Enhance federal government permitting authority for interstate electric transmission facilities that have been determined by the Secretary of Energy to be in the national interest.

Replace DOE’s national interest electric transmission corridor process with a national interest determination by the Secretary of Energy that allows FERC to issue a construction permit.

Require FERC to ensure costs for transmission projects are allocated to customers that benefit.

Allow FERC to approve payments from utilities to jurisdictions impacted by a transmission project.

These arrogant greedsters will continue to push their narrative that only a boot on the neck of rural America can usher in a renewable energy future.  Instead of working with rural America to find a solution, these folks continue to push for more authority to simply take what they want.

At a recent Australian energy conference, the program indicates that the energy industry is acutely aware of, and concerned about, the urgent need to develop trust and acquire social licence for transmission. So much so that a panel discussion specifically focussed on the best ways to combat anti-transmission line sentiment. The panel included key industry representatives from the Victorian Department of Environment, Land, Water and Planning (DELWP), the Australian Energy Infrastructure Commissioner, AusNet Services, Powerlink Queensland, Nous Group and CutlerMerz.

Interestingly, the panel did not include members of the public, representatives from community advocacy bodies or community groups calling for better transmission planning and framework reform.

This raises an important question; how can anti-transmission sentiment be truly understood by the industry if those representing the Australian public are not involved in the discussion? The lack of public inclusion in forums such as this suggests there is still much work to be done in understanding best practice engagement principles.

Firstly, communities are not upset that their concerns haven't been heard as there is no doubt opposition has been voiced. Communities are upset because their concerns are not being understood, listened to or respected, with collaborative action being taken to understand and accommodate this opposition to bring about a more mutually beneficial outcome. There is a significant difference between being heard and being understood. Communication is not simply about the transmission of information; it is about the reception and understanding of it. Genuine engagement is then demonstrated by taking meaningful, constructive and collaborative action.

Secondly, in the case of the WVTNP, there are no foreseeable benefits to communities expected to carry the burden of 190km of overhead transmission. How can the industry better sell the benefits to host landholders and neighbouring communities when there are no benefits to sell?

The energy industry and governments can do more to understand and appreciate that community benefits and compensation may not be the quick-fix solutions they hoped they might be. In fact, pushing the ‘talk to them early and pay them more’ agenda is very likely to further dilute trust, increase opposition and dissolve any credible opportunity to acquire social licence. Without empathy in the social licence and public policy equation, it will be near to impossible to develop trust for transmission.

Empathy is the ability to emotionally understand what other people feel, see things from their point of view, and imagine yourself in their place. Essentially, it is putting yourself in someone else's position and feeling what they are feeling. The ability to feel empathy allows people to "walk a mile in another's shoes". It permits people to understand the emotions that others are feeling.

The admonition to walk a mile in someone else's shoes means before judging someone, you must understand his/her experiences, challenges, thought processes, etc. Truly listening to another persons view creates empathy, something that community sentiment suggests is lacking within the energy industry.

It’s not difficult to understand why it may be challenging for the energy industry to demonstrate empathy. For decades, its has been insulated from the need to consider social or environmental externalities and has rarely had to meaningfully engage with, or have empathy for landowners and communities.

Empathy helps develop trust; therefore, it is important that transmission network planners and policy makers spend time to consider, understand and respect landowner and public perspectives, experiences, and motivations before making a judgment about them and asking rural communities to shoulder the burden of overhead transmission for the benefit of the masses. Economic benefits, community benefits, compensation, the climate, environment, emissions, jobs, and green energy, are often wielded by governments and the industry to garner public support for overhead transmission. While there may be truth in some of these benefits, many in the community view this strategy as an intentional attempt to reduce credible objections to those of NIMBYism (Not in my backyard). For many, this strategy demonstrates a concerning lack of empathy as to why overhead transmission projects are being objected to in the first place.

In addition to legitimacy, credibility and trust, empathy should be added to the list of social licence components. Without empathy, it is impossible for the other three components to exists. Without empathy, it will be challenging to garner community support. To develop empathy, it is necessary to first explore the deeper reasons for objection to offer these objections the respect and attention they deserve.

When discussing compensation and engagement with potentially impacted landowners throughout the eastern states of Australia, many have indicated, in no uncertain terms;

‘I'll never sell'; 'We will not be bought off'; 'No amount of money will compensate for the impact on our properties, community and environment'; 'We will not risk our kid's inheritance'; 'Our land is our superannuation, we will not sacrifice that'; ‘This is our livelihood, who has the right to take that away.

When speaking with stakeholders in the energy industry and those living in more urbanised environments, reactions suggest a level of confusion. Comments often conveyed indicate it’s difficult to comprehend why people would not accept payment for the burden they are expected to carry.

'They are only transmission lines'; 'We drive past them every day to work, what's the issue'; 'This is the price we must all pay for progress and to reduce our impact on the climate'; 'Transmission towers remind me of our engineering mastery'; 'It's only farmland, plant your potatoes somewhere else'.

To understand this, we need to dig a lot deeper than early engagement and financial motivation. We need to understand the connection between people, the environment, the land, and rural areas. We need to understand the person-place interaction that leads to attachment to place. This connection to place is experienced by traditional owners, landowners, neighbours, and visitors alike. The strength of this attachment often surfaces under threat of loss of place.

Family farms are a unique institution, continuing through time in a world where considerations of hard work, long-term thinking and commitment are often sparse. Families in agriculture have long provided a steady backbone to rural Australia, serving as stewards of our natural resources and taking care of the neighbours, communities and environments in which they live. Because of their dedication to preserving farm operations and improving land for native wildlife, farm families are very emotionally close to their way of life and to the land on which they live. Many see themselves as temporary stewards of their land, managing it for future generations, just as their great-great-grandfather might have done for them.

A statement by one landholder was, “I don't have a sense that I own it as such. But I've been given the privilege to influence it, to protect it, to enhance it and among other things – stop other people influencing it, without me giving them permission."

It’s also important to note that a cost seen by some, is viewed as an investment by others. Communities impacted by proposed overhead transmission projects argue that despite potential increase in capital by avoiding a shorter more impactful route, use of existing easements, longer least-impact routes or an investment in undergrounding (particularly HVDC), is a long-term economically viable investment in achieving climate change objectives, protecting our environment, avoiding land use conflict, and providing increased redundancy, resilience and reliability to our transmission networks. Despite the increased cost, Star of the South, a private development, is undergrounding its transmission to minimise the environmental impacts. This has been well received by potentially impacted communities.

On March 17, 2021, MISO laid out its initial roadmap for LRTP transmission solutions based on the Futures analysis. The initial roadmap included a proposed line from central Iowa, through northern Missouri, with two offshoots further south into Missouri with one in a similar area as the proposed Point(s) of Connection for the GBX Line, and finally into central Illinois.
 
It was announced during that meeting that the analysis had been completed on the proposed Transmission Solutions linking central Iowa to Northern Missouri to central Illinois and that those upgrades would be included in the LRTP portfolio. It was only after this announcement that Invenergy approached MISO to express its views regarding the GBX Line and how it interacted with LRTP.

In comments to MISO, Invenergy claimed that “[f]ailure to account for the GBX Line may cause economic harm to GBX.”

Grain Belt Express acknowledges how it intends to edge out new MISO projects by taking their place:

“Across the Midwest and Great Plains, several potential transmission projects have been proposed over the next decade to address regional reliability needs, enable the delivery of power to load centers, reduce congestion, and unlock renewables potential. While there still may be a need for localized upgrades, given that the Project addresses these broader goals, it stands to logically reason that the Project could plausibly defer/eliminate the need for certain future major transmission developments."

Invenergy also compares the expected timeline of its proposed projects to the expected timelines of the LRTP Tranche 1 projects, but that comparison does not help Invenergy’s argument, even if taken on its face value. Under the Tariff, the MTEP is “developed to facilitate the timely and orderly expansion of and/or modification to the [MISO] Transmission System.

Including projects without sufficient certainty, regardless of timeline, does not advance system reliability.

Invenergy also fails to show that the GBX Line should receive special treatment and circumvent the MISO planning process. As a project that is not yet certain, MISO properly excluded the GBX Line from the planning studies for LRTP projects.

Invenergy claims that its GBX Line, a merchant high voltage direct current (“MHVDC”) transmission project designed to carry up to 5,000 megawatts (“MW”) of energy, should have been accounted for in MISO’s transmission planning analyses even though it has not yet obtained all necessary approvals and interconnection agreements, and its prospects for achieving such statuses are not at all certain.

While Invenergy explains the status of the GBX Line noting the number of approvals and permits it has obtained, the prospects for the project are far from certain. For example, as Invenergy concedes, permits are still required in one state. In addition, on August 24, 2022, Invenergy submitted an amended Certificate of Convenience and Necessity Application in Missouri to request significant changes in the GBX Line.   Invenergy also has not yet executed interconnection agreements with half of the transmission systems it proposes to interconnect—MISO and PJM.

The Commission should deny Invenergy’s attempt to obtain preferred treatment for the GBX line.

In its Complaint, Invenergy claims “Grain Belt Express has secured voluntary easements for over 75% of the necessary right-of-way in Kansas and Missouri.” However, in its Application in Missouri, Grain Belt claims it has “[a]cquired 72% of all easements required for the Kansas and Missouri portion of the Project.” While only a difference of 3%, it is notable that the percentage of easements acquired went down in the two weeks between the filing of this Complaint and the filing of the Missouri application.

“Subject to additional oversight and approval by the Federal Energy Regulatory Commission (“FERC”), Grain Belt Express may sell and/or lease an undivided interest in the project to potential buyers and/or lessees, and Grain Belt Express and those buyers/lessees may seek to provide transmission service over the line to eligible customers as defined by FERC on a non-discriminatory basis under a FERC-approved open access transmission tariff (“OATT”). Any co-owner or lessee of Grain Belt Express that seeks to provide transmission service will be required to operate pursuant to an OATT on file with FERC that will meet the requirements of the Federal Power Act and FERC’s regulations. Grain Belt Express may also sell a cotenancy interest or lease a long-term leasehold interest in the transmission line, in which case it is not providing transmission service to such buyer/lessee because the buyer/lessee has control over that undivided interest”.

“If the shoe were on the other foot, would Invenergy or its executives consent to a forced sale of their property to Missouri farmers and ranchers? We could run cow-calf pairs on their lawns in Chicago, and they’d probably even come out ahead on mowing cost. But something tells me they might feel differently about the eminent domain doctrine if that were the proposal.

“I am a farm wife, and we live in Boone County, but our farms are in Audrain and Callaway,” Stemme said. “There are several residents from Audrain that will be attending the protest. I don’t have the commissioners schedule, so I don’t know if they will be in house or not. It doesn’t matter: We will still be able to get our message across, that we are opposed to any decision that allows the Tiger Belt (Connector) to move forward. I don’t feel the (House Bill) 2005 is very comforting. Our Fifth Amendment rights are being abused.
“The PSC has no agricultural representation. They also have no oversight.”
According to Stemme’s press release announcing the protest, Invenergy proposes to add a “completely unnecessary” 40-mile double circuit 345-kV electric transmission line on a destructive course that would impact prime farmland that is presently producing crops for ethanol and biodiesel. These valuable farms are helping reduce emissions in St. Louis, Columbia and Kansas City.
Stemme noted that Invenergy has only revealed customers for less than 10 percent of its planned delivery to Missouri.
“As a merchant transmission project, the company cannot charge captive ratepayers for its project and can only recover its costs from voluntary customers,” the press release states. “Without customers, there is no revenue to pay for the project.”
Stemme’s press release adds, “The PSC’s prior granting of a permit and eminent domain to Grain Belt’s speculative plan have directly caused the Tiger Connector proposal by encouraging the company to take land for a route that has now changed and must be extended into Audrain and Callaway in order to connect with Missouri’s electric grid. Without an approved grid interconnection and enough customers to pay for its construction, Grain Belt Express remains nothing more than speculation and could change again in the future.”

a) Appropriation.--In addition to amounts otherwise available, there is appropriated to the Secretary for fiscal year 2022, out of any money in the Treasury not otherwise appropriated, $760,000,000, to remain available through September 30, 2029, for making grants in accordance with this section and for administrative expenses associated with carrying out this section. (b) Use of Funds.-- (1) In general.--The Secretary may make a grant under this section to a siting authority for, with respect to a covered transmission project, any of the following activities:

(2) Economic development.--The Secretary may make a grant under this section to a siting authority, or other State, local, or Tribal governmental entity, for economic development activities for communities that may be affected by the construction and operation of a covered transmission project, provided that the Secretary shall not enter into any grant agreement pursuant to this section that could result in any outlays after September 30, 2031.

(3) Economic development.--The Secretary may only disburse grant funds for economic development activities under subsection (b)(2)-- (A) to a siting authority upon approval by the siting authority of the applicable covered transmission project; and (B) to any other State, local, or Tribal governmental entity upon commencement of construction of the applicable covered transmission project in the area under the jurisdiction of the entity. (d) Returning Funds.--If a siting authority that receives a grant for an activity described in subsection (b)(1) fails to use all grant funds within 2 years of receipt, the siting authority shall return to the Secretary any such unused funds.

As stated above, Grain Belt Express then intends to raise debt secured by the revenue stream from the transmission capacity contracts to raise the capital necessary to complete the remaining development activities, construct the Project and place it into operation. Grain Belt Express anticipates utilizing a combination of commercial and governmental sources of financing, and at this time is still evaluating all potential options for financing. Options for governmental sources of financing include the Western Area Power Administration (“WAPA”) Transmission Infrastructure Program (“TIP”); and the Bipartisan Infrastructure Bill Transmission Facilitation Program; Department of Energy loans to non-federal borrowers for transmission facilities pursuant to the Inflation Reduction Act and potentially other government funding options. Additional equity capital may also be raised to help finance construction of the Project, or Grain Belt Express’ existing investors may make additional equity investments in the Project.

Have you entered any new agreements with any potential partners or “customers” who will use the Grain Belt and the connector?
We have an existing contract with a consortium of 39 Missouri communities to take power from the Grain Belt Express at an annual savings for $12.8 million, and we see very strong market interest in transmission capacity from the line, which is one factor in the recent announcement to expand local delivery capacity.
Will you move forward prior to an agreement or wait until you get enough before beginning construction?
Kuykendall: “We will begin construction after acquiring the necessary easements and approvals from regulators.”

So, to clarify customers that pay into Grain Belt Express through money or service, who, if anyone, have you entered into an agreement with? If you have no one paying into the line - a customer - you are saying you would build anyway? Or do you want to expand on this?
Kuykendall: ““Grain Belt Express will be bringing power to 350,000 electric consumers across Missouri through a signed transmission service agreement with the Missouri Joint Municipal Electric Utility Commission (MJMEUC) representing 39 Missouri municipal utilities. Grain Belt Express has seen strong interest in the market and expects to secure additional customer agreements prior to construction beginning.”

What measures will the company actually take to minimize negative impacts for affected landowners?
Kuykendall: “Missouri stakeholders have urged Invenergy to develop solutions to deliver more power to Missouri from the Grain Belt Express project. The Tiger Connector is necessary to meet that request, and in doing so provide billions in energy savings to Missourians.

What will the company do to avoid condemnation, which is likely the biggest issue?
Kuykendall: “This is always a last resort for us. We’ve already acquired 84 percent of the parcels needed along the Phase I portion of the Grain Belt Express HVDC route, with nearly all of them coming through voluntary easements.

Can you confirm that Invenergy intends to honor the 7-year Sunset revision on easements as stated in the law?
Kuykendall: “The company is still reviewing that provision of (House Bill 2005) and expects this issue to be addressed in any regulatory filings before the Missouri Public Service Commission. As you know, HB2005 does not apply to Grain Belt Express and any commitment to comply with portions of the law would be voluntary in nature.”

We will engage further with the Missouri Farm Bureau, other ag groups, and the Missouri Public Service Commission to implement these commitments to balance energy affordability and reliability and landowner interests in Missouri.”

Will Invenergy move lines from the middle of fields? Bury lines?
Kuykendall: “We will propose a route that takes the input gathered from these public meetings into account. We understand the desire for some or all parts of the Tiger Connector line to be buried.  Undergrounding the Tiger Connector would require burying two separate transmission systems to meet safety and reliability requirements. This makes undergrounding a non-starter.

“The Tiger Connector line will have one circuit for MISO and one circuit for AECI.
“Overhead line maintenance can be performed by shutting down one circuit while the other continues to deliver power.
“This is not possible underground because workers cannot work with a live circuit present, and federal reliability requirements prohibit a system design that would shut down power delivery to multiple markets at once. This would require two separate buried systems.
“Undergrounding would also have much greater impacts on ag operations, including:
Eight times as much land permanently taken out of production.
Over 80 times the excavation that can reduce yields from compaction and soil mixing.
Permanent “call before you dig” requirements for landowners in easement areas.
Ag impacts result from:
Excavating two buried cable trenches across the entire length of the line – with the trenches separated sixty feet from each other. Recent studies of other buried infrastructure projects have shown reduced yields for corn and beans between 15-25 percent due to compaction and the mixing of topsoil and subsoil caused by trenching.
Installation of permanent access bunkers which are like U-Haul trucks parked in the ground every 2,000 feet in pairs, one along each set of buried cables. Crops cannot be grown over these, and each set would be farmed around.
“In addition to the significant land impacts, this request could set a precedent for other future transmission lines in Missouri, representing billions of dollars in added costs for Missouri electric consumers over time.
“Stakeholders have cited the importance of balancing energy affordability and reliability while also serving landowner interests. Burying any part of Grain Belt Express would fail both of these goals.”
Kuykendall added these statistics to the response:
1.3 acres permanently out of production, vs. 0.16 acres
484,853 total cubic yards of soil excavation for undergrounding, vs. 5,759 cubic yards for monopole foundations

Grid United Texas was created as an electric corporation in 2021. Grid United Texas is
wholly owned by Grid United LLC (Grid United) with a mission to unite the U.S. electric grid by
building new long-distance, interregional transmission lines to ensure that Americans have access to low-cost power when and where it is needed.

The Pecos West Intertie Project (Proposed Project) is a proposed 1,500 MW HVDC interconnection between ERCOT and the Western Electricity Coordinating Council (WECC). The Proposed Project is proposed with an HVDC converter station at the LCRA TSC Bakersfield Switching Station in Pecos County, Texas, and an HVDC converter station at an EPE Station in El Paso County, Texas. Grid United Texas has evaluated interconnection at EPE’s Caliente Station and Newman Station, but the EPE interconnection will be determined following further consultation with EPE and the U.S. Army regarding a potential crossing of Fort Bliss (for the Newman Station interconnection). An approximately 250 to 300 mile ±525 kilovolt (kV) overhead HVDC tie line (Tie Line) will connect the HVDC converter stations at each end of the Proposed Project.

On the supply side in PJM, "we're seeing dramatic retirements" of coal-fired generation, with PJM retiring about 15 GW of coal in the next two years that it is not being replaced on a one-to-one basis, Thomas said.
The Midcontinent System Operator is experiencing a similar trend, with incremental generation resources being added that do not have the same reliability attributes as those being retired. "They are adding megawatts that are less valuable than the megawatts being retired, meaning they need to add significant multiples to replace what's being retired," he said.
In MISO, the accredited capacity being added goes down out to 2041, while the future load scenarios continue to go up.

"This is kind of a fascinating trend, and arguably not a sustainable trend, because what all these other regions are counting on is importing power from other areas of the country to make up the difference and that's a house of cards waiting to fall," Thomas said.
PJM is not one of the areas identified by the North American Electricity Reliability Corporation, an international regulatory authority, as having reliability concerns, but "they're coming in a big way," he said.
The PJM interconnection queue of resources planning to connect to the grid is 95%, if not more, wind and solar power resources, which is where the economic signals are right now.
"There is going to be very little to no new natural gas coming into the system and coal is going to continue to retire" with the nuclear power resources remaining because they are subsidized at the state and federal level, Thomas said.

One of the core tenets of the PJM capacity market is that in order to have capacity it must be deliverable. A megawatt of power on the system only has value if it can be delivered at peak demand periods, Thomas said.
PJM has been giving capacity accreditation to intermittent resources above their approved capacity injection rights levels, so these resources were selling capacity that was not deliverable, and that is a problem, he said.

The problematic aspect is consumers have been paying for capacity that has no value at peak, and suppliers "are getting boxed out of the market by these undeliverable megawatts," Thomas said.

One 1018 MW interconnection request (queue number GI-083) was submitted to AECI (Associated Electric) in June 2019, with a point of interconnection to the McCredie 345 kV substation.

Four interconnection requests were submitted to MISO in April 2019. The point of  interconnection for all four interconnection requests is breaking Ameren’s McCredie – Montgomery 345 kV line, approximately 0.5 miles East of AECI’s McCredie 345 kV
substation. Two of the interconnection requests (total 1,500 MW) are being processed per MISO’s Merchant HVDC Transmission Connection Procedures (“MHCP,” Attachment
GGG) and the two remaining are being processed per MISO’s Generator Interconnection Procedures (“GIP,” Attachment X).

The converter in Missouri is proposed to be interconnected with the MISO system along the Ameren 345 kV AC transmission line connecting the McCredie substation and the Montgomery substation. The proposed connection will be made via a single 345 kV circuit from the converter station to a nearby tap point along the Ameren 345 kV transmission line. The proposed converter will also interconnect with the AECI system at the McCredie 345 kV substation. The proposed connection will be made via a single 345 kV circuit from the converter station to AECI’s McCredie 345 kV substation.

Subject to additional oversight and approval by the Federal Energy Regulatory Commission (“FERC”), Grain Belt Express may sell and/or lease an undivided interest in the project to potential buyers and/or lessees, and Grain Belt Express and those buyers/lessees may seek to provide transmission service over the line to eligible customers as defined by FERC on a non-discriminatory basis under a FERC-approved open access transmission tariff (“OATT”). Any co-owner or lessee of Grain Belt
Express that seeks to provide transmission service will be required to operate pursuant to an OATT on file with FERC that will meet the requirements of the Federal Power Act and FERC’s regulations.  Grain Belt Express may also sell a cotenancy interest or lease a long-term leasehold interest in the transmission line, in which case it is not providing transmission service to such buyer/lessee because the buyer/lessee has control over that undivided interest.

Grain Belt Express has been granted negotiated rate authority from FERC, which
may be updated. Under this authority, Grain Belt Express is required to broadly solicit interest in taking service on the Project from potential customers and accordingly, will offer the opportunity to contract for firm and non-firm transmission service to eligible customers, and to provide transmission service over its available transmission capacity to all eligible customers on a not unduly discriminatory basis. Grain Belt Express will provide eligible customers with the opportunity to contract for transmission service where available transmission capacity exists on the line and cannot and will not unduly discriminate against any transmission customer in favor of another transmission customer. All eligible customers will have equal opportunity to obtain firm and non-firm transmission service through these means.  If Grain Belt Express sells or leases one or more undivided interests to potential coowners/lessees, Grain Belt Express may be required to seek FERC approval of such a sale or lease if Grain Belt Express is a public utility subject to FERC jurisdiction at that time pursuant to Section 203 of the Federal Power Act. Furthermore, if any co-owner/lessee seeks to provide transmission service to eligible customers, such co-owner/lessee will be required to comply with FERC’s statutory and regulatory open access requirements and similarly be obligated to provide available
transmission service on its portion of the line on a not unduly discriminatory basis.

Grain Belt Express expects that its co-owners, lessees and transmission customers will consist principally of (i) entities with wind and solar energy ownership interests located in southwestern Kansas and (ii) buyers of electricity—particularly buyers seeking to purchase electricity generated from renewable resources—located in MISO and PJM who take delivery at the respective delivery points. These buyers of electricity are expected to be principally participants in the wholesale markets (utilities, alternative retail electric suppliers (“ARES”), other competitive retail suppliers and brokers and marketers) but could include retail purchasers. The ultimate beneficiaries of the Project will be retail consumers of electricity in Illinois and other parts of PJM, MISO and adjacent markets who purchase and consume electricity from renewable resources that the Project delivers to the MISO and PJM delivery points.

At this time, all of the costs associated with the development, construction and operation of the Project are expected to be recovered through a combination of sales/leases, as well
as FERC jurisdictional services including transmission service agreements with customers and other rates and charges pursuant to FERC approved tariffs and rate schedules. Grain Belt Express does not intend to seek to recover all of the costs of the Project by regional cost allocation to retail
customer load using the transmission cost allocation processes of PJM or MISO.”

The projected cost to construct the total Project and place it into operation is approximately $4.95 billion (not including network upgrades). Grain Belt Express has a viable plan for raising the capital necessary to finance the cost of constructing the Project on a project financing basis. Specifically, after advancing development and permitting activities to a status at which developers of wind and solar generation facilities and other potential customers of the transmission line are willing to enter into commercial agreements for an undivided interest (purchase or lease) or long-term contracts for transmission capacity on the Project, Grain Belt Express will enter into such contracts with interested subscribers that satisfy necessary
creditworthiness requirements. Grain Belt Express will then raise debt capital using the
aforementioned contracts as security for the debt. Grain Belt Express may also raise additional equity capital.