November 28, 2017
DeWitt Burleson, TVARA Valley Wide President
TVARA Board Directors
TVARA Chapter Officers
Dear Mr. Burleson, Directors, and Chapter Officers,
Few have recognized just how underfunded TVARS has become and that
your TVARS benefits have already eroded. This was brought about by inadequate
TVARS funding requests and TVA under-funding over the last 10 years. TVA
planning does not fully recognize the need for adequate annual TVARS retirement
funding. Without adequate funding requests and a TVA catch-up plan, we both fear
and anticipate additional cuts. Most at risk are long term TVA employees and
retirees who depend on a pension.
A TVARS Board Member’s job is to clearly represent funding needs
and the benefits required for all members, not just a specific group. We are asking
whether retirees support the priorities in this plan. Broadly stated these
priorities fall into two groups, governance and funding. Current governance allowed
the funding to fall to 53% without sounding an alarm. It took an independent
GAO report to clearly state the funding level and make recommendations. Now
that we have that report it is time to address both the governance issues and
funding. We believe funding cannot be successful without governance
improvements and funding requests which are accurate.
In the last 19 months, the TVARS Board approved reducing your
future TVARS benefits by $960 million to close this gap. Even after this
reduction, the shortfall was $6.0 billion from an actuarial need of $13.1
billion for a funded ratio of 54%. After the GAO report, TVA made a
“pre-payment” this year which decreased the shortfall to $4.6 billion for a
funded ratio of 63%. We believe a “pre-payment” is not a plan.
The cornerstone of our plan is to have the retiree TVARS director
(7th member) be elected by retirees. Please see below for more
details on our 5 Point TVARS 2018 Accountability Improvement Plan (AIP).
As stated in the most
recent TVARS director’s campaign statement:
Underfunding retirement
is interest-free borrowing from you. I support the GAO recommendations and will
work to develop accurate, best practice funding and reporting for TVARS. Help
us have a retirement system that is there for us and those we love.
Funding issues require
three votes to be put on the Board Agenda, and four votes for approval. You
haven’t had those votes. Benefits without advocates go away. Benefits
matter when you were hired, employed, and when you retire. Keep your benefits.
“The workman is worthy of his hire”.
Time is short. The next
term for the 7th member begins this coming October. In order to
create a retiree elected 7th member, we believe a new retiree board director
election plan must be in place by March 2018. If you agree that a retiree
elected board director will help your voice be heard, you need to lobby the TVA
and current retiree 7th member board directors to vote for a rule
change to make the election of the 7th member happen.
We believe your support will be critical. Please help us obtain
comments on this plan. We recommend discussions at your next TVARA meetings and
we look forward to your comments. We hope to make TVARS better for all
employees and retirees.
Sincerely,
Sam DeLay, TVARS Board Director
Jim Hovious, TVARS Board Director
Leonard Muzyn, TVARS Board Director
5 Point TVARS 2018 Accountability Improvement Plan (AIP)
1)
Amend the rules regarding
the retiree TVARS Board Director (7th member) to:
a. Call for an election for the term beginning
November 1, 2018. Similar to the nominating and election process for the
current employee directors, nominations are to be made by petitions signed by
at least 25 retiree members. All retiree members are to be eligible for
nomination and to vote.
b. Ensure that there is no appearance of conflict
of interest. As with the employee elected directors, the retiree director shall
receive only reimbursement of travel expenses from TVARS. The practice of
paying the retiree director an additional $10,000 per year for service on the
TVARS board from the pension fund will be discontinued. The retiree director
shall also be prohibited from contracting with, or having other financial
relationships with, TVARS or TVA during their term, as well as for a period
afterwards.
2)
TVARS to use the discount
rate currently used by the GAO, TVA, and TVA’s actuary in its financial
reporting to avoid confusion of reporting under two different accounting
methods, and to give a more realistic picture of the financial health of the
System.
3)
TVARS to follow the
recommendations in the March 2017 GAO report with regards to properly funding
TVARS:
a.
“According to TVA’s
analysis, there is a 50 percent chance that annual contributions of $300
million could eliminate the $6 billion funding shortfall at the end of 20 years
and a 50 percent chance that a funding shortfall would remain. TVA’s analysis
assumes an annual return of 7 percent on pension plan assets, but depending on
market conditions, assets could yield higher or lower than expected returns”
b.
“TVA aims to eliminate
its $6 billion in unfunded pension liabilities within 20 years, according to
TVA officials, but no mechanism is in place to ensure TVA fully funds the
liabilities if, for example, plan assets do not achieve expected returns.”
c.
“TVA officials told us
that the agency does not plan to contribute more than the TVARS Rules require
and that it plans to continue to treat its unfunded pension liabilities as
regulatory assets, deferring pension costs for recovery through rates in the
future. However, the TVARS Rules do not provide for fully funding pension
benefits over the service of TVA employees covered by the plan…”
d.
“A Blue Ribbon Panel
commissioned by the Society of Actuaries believes that plans’ risk management
practices and their ability to respond to changing economic and market
conditions would be enhanced through the use of amortization periods shorter
than the 30-year period commonly used today. The panel recommended amortization
periods of no more than 15 to 20 years for gains and losses.”
e.
“In the private sector,
ERISA generally requires a 7-year amortization of shortfalls for private sector
single employer pension plans.”
f.
“The open amortization
period utilized by the TVARS formula-based contribution requirement does not
ensure TVA’s contributions will adequately adjust for plan experience and does
not ensure full funding of the pension liabilities.”
g.
“…a closed amortization
period would be a better practice if the goal is to fully fund pension
liabilities.”
4)
TVARS meetings to be open
to the public so that interested retirees may attend and see for themselves
what TVARS is considering and the reasoning behind each director's vote.
5)
Amend the rules so that
only TVA employees who are not covered by the Supplemental Executive Retirement
Plan be allowed to sit on the TVARS Board as fair representatives for thousands
of non-executive employees.
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