Even though the Commission gave GBE a second chance to provide the additional information the Commission said it requires in order to make a decision in this case, GBE did not provide the requested information. Much of the requested information—for example, the RTO interconnection studies—will not be available for some time, perhaps years. And, GBE may never be able to get the required consents from all of the county commissions. GBE’s general attitude is summed up thusly: Trust us—we will give you the information only after you give us our CCN.

The Commission should not allow GBE to play this “which comes first—the chicken or the egg” game. Show Me recommends that the Commission deny GBE’s Application without prejudice. GBE is free to refile its Application after it obtains all of the relevant information and documentation that the law and this Commission require.

The Commission’s supplemental procedure should be scheduled with consideration given to the time that has already elapsed in this case. The Company filed its Application for a Certificate of Convenience and Necessity on March 26, 2014, over 12 months ago. Staff and other parties conducted extensive discovery regarding the Company’s Application, testimony, and schedules. The Commission held eight local public hearings, which occurred on August 12 and 14, and September 3 and 4. Three rounds of pre-filed testimony occurred, and the Commission conducted five days of evidentiary hearings (November 10, November 12-14, and November 21).

UFM recommends that the Commission reject the Grain Belt Express Response and deny Grain Belt Express’ application because the Commission misapplied its rules in its March 11 Order. The Commission’s order, therefore, was unlawful, arbitrary and capricious. Further, a review of the Grain Belt Express Response shows that there is very little additional relevant evidence to be adduced in additional proceedings. As a result, further proceedings would be inappropriate and a useless exercise. Finally, a review of the Grain Belt Express Response confirms UFM’s argument in its briefs previously filed in this case, that the proposed facilities are a private enterprise not devoted to the public convenience or necessity, and therefore are not qualified to receive a certificate of convenience and necessity.

Another initial point pertains to the information provided on the number of voluntary easements Grain Belt Express has obtained from landowners on the proposed route. According to Supplemental Exhibit 1 of Grain Belt Express’ Response, out of 724 tracts of land, Grain Belt Express has acquired only 45 easements voluntarily—about 6.2%. Grain Belt Express has been aggressively pursuing voluntary easements from landowners for a year. Given Grain Belt Express’ lack of success in convincing landowners that this is a good project for Missouri, granting Grain Belt Express the power of eminent domain would be inappropriate.

TVA analyzes historic and forecasted wind patterns to determine expected wind
deliveries at our system peak. Our forecasting and planning processes reflect
adjustment to wind generation at our summer peaks based on this analysis. Clean
Line has told us that a production profile provided by the independent meteorology
firm, 3Tier Oklahoma, shows that panhandle wind energy produces at about a 50
percent capacity factor between the hours of 4:00 p.m. and 7:00 p.m., thus
contributing to meeting peak demand. TVA's current wind resources produced
about 25 percent average capacity factor over that peak period last summer, with
significant variation each day (between 5 and 65 percent capacity factor). TVA will
take the seasonal and time-of-day energy patterns of wind into account when
evaluating adding additional wind energy to its portfolio.

Because wind is an intermittent resource that lacks some of the dispatch capability
of other resources, it does not eliminate the need for base load or dispatchable
power plants like nuclear, natural gas, coal and hydropower. Adding intermittent
generation resources like wind can be challenging to manage, particularly as the
volume of generation from those sources increases. Wind patterns are fairly
predictable, but not entirely so; in addition, weather and other factors can affect
output. To maintain reliability, a wind energy purchaser must keep adequate
capacity and spinning reserves to cover the variability inherent to wind. Spinning
reserve is typically calculated as the amount of capacity available to cover the loss of the largest generation source on the system. Utilities across the country have
been integrating more wind into their systems over the last several years, and TVA
already integrates 1,515 megawatts of off-system wind power. The industry has
growing experience with this issue, but it does make ensuring reliability more
complex.

TVA is studying the addition of new wind energy resources as part of the
development of its new Integrated Resource Plan (IRP). This process provides
opportunity for public participation. When TVA evaluates the cost of wind energy,
we include the value of the energy itself, as well as the cost to transmit out-of-valley
wind energy to the Tennessee Valley. In addition, there are costs associated with
the intermittent nature of wind generation. Through the IRP, TVA will rigorously compare wind energy purchases against other alternative sources of energy
(renewables, new and existing TVA generating assets, or purchased power) to serve local power companies and directly-served customers in a cost-effective manner.

"Grain Belt Express has not shown its project is the most cost-effective means of compliance with renewable energy standards in Missouri, as all but one of Missouri's investor owned utilities has already disclosed that it has existing capacity and new contracts that will meet or exceed the 15% renewable portfolio standard target by 2021."

Ten respondents submitted requests for service to deliver some 3,000 MW of power to Missouri, more than six times the available capacity at that delivery station, Lawler said.
“We have 500 MW going to Missouri, which is enough to power 500,000 Missouri homes,” he said. “The rest of it will go farther east, to Illinois and Indiana.”
“Originally we had it all going to Missouri, but the grid there is not robust enough to take full delivery, so we had to bust it up and make an additional delivery point.”

“In Missouri, we’re at the very tail-end of the regulatory process,” Lawler said. “We expect an order from the (Missouri Public Service Commission) in the next couple of months. There is no regulatory time frame (for approval) like there is in Kansas. We expect a decision in the first half of this year.”

Branstad, who appoints the members of the utilities board, warned against "political interference" into the administrative review process by which a pipeline carrying Bakken crude oil and a transmission line transporting wind-generated electricity could be approved.

"It would be mistake to get politics into this," Branstad said. "We should abide by the processes that have been put in place."

An outgoing member of the Iowa Utilities Board has bluntly told Gov. Terry Branstad in a letter that his decision to remove her is improper and being done to placate a powerful energy company.

Sheila Tipton told the governor in the March 18 letter that his move to replace her and demote board chairwoman Elizabeth Jacobs is an inappropriate attempt to influence future decisions to favor utilities and "appease MidAmerican Energy." The company had complained about a ruling requiring the company to use some proceeds from a $280 million wind energy investment to reduce customers' rates.

“Clean Line’s not asking everyone within the region to pay for the line,” Moore said. “That’s the piece that sometimes causes state utility commissioners to pause, because the commissioners haven’t seen this kind of truly competitive business plan before.”

“The more favorable decisions from commerce commissions, the more opposition will recede,” Moore said.

Clean line energy is apart of America's future. Many people came from other parts of the
nation to Morrilton, Arkansas to participate in a meeting about the project [name removed to protect the ignorant from public ridicule].
Many things have changed in Little Rock, Arkansas. The interstate and the airport were apart of Little Rock's future that required change. Some people had to relocate because of the expansion, airplanes come and go, and some people have to live with the noise.
Our company is near the airport and interstate. As Little Rock expanded we had to expand and we are now accustomed and familiar with change. We fully understand that change is a good thing when it is about improving our way of life, now and for future generations.

“If you keep trampling on the rights of ‘we the people’ you may have another American Revolution on your hands!"

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