rate-payers so well over the years. This continued generation beyond 2012 will allow the PSC to wait approximately 10 years before needing to approve new construction. Technology advances will then provide generation alternatives that have less of an impact on the environment than current technologies.

It does not make sense to shut down the Oak Creek units prematurely. If the units are shut down, the PSC will be forced to decide on construction of new base load generation to replace this loss of generation. Rates will increase because the construction of new coal or gas plants will be more expensive than South Oak Creek. And family supporting jobs may be lost in the community.

We ask the Commission to approve the AQCS project because it is

Good for reliability.

Good for the environment.

Good for rate-payers.

And good for jobs.

Submitted by:

Mark Maierle

Business Manager

Local 317

International Union of Operating Engineers