It is improper for any person interested in a case before the commission to attempt to sway the judgment of the commission by undertaking, directly or indirectly, outside the hearing process to bring pressure or influence to bear upon the commission, its employees, or the presiding officer assigned to the proceedings.

The Alliance is not objecting here to  everything on the two Grain Belt websites.
It recognizes, for example, that it is perfectly acceptable for Grain Belt to provide  nonargumentative factual descriptions of the Line and its supporting towers; to include maps of the alternative routes of the Line; to provide information for potential suppliers of
component parts for the line; and to address any other matter which is not likely to be a
contested issue at the forthcoming  Commission hearings.

As is apparent from all of the above, Grain Belt has engaged and continues to engage in an elaborate PR campaign designed to sway public opinion on matters which it will litigate in the forthcoming Commission proceedings. Their campaign is extensive, it is expensive, and it is professionally managed in all of its various aspects. They have even incorporated Facebook and Twitter into their PR arsenal, and added links in their website to a number of video presentations.

For example, it its Application to the FERC for approvals regarding the proposed Line, Grain Belt refers to their video "that describes the need for the Project and how Grain Belt Express will bring significant economic benefit to states through much-needed transmission expansion for new wind energy projects .... " (Exh. 23, p. 8).

This description of the Grain Belt PR efforts is not intended in the pejorative sense at all. The Grain Belt publicity campaign is undoubtedly effective, and will no doubt accomplishing two of its principal goals: to sway public opinion on the Line in Grain Belt's favor, and to thereby convince members of the public to sign on to the computer-generated letters of support which Grain Belt will file with the Commission.

The letters may have no effect at all with the Commission. However, the ultimate impact of Grain Belt's efforts should not be the deciding question here. If Grain Belt has violated the Commission's ex parte rules, their conduct should not be excused by some sort of "no harm, no foul" escape clause.

We may never know how many people in Missouri were exposed to and influenced by Grain Belt's one-sided presentation on issues which they themselves will raise later at the Commission. Nor could the Alliance ever hope to present its own position to all of the people reached by Grain Belt. Grain Belt has been waging an extensive PR campaign for about four years, and will likely win that battle.

Just how Grain Belt has gone about doing so is illustrated in materials presented at a recent conference in Houston, where participants spent two days learning various techniques for "selling" a transmission project to the public.
A copy of the initial brochure for that  conference is attached here as Exhibit 18.
As noted on the first page, the conference was held this past January, and was to be hosted by Grain Belt's parent company- Clean Line. As noted at page 3 of that brochure, the keynote speaker at the conference was to be the Executive Vice-President of Clean Line.

According to the brochure, this is a sample of what those involved with building and siting transmission lines were to learn in Houston:

• How best to utilize social media to "engage the public", including who you can expect to reach, and how to go about doing it. (Exh. 18, p. 4) Not surprisingly, an expert in social media from Clean Line was to be one of the two speakers on this subject.
• How to deal with people disparagingly referred to as "NIMBYs" and "BANANAs". Ironically, the audience at that session was also told that a driving force behind the emergence of community-based opposition groups has been the push to build more infrastructure to support more renewable energy. (Exh. 18, p. 4).
• In "Marketing to Mayberry" the attendees would learn, among other things, how to talk down to people in small town, rural America, by communicating with them "in a conversational tone rather than corporate tone ... "  Presumably, these techniques were designed with the citizens of rural northern Missouri in mind.
• "How to frame and 'sell' infrastructure projects ... ", and how to use "effective
strategies and tactics, and share in critique of on-camera training ... "
• How to deal with the media, including:  "Getting into a reporter's head"; "How to answer questions you don't want to be asked"; and how to "position" your message to the media. (Exh. 18, p. 6)
• Finally, the Executive Vice President from Clean Line was to explain "how to ensure that our stakeholders feel they are informed and part of the process". (emphasis added). Apparently, it is not important to Clean Line that stakeholders actually be informed, or actually be involved in the process, so long as they are somehow made to feel that they are.

Rock Island wants this Commission to grant its requests for a CPCN and Section 8-­‐503 order despite, among other things, (i) not having any generation, or commitments for the development of generation, to connect to the western terminus of the proposed line; (ii) not yet having any commitments for shippers, or customers, to take service on the planned transmission line; (iii) not having commitments from any equity or debt
providers to construct the Project; (iv) and not having completed interconnection studies and agreements needed with MISO and PJM.

Many along the route worry that a private company could simply take over land that in some cases has been in families for generations.

"We have sacrificed everything for this land," said Jennifer Gatrel, 33, who, along with her husband, Jeff, farms a 430-acre cattle ranch in western Missouri. "We don't go on vacation. We don't go out to eat. Everything we have is tied up in this land. The idea that somebody can come in and take it from us is appalling and it goes against what it is to be an American."

Lawlor said the company prefers not to use eminent domain and wants to reach agreements with landowners. He also cited studies showing that power lines and towers have no effect on property values.

"When they sit down and talk to us and get the information about the reality of the project, I think we're succeeding in clearing the air," he said.

Not as far as Gatrel is concerned.

"There are already significant barriers to farming," Gatrel said. "This would be another major barrier."

In addition, if granted § 8-503 relief, what Rock Island characterizes as “voluntary” easement negotiations with farmers will actually sound something like “Rock Island has been directed by the Commission to construct a transmission line on an approve[d] route, which crosses your land.” Characterizing the easement negotiations as voluntary under these facts is kind of like giving someone the option of jumping off of a cliff before you push them.

The biggest hurdle for these projects is their intent to use eminent domain for pecuniary gain. Traditionally, utilities have been bestowed with eminent domain to build transmission for reliability reasons. But these "renewable" projects are not necessary for reliability or economic reasons -- they are solely an attempt to increase the percentage of "renewable" energy consumed in far-flung areas remote from the generator. And further, these particular "Clean" Line projects are an attempt to corner the market on "renewable" energy so that urban communities are precluded from developing local renewables. Instead of investing in our own communities, "Clean" Line proposes that we send all our energy dollars to midwestern states and into "Clean" Line's pockets. "Clean" Line has publicly stated that its transmission line will add considerable cost to the energy delivered and has provided no proof that the energy it proposes to transport will be economic or competitive with local renewables in the east. Stating that "Clean" Line will "drive down electricity costs" is disingenuous when "Clean" Line has no idea how much its delivered product will cost. It is just as likely that "Clean" Line will drive up electricity costs. "Clean" Line calls itself a merchant transmission company. A merchant transmission company depends on the free market to make itself competitive. "Clean" Line is depending on eminent domain to keep its cost of building the project down (cost of project shows up in the cost of delivered energy) and on renewable portfolio standards in other states to force utilities to purchase its product at any cost. In addition, this company has made noises about passing the cost of its project on to captive ratepayers, or using federal eminent domain authority to override state authority to site and permit its projects. Not the actions of a company depending on fair market competition for its success or failure! Right now, there is no market for "Clean" Line. There are no generators, and no purchase agreements. Opposition to "Clean" Line by affected communities and elected officials is increasing, and with each new opponent, the chance of success decreases just a little bit more.

From an environmental group perspective we're very interested and supportive of those lines if they're carrying wind power and clean renewable energy, as some of them are saying that they're doing.

Distributed generation, particularly solar, plays a vital role in terms of reliability, cleaning up the air and saving money for consumers. The efficiencies of solar panels are going up, the costs are coming down, and those entities that are getting behind it I think will be in good shape. People who are trying to stop the progress technologically when it comes to solar are going to be like the utilities that had landline telephones that tried to stop wireless telecommunications. It almost never works to stand in the way of technological progress.

Well, renewable energy wind power can bring costs down. Building new transmission of course passes costs on to consumers. Some of the transmissions being used for renewables, some of that transmission is being used for coal. So what you have to do is not look at it as one size fits all, but look at particular transmission lines and really say, No. 1, are the costs justified? Are the benefits greater than the costs, and therefore you can build a line? Or had the world changed in which a particular transmission line, and there are a number of lines that are being challenged on this basis, given the demand has gone down is there less need for the lines, they shouldn't be built? Secondly the question is is the line carrying renewable energy like wind power, or is it carrying coal and natural gas? The premise of what the Midwest independent system operator did is that these transmission lines, they call them the MVP lines, are supposed to be carrying wind power. Some of them do, some of them don't very much. And that's going to be an issue both before the regional commissions and also an issue before FERC.

The Rock Island Clean Line is one for-profit company proposing to ship wind power produced in western Iowa to the outskirts of Chicago. None of that power would stay in Iowa and a number of landowners along the proposed 500-mile-long transmission line route have opposed the plan. Some owners and farmers have expressed concerns about potential damage to land from transmission tower construction and the threat of eminent domain to push a route if enough willing sellers aren’t found.

 But Lang, and Mike Prior, interim director of the Iowa Wind Energy Association, hope the new organization could serve as a “go-between” to bridge some of the disagreements between land owners and the Clean Line developers.

A front group is an organization that purports to represent one agenda while in reality it serves some other party or interest whose sponsorship is hidden or rarely mentioned. [or denied!] The front group is perhaps the most easily recognized use of the third party propaganda technique.

Larson Shannahan Slifka Group (LS2group) is a bipartisan public relations, public affairs, and marketing firm that guides its practices with one goal in mind: what others may do, we strive to do better. We offer clients an unparalleled commitment to excellence and take pride in our consistent delivery of successful outcomes. Our strength lies in the diversity of our team and its determination to apply creative solutions and unique perspectives to clients' needs. We see possibilities others cannot and have a track record of helping our clients reach their goals.

"LS2group has a thorough understanding of our needs and responds quickly to our requests, coupled with a vast network of strong relationships with key officials."
- Cary K., Director of Development, Rock Island Clean Line

to promote social welfare by seeking to educate and encourage landowners to become familiar with wind energy production and transmission, and expand the wind industry in the state of Iowa to further the common good and general welfare of the people of Iowa and the Midwest.

no substantial part of the activities of the corporation shall be the carrying on of propaganda, or otherwise attempting to influence legislation, and the corporation shall not participate in, or intervene in (including the publishing or publication of statements) any political campaign on behalf of or in opposition to any candidate for public office

TVA is in final negotiations to allow a proposed $2 billion transmission line carrying wind power 700 miles from Oklahoma to connect to TVA's grid near Millington.

However, it will be another issue entirely whether Texas-based Plains & Eastern Clean Line LLC can send its wind-generated electricity into the TVA system, TVA spokesman Chris Stanley said Tuesday.

TVA policy requires the federal utility, which supplies electricity to MLGW in Memphis, only buy power priced competitively with other energy sources.

No consumer prices have been disclosed by the Houston firm.

"Inter-connectivity just allows Clean Line, in this case, to connect to our grid," Stanley said. "They do not, however, have the ability to inject any power into our system."

TVA is now waiting on Clean Line to request a "transmission study," he said.

"We had to do studies and make sure we have system reliability. That's all happened and we're in final negotiations with them about what that looks like going forward,'' Stanley said.

After the interconnection study is completed, a the transmission-service study will look at sending wind power into the electric grid.

But some people don't like the project, which is why the bill came forward. Landowners who are wary of eminent domain powers are speaking up against the project. In large part it has become an issue pitting pro-business groups and legislators against people who carry the NIMBY, or Not in My Backyard, mindframe.

Propagandists use the name-calling technique to incite fears or arouse positive prejudices with the intent that invoked fear (based on fearmongering tactics) or trust will encourage those that read, see or hear propaganda to construct a negative opinion, in respect to the former, or a positive opinion, with respect to the latter, about a person, group, or set of beliefs or ideas that the propagandist would wish the recipients to believe. The method is intended to provoke conclusions and actions about a matter apart from an impartial examinations of the facts of the matter. When this tactic is used instead of an argument, name-calling is thus a substitute for rational, fact-based arguments against an idea or belief, based upon its own merits, and becomes an argumentum ad hominem.

"In addition, if granted § 8-503 relief, what Rock Island characterizes as “voluntary” easement negotiations with farmers will actually sound something like “Rock Island has been directed by the Commission to construct a transmission line on an approve[d] route, which crosses your land.” Characterizing the easement negotiations as voluntary under these facts is kind of like giving someone the option of jumping off of a cliff before you push them."

The emergence of Microgrids for power generation could threaten the dominance of the age-old power distribution system in the U.S. Microgrids have evolved from simple power backup systems to small smart grids. The swift and cost effective installation of Micro grids could help distribute electricity among the masses. These rooftop solar systems meet the energy needs of the customers. In addition, the customers are allowed to sell excess power back to the utilities.
A report from American Society of Civil Engineers estimated that utilities need to spend $763 billion by 2040 to properly modernize and harden the existing grids against natural disasters. We believe that rather than going for a very costly maintenance, it will be economical to develop these Microgrids, which could lend support to the existing system.

A microgrid is a localized grouping of electricity generation, energy storage, and loads that normally operates connected to a traditional centralized grid (macrogrid). This single point of common coupling with the macrogrid can be disconnected. The microgrid can then function autonomously. Generation and loads in a microgrid are usually interconnected at low voltage. From the point of view of the grid operator, a connected microgrid can be controlled as if it were one entity.
Microgrid generation resources can include fuel cells, wind, solar, or other energy sources. The multiple dispersed generation sources and ability to isolate the microgrid from a larger network would provide highly reliable electric power. Produced heat from generation sources such as microturbines could be used for local process heating or space heating, allowing flexible trade off between the needs for heat and electric power.