Comments on the DOE
Informational Meeting –
DRAFT 2 Bob Henderson & Al Brooks – 7/25/06 DRAFT 2
This
critique comprises the reformatted contents of the DOE presentation slides each
accompanied by critical comments on the slides or external DOE information
related to the slide contents. The comments on a slide are roughly in the order
of the slide's bulleted items. Some of the comments are adapted from earlier
critiques which may be referenced by Internet link after a brief summary. These
earlier comments can be found on:
http://home.comcast.net/~brooks50/PensionPlanInformer.htm
(look in Informer Index).
This
critique focuses on the
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Slide 1 DEPARTMENT OF ENERGY CONTRACTOR PENSION AND MEDICAL BENEFITS POLICY |
Comments:
1) This meeting was a result of a request by CORRE to Congressmen Zach Wamp and a subsequent request and pressure applied to DOE by Mr. Wamp. The meeting had been preceded by several meetings between CORRE and local DOE or Contractor administrators and several exchanges of correspondence.
2) The original purpose of the meeting was to discuss the retirees concerns for the apparent reduction in ad hoc pension adjustments since 1984 when Union Carbide left and the resulting need for current adjustments
3) The discussion directly with the DOE Headquarters staff was deemed necessary due to the repeated statements that the responsibility for pension decisions had been transferred from local DOE staff and Contract administrators to Headquarters making it impossible for local administrators to answer retiree's questions. This was apparent in the meeting.
4) The presenter was Ms. Ingrid Kolb, Director, of the DOE/HQ Office of Management Dave Reichle, president of CORRE, gave the CORE response.
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Slide 2: AGENDA = Provide current
status of DOE Notice 351.1, Contractor Employee Pension and Medical Benefits
Policy = Provide overview of
key features of the Policy = Open forum – feedback on contractor employee pension and medical policy |
Comments:
1) The original topic of concern: the impact of inflation on the pension plan and lack of adequate COLAs seems to have been minimized in the agenda.
2) The timing of DOE N 351.1 seems to be a coincidence and this topic and the topic of the medical benefits policy was added by DOE as well as a review of the DOE-wide pension problems.
3) A discussion of N 351.1 and
DOE's larger problems tends to divert attention form the
3) The open forum did allow the retirees to voice their concerns and questions but there was little constructive discussion or interchange. The lack of DOE credibility was apparent.
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Slide
3: POLICY IMPLEMENTATION = DOE Notice 351.1, Contractor Employee and
Medical Benefits Policy, issued on = Implementation not later than = On = Provides opportunity to obtain views of stakeholders, including Members of Congress. |
Comments:
1) The description of DOE N351.1 was useful and
instructive but was quite adverse to the main retiree concern: the lack of
adequate ad hoc adjustments. In fact, N351.1, by denying reimbursement to the
contractors for any expense incurred for any future or potential improvement to
a current defined benefits pension plan, rang the death knell on any such plan
which did not already contain a contractual provision for periodic adjustments,
including the Oak Ridge Plans.
2) The replacement of defined benefit pension
plans by defined contribution (401k) plans is a relatively new topic for
3) The suspension of N351.1, as requested by
Sen. Peter Domenici (R-NM), for one year will be a welcome move if the time is
used to seriously obtain the retirees' views. This meeting did not do so; it,
like the agenda and slides indicate told the retirees what the future would be
and then asked for and largely ignored their concerns. It was not apparent that
the concerns were even being captured for future consideration.
4) The members of representatives of the members
of congress and candidates were quite vocal in their support of the retirees and,
I believe got their eyes opened. The Tennessee Senators were not present or
represented.
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Slide
4: BACKGROUND DOE reimburses the allowable costs of
Contractor pension programs and other post-retirement benefits (PRBs), including medical benefits, through 46 M&O and
other site operating contracts: |
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Major Plan
Distribution = 3 Defined Benefit
Plans = 23 Defined Benefit
Plans supplemented by Defined Contribution Plans = 7 Defined
Contribution Plans > 100 Medical Benefit Plans |
Personnel Covered = 100,000 Active
Employees = 57,000 Retirees = 46,000 (approx)
Retiree
Beneficiaries/Dependents |
Comments
1) While this slide shows the complexity of the
DOE Contractor retirement systems, it does not show the wide variability in
their nature, status or provisions. It is in the comparison of these details
that the
2) The details behind this slide are not made
avail to the retirees.
3) The slide did little but to convince the
public that DOE has created a problem and is sacrificing the
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Slide
5: FINANCIAL IMPACT OF CONTRACTOR DEFINED BENEFIT PENSION AND PRB PLANS = DOE contributions to
Contractor defined benefit and medical plans: = FY 2006 Projection
--$784M = Increase since FY
2000 – 198 percent = DOE contributions to
Contractor defined contribution plans: = FY 2006 --$219M = Total FY 2006
contributions are just over $1 Billion which equals 1 out of every 23 dollars
spent by the Department = Accrued Unfunded
Liability (represents current financial exposure as indicated on DOE’s
financial statement) = FY 2005 --$11.6B = Increase since FY
2000 – 63 percent |
Comments:
1) This slide also supported the contention that
DOE administers several benefit plans and experiences increasing costs (along
with all other employers)
2) These claims are undoubtedly true but merging
the costs of Pension Plans and medical plans covers up the individual costs and
hides the primary cause of the problems: inflating medical costs. DOE ignored
the retirees' comments.
3) While DOE undoubtedly made large
contributions to defined contribution plans and trust funds, they have not made
a contribution since 1984 to the Oak Ridge Pension Trust Fund. Rather they are
reducing the benefits at every opportunity to prevent such additions.
4) One out of twenty three billion sounds big
but what does it mean when realistically compared to the costs of other
agencies and businesses. Less than 5% really sounds rather small for a major
expense. How do we really compare with others?
5) An unfunded balance of $11.6 billion may
sound large but it includes both pensions and medical liabilities and is MOSTLY
medical. Pensions are not the big growing cost problem. The important fact for
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Slide 6: DEPARTMENT OF ENERGY BUDGET ($
Billions) Enacted
FY 2000-2006 **
Requested FY 2007 *
Forecast FY 2008-2011 |
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2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 |
18.0 20.0 21.5 22.4 23.5 24.6 23.5 23.5** 23.5* 23.8* 24.1* 24.6* |
Comments:
1) This slide (originally a graph) shows the DOE
total budget from 2001 to 2011 (* projected). It does show a flat budget from
2004 to 2011 but
2) Further some of this data is in the proposal
stage: Why doesn't DOE propose enough to pay a decent pension to
3) In a government agency, the criteria should
not be a rising or fixed budget but : Is the agency
fully meeting its responsibilities? Are the activities being carried out
efficiently and in a timely manner? And, does the agencys
policies lead to a stable and reasonable future?
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Slide
7: POLICY OBJECTIVES = Ensure fairness to
incumbent contractor employees and retirees. = Improve stewardship
of taxpayer dollars by: = Limiting expected
cost growth associated with benefit liabilities. = Moderating the
volatility and improving the predictability of the Department’s cost
reimbursement obligations. = Ensuring that costs
for contractor employee pension and medical benefits are more consistent with
market trends. = Providing direction
on the treatment of contractor post-retirement benefits at closure sites. |
Comments
1) Someplace there is a new definition of fair
which I failed to learn. I don't believe that anyone can convince me that
cutting a retiree's buying power by a factor of five over thirty years is fair.
Certainly not someone who will get an automatic COLA every
year.
2) The
3) The policy changes will certainly reduce the
volatility if DOE's obligations by transferring them to the individual who must
then depend on the investment market. I remember 1929.
4) Predictability! God, that the retirees'
economic future should be sacrificed because DOE can't predict the future of
the economic system. When a government starts sacrificing its citizens due to
its incompetence, then we are all doomed.
5) "Market trends" is meaningless to a
congressional funded agency and is a euphemism for "Pass all the risk and
responsibility to the individual". This just passes the increase in cost
to someone else; it does nothing to control medical costs and the cost of living.
6) The directions for the retirees seem to be:
Turn right at retirement and go to the poorhouse. I can't believe that this is
my government doing this to me.
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Slide
8: PENSION BENEFIT POLICY Incumbent
Employees = Continue to reimburse
Contractors for allowable costs associated with existing pension benefit
plans for incumbent contractor employees. = Reimburse the costs
for Contractors to provide a one-time option for participating incumbent
contractor employees to transfer to a new market-based plan. = Continue to reimburse
Contractors for allowable costs associated with pension benefits provided
under collective bargaining agreements. New
Employees = Reimburse Contractors
for the allowable costs of pension plans that are consistent with current
market trends (defined contribution plans) for new contractor employees. = Consider as an
unallowable cost, the participation of a new employee in an existing defined
benefit plan by a date certain to be negotiated with Contractors, but no
later than Applicable
to Incumbent and New Employees = Disallow Contractor
requested pension plan benefit augmentations which may increase liabilities,
including subsidized early retirement benefits and lump sum pension
distributions, unless required by law or approved by the Secretary. |
Comments
1) DOE by not defining what these costs are and
exactly who benefits from them, continually sweeps the Oak Ridge pension
problem under the rug: The retires, new or old, have no right to an ad hoc COLA
unless it is specified in a negotiated contract. One must read the N351.1, the
DOE Orders 350.1 and any applicable contracts (collective bargaining
agreements) to fully understand the import of the N 351.1 policy changes. One
must also be aware of what these documents do not say: they do not establish
the right to any cost of living adjustments for salaried employees.
2) Market based again means a 401k type, defined
contribution plan, passing the risk and responsibility to the individual. This
is the administration's plan for social security and other pensions which the
Congress has rejected.
3) This reimbursement policy accomplishes by
indirection that which DOE avoids to direct – but this is the death knell of
the classical pension.
4) "Disallowing Contractor requested
pension plan benefit augmentations" is another euphemism for '"no
more adjustments or improvements of any kind." DOE N 351.1 is rather
definitive on this point and if anyone believes that the Secretary will be
generous on this point, I have a bridge up in
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Slide
9: MEDICAL BENEFIT POLICY Incumbent
employees = Continue to reimburse
allowable costs for existing Contractor medical benefit plans as required in
specific contract terms and conditions. = Continue to reimburse
Contractors for allowable costs associated with medical benefits provided
under collective bargaining agreements. New
Employees = Limit cost
reimbursement to market-based medical benefit plans or participation in
non-market based medical plans if new enrollees share the costs so that the
benefits are market-based. = Determine as
unallowable the costs associated with new enrollees in existing
non-market-based contractor medical plans unless the new enrollees share in
the costs so the benefits are market-based. Applicable
to Incumbent and New Employees = Disallow Contractor
requested benefit augmentations to existing plans unless required by law or
approved by the Secretary. |
Comments:
1) I can't find anyone with an enforceable
contract except the various unions collective bargaining agreements. Just
because Carbide gave ad hoc adjustments didn't establish a contractual
relationship.
2)
Market based again means a 401k type, defined contribution plan, passing the
risk and responsibility to the individual.
3) Again, "disallowing" is a not too
subtle way of directing the contractors not to do something. Several members of
congress have said DOE is starting to micromanage their contractors.
4) This slide makes it pretty clear that new
employees have no choice; it's market-based or nothing.
5) The last bullet makes it pretty clear that
you go along with the DOE way or you'll have a tough time of it.
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Slide
10: PENSION AND MEDICAL BENEFITS POLICY FOR CLOSURE SITES = When feasible, budget
annually to reduce pension plan under-funding at an accelerated rate prior to
closure. = When feasible, settle
pension liability with Contractor at or near closure. = Where appropriated
funds are not available for settlement at closure, Contractor remains
sponsor, but, with DOE approval, may transfer to a corporate relative pending
settlement or otherwise continue plan administration and management in
accordance with contract terms. = Continue to reimburse
the Contractor until the obligation can be settled. = Analyze feasible
alternatives to provide long-term Contractor medical benefit coverage. |
Comments:
1)
2) One way to reduce liabilities is to reduce
them to zero.
3) It looks as though medical costs are
definitely on the chopping block also.
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Slide
11: POLICY IMPACT Federal
Government and the Department of Energy = Ensures fairness to
incumbent contractor employees and retirees. = Improves stewardship
of taxpayer dollars. Department
of Energy Affected Contractors = Supports efforts to
recruit and retain a highly qualified workforce. = No impact on existing
collective bargaining agreements. Incumbent
Contractor Employees = Provides continuity
in pension and medical benefits pursuant to existing policy as implemented in
specific contract terms and conditions. = Provides a one-time
option to transfer to a pension plan that offers portability. New
Contractor Employees = Provides competitive
pension and medical benefits. = Provides pension
portability. |
Comments:
1)
When DOE reduces its liability and avoids the volatility of future costs some
one else must take over the job. Certainly the Contractor can't be expected to
do it unless they are reimbursed; and that seems unlikely. Therefore it must
fall to the individual who had better successfully saved the money and made
good investments or do without the medical care or go on welfare. All three
will probably happen.
2)
I heartily approve of "taxpayer dollar" stewardship though I'm not
sure if I like my pension cut so the rich men can have tax cuts. Somebody needs
to explain stewardship (and equity) to
3) It nice to know that DOE will conform to
contract law but many retirees don't have a contract. I hope DOE will also
comport with human decency.
4) This one time option may be transfer to a
plan that is unproven and may be a blooper.
5) Competitive to what: Other plans with decreasing
benefits.
6) Hopefully. There's something to port.
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Slide
12: Current:
= Bechtel Jacobs
Company LLC: Bechtel Jacobs Company LLC Pension Plan for Grandfathered
Employees = BWXT-Y12,
LLC/UT-Battelle, LLC: Retirement Program Plan for Employees of Certain
Employers at the = Wackenhut Services,
Inc. - |
Comments:
1) While it is valuable to know that there are
new participants in the plan, it is not clear that it is all one plan with equal
benefits for all.
2) The slides raise several questions about the
plans actual structure: a) Is there one plan or five
plans and one trust fund? b) How does a single plan deal with collective
bargaining agreements for the union workers and none for the non-union workers?
c) Did the newcomers bring trust funding or not? d) Where are the K-25 retirees
and who represents them? d) How do the advisory committees function and how
many are there?
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Slide 13: = Contractors are the
employers and sponsors of all of the pension plans. = DOE is contractually obligated
to reimburse the Contractor for allowable costs subject to appropriations. = One of the three
Contractor Plans is currently fully funded based on ERISA requirements
without DOE contributions. = All three of the
Contractor Plans are able to meet existing promises to pay beneficiaries. |
Comments
1)
Here are answers to some of but not all of the previous questions and they
raise even more questions.
2) If contractors are employers and sponsors,
why have the responsibility and initiative been transferred to Headquarters and
local suggestions for plan improvements been effectively prohibited by
"non-reimbursable" proclamations?
3) How can any contractor risk committing any
plan to any future obligation if reimbursement is dependent on future congressional
appropriation? It would seem that DOE is avoiding all future commitments unless
they issue contracts to ALL employees.
4) Does the whole federal pension system rest on
such a flimsy and whimsical basis such that DOE can without consulting change
it? I think NOT.
5) It seems there are three contractor plans
(one fully funded) and all of which can meet existing promises (even if not
fully funded and dependent on the DOE budget requests and the further vagaries
of congress.). What does "funded" and "under-funded" really
mean?
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Slide
14: HOW OAK RIDGE MULTIPLE EMPLOYER PENSION PLANS RANK – 2004 = Hourly Employees* = ORNL - Retirement
benefits rank 10th out of 31 DOE Contractor pension plans with 99.9% salary
retained upon retirement = Y-12 – Retirement
benefits rank 9th out of 31 DOE Contractor pension plans with 100% salary
retained upon retirement = Bechtel Jacobs
--Retirement benefits rank 11th out of 31 DOE Contractor pension plans with
99.2% salary retained upon retirement = Salaried Employees* = ORNL - Retirement
benefits rank 11th out of 28 DOE Contractor pension plans with 93.4% salary retained
upon retirement = Y-12 – Retirement
benefits rank 9th out of 28 DOE Contractor pension plans with 93.5% salary
retained upon retirement = Bechtel Jacobs –
Retirement benefits rank 8th out of 28 DOE Contractor pension plans with
94.4% salary retained upon retirement = Federal Employees** = By comparison, the
average retirement benefit for Federal employees covered by the Civil Service
Retirement System is 66% of their final salary. *Assumes
retirement at age 65 years of age with 35 years of service, social security
benefits and maximum employer contributions to defined contribution plans. **Based
on retirement after 35 years of service at age 65. Federal employees do not
earn Social Security credits for CSRS-covered employment. |
Comments
1)
This slide contains the crux of the pension plan problems. It is based on
ill-defined computations which DOE uses to qualify the pension plan as
"generous" and also to manage the pension plans. Similar computations
are contained as charts in correspondence from DOE headquarters and in the BenVal report.
2)
The DOE casual descriptions of the computation vary with the source of the
description. In addition, DOE chooses the comparison list and some valid
comparisons are not permitted. To-date, DOE has refused to reveal the details
of the computations which in itself should disqualify them as acceptable
measures of pension plan performance.
3) Even more unfortunate is that from the
sketchy description given, the computations contain: a) a fundamental error in
algebra, b) an error in the pension plan model, c) assumptions so far from
reality as to be gross errors, and d) differences of opinion as to the model
for and the descriptor of the pension. The most grievous failure of the
model may be that the computation is made solely at the time of retirement and
it cannot possibly reflect the performance of the pension benefit with passing
time and inflation.
4) The computations involve the addition of the
monthly pension payment (see assumptions): a monthly social security payment
and the "maximum employer contributions to defined contribution
plans". This is a suspect operation, How can a defined benefit savings
program be included in the pension benefit and also be claimed as a outstanding benefit by itself? You shouldn't count it
twice.
5) The fundamental error in algebra is
the addition of monthly salaries to a lump sum of money. The units are
different, $/month and $, making it an illegal algebraic operation and the
result has no rational meaning. If this error is one of improper description
then the question of how the lump sum is annualized remains unanswered.
6) The error in the pension plan model is
that the computation is made immediately after retirement and can not possibly
show the behavior of the pension after 30 years of inflation, about an 80%
reduction in buying power.
7) The first assumption so far from reality
as to be a gross error is the assumption of 100 % participation in the
defined benefits plan when the empirical studies show that the figure is close
to 6%. A second one is that everyone works until age 65; the SSA says it's only
38%. A third error is that the multiplier is 1.4 % where for most retirees the
multiplier is 1.2 %. Errors of this magnitude invalidate models.
8) The differences of opinion as to the model
for and the descriptor of the pension comprise: a) the validity of
including the defined compensation program in a pension benefit, b) the
validity of dividing the pension benefit by the terminal wages removing any
evidence of low salaries and hence low pensions, and c) describing a pension
plan which lies close to the average as "generous".
9) It is the intent of DOE to have the above BenVal ratios lie in the range of 95-105%. Currently, the
following ratios are known:
9) The Federal Employees Retirement System
clearly states that the Social Security Benefits the Basic Benefit Plan and the
Thrift Savings Plan are a part of the pension system and must be considered
jointly. This has not been true of the Oak Ridge Savings plan. It is not clear
how this slide treats the federal pension systems but neither the FERS or the
Civil Service Retirement system seem to be well fitted by this model. However
they do have periodic COLAs.
10) The failure of DOE to obtain and use a
computational model reasonably acceptable to the retirees is a point of
distrust to the retirees. It would have been so simple to have given an
accurate description of what was done. It is openness that prevents major
errors. It is also distressing that the conclusions of this slide are used to
inform legislators that the pension benefits are "generous'" and it
is never clear if the legislatures have the opposing critique of the claims.
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Slide
15: REQUESTS FROM = Ad Hoc increase in
pension benefits for all retirees that will restore at least 75% of the loss
in value of pensions due to cost of living increases = Contractors’ estimated
long-term liability --$95.4M = Flat-rate reduction
factor of 2 percent for retirees who have chosen the surviving spouse option = Contractors’
estimated long-term liability --$51.3M *Source:
CORRE’s 2006 Position Paper: A Statement of
Proposed Changes in Pension Benefits for 2006 |
Comments
1)
This slide accurately portrays the CORRE requests as far as it goes. It avoids
discussing the reason for the flat-rate reduction (current equity) and makes no
mention that DOE has made no payments to the pension fund since 1984.
2)
It does not reveal what the net cost to DOE will be after the existing fund
surplus is committed to these improvements.
3) Nor does it discuss why NOT making new
payments to the trust fund is to be avoided at any cost (to the retirees).
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Slide 16: RETIREE BENEFIT INCREASES |
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Date |
Description |
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1969
1973
1975
1977
1980
1987
1992
2001
2004
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Retiree ad hoc increase Retiree ad hoc increase Retiree ad hoc increase Retiree ad hoc increase Retiree ad hoc increase Retiree ad hoc increase Retiree ad hoc increase Retiree ad hoc increase $600/400 Minimum |
Comments:
1)
This is a very revealing slide, in what it doesn't say.
2)
The last adjustment was proposed by CORRE and affected very few retirees
although it was badly needed by them.
3)
The other adjustments were severely limited by caps and recent retiree
exclusions; many retirees did not receive an increase. Unstated caps and recent
retiree exclusions can result in retirees completely missing out on several of
what appear to be reasonable ad hoc adjustments.
4) The increases did NOT keep up with the cost
of living and this slide completely avoids any quantitative discussion of its
impacts or lack of them.
5) Union Carbide left in 1984 and initiated all
increases through 1987. CORRE initiated the increase in 2001.
6) Only one ad hoc increase was initiated by a
contractor since Carbide left. This new policy of N351.1 will preclude any
increases of any kind for the current retirees and vested employees who are in
the current plan.
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Slide
17: CHALLENGES AND CONCERNS = Increased pressure on
appropriations and budget. = DOE’s FY 2006 budget
is $23.6 Billion and is expected to remain relatively flat through FY 2011. = Spiraling costs mean
less money to achieve DOE’s mission (e.g., environmental cleanup at former
nuclear weapons sites and advanced scientific research). = Plan assets may not
be sufficient to cover cost of proposed ad hoc increase resulting in greater
liabilities and possible plan contributions. |
Comments:
1)
The cost of doing business in the entire world has risen steadily during the last
sixty years. Why implement Draconian practices affecting a minority group of
old employees who can do little to avoid their disaster?
2)
Budgets are flat either because DOE didn't ask for more funds or congress did
not approve more. In either case, it is a conscious decision not to support a
decent pension for the retirees.
3) One of DOE's missions by stated policy is to
supply funds for a decent pension for retirees. This includes explaining the
problem to congress and requesting adequate funds. This is not accomplished by
fallacious computations and the use of overly flattering adjectives to describe
the pension plans.
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Overall Comments
1) There is absolutely nothing in the slides to establish there is equity among the pension plans at the several DOE sites.
2) The DOE arguments for the high quality of the
3) Throughout the slides there is an objective to NOT make any new
payments to the
4) The undercurrent that DOE should adopt "market-based" or "market competitive" benefit plans totally avoids a discussion that DOE is not a market-based enterprise subject to market pressures but is rather a government agency funded by congress. Profit and loss are not legitimate factors in the competitive market sense. Granted some corporations are seeking to shed their pension obligations but they are also facing bankruptcy, i.e., are financial failures. Are we to believe that our government is also a financial failure? Even when the administration assures us the economy is strong?
5) The slides give no indication that the moves toward defined contribution pension plans are closely related to the administration's intention to likewise change social security, industrial pensions and medical benefits. This DOE action is being watched with great interest by the political, corporate and labor union world. We are a small frog in a big pond. Frogs get ahead by kicking!!
6) The slides raise questions about the trust fund: Exactly what are its
terms? A trust is usually thought of a collection of assets supplied by a
grantor, held and managed by a trustee for a specified benefit to a specified
grantee or beneficiary. Federal laws and rules also control pension trusts. The
questions are: Who is the trustee? How do new groups of retirees leave or join
the beneficiaries? Some at
7) Again, it seems disingenuous that the slides purport to give the retirees concerns before they were expressed as well as give the conclusions prior to receiving any suggestions. It looks like snake oil to the commenter.
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