Dear Governor Parson:

We are writing to ask for your support in taking action to protect agriculture in Missouri from Grain Belt Express-Clean Line. The proposal to take wind energy from Kansas through Missouri to PJM Grid is only a speculative venture and is for private gain for a company that is not a utility but a merchant transmission line. Our Missouri PSC has denied this project two times, and we are now at a point of decision on the third application which involves the sale of GBE to lnvenergy, who did not have to make an application to PSC.

Growing up on a family farm in the 1930's, we can tell you about adversity and how we have
seen agriculture change from horse drawn equipment to the development of auto-steer and technology that has greatly enhanced production. Our University Extension Century Farm was settled in 1873. We currently have 5th generation grandchildren involved in the family operation, and are fortunate to be able to continue living on the homestead even though we are in our late 80's.

The GBE proposed line will run through the middle of our farm, tearing up farm ground that has been cared for since 1873.  In fact, the dangerously high voltage line will be within 600 feet of our home and machine shed, a nice view from our patio. Until recently, like you, we took much pride in my cow herd. Our pastures near our home would be affected by the proposed GBE line as well.

In all our years of farming, we have never faced a troubling situation like GBE. And, to think our state government could possibly approve such a project by giving authority of eminent domain adds to our worries.

With all due respect, please protect the future of farming and agriculture in Missouri. If a project like GBE is approved, what is next? We have included a picture of us with some of the
other generations involved in our century farm.

Our regards,
Dale & June Morgan
Madison, MO

L to R: Vickie Morgan Ross, June Morgan, Jay O'Bannon, Dale Morgan, Alan Morgan, Marilyn, Kevin, Jeff & Lisa O'Bannon. Front row: Kade, Grey and Isla Kate

Witness Herling testified that PJM evaluated new proposed second circuits on Furnace Run - Conastone 230kV and Furnace Run - Graceton 230kV and found that these alternatives could potentially violate NERC Reliability standards. It is unclear exactly what PJM modeled here with regard to existing PPL EU-owned facilities because "the Furnace Run - Conastone 230 kV circuit towers and the Furnace Run - Graceton 230 kV circuit towers" are not PPL EU-owned facilities (and indeed have not yet been constructed).

Transource 9A proposes a new circuit from Furnace Run to Conastone. This parallels an existing Otter Creek-Conastone 230 kV line jointly owned by PPL EU and BGE. The PPL EU owned section of the line is designed to accommodate a second circuit without acquiring new Right of Way. PPL EU's Otter Creek 230 kV substation is built next to the TMI-Peach Bottom 500 kV line and can be connected to the line through 500-230 kV transformers. Thus, adding 500-230 kV transformation at the existing Otter Creek
substation, adding a second high capacity 230 kV circuit and replacing the current circuit with a higher capacity circuit on the existing Otter Creek-Conastone 230 kV line may provide similar economic benefits as the proposed new Furnace Run substation and a new double circuit line between Furnace Run and Conastone substation. Furthermore, there is another PPL EU-BGE jointly owned line (Manor-Graceton 230 kV) in the area that can be utilized to add a second 230 kV circuit from north to south.

...it does not appear that PJM ever considered adding a new 500 kV circuit from the existing TMI-Peach Bottom 500 kV line (utilizing a new 500 kV substation at Otter Creek) to the 500 kV Conastone substation, utilizing PPL EU owned right of way on the Otter Creek- Conastone 230 kV line.

In fact, a new 500 kV circuit utilizing PPL EU's existing Right of Way between a new Otter Creek 500 kV substation (to be built by expanding PPL EU Otter Creek 230 kV substation) and the existing Conastone 500 kV substation will provide more capacity than the total capacity of the proposed Transource 9A project, which only adds a new double circuit 230 kV connection between the Furnace Run and Conastone substations.

Dear Governor Parson:

We have been engaged in farming since 1978. In fact, to help make ends meet, one of us worked as a Social Worker for Missouri Department of Social Services Children's Division and Department of Health and Senior Services for over 25 years.

Nothing has been as threatening to our livelihood as Grain Belt Express-Clean Line. We have been strongly opposed to the project since finding out in mid-December 2013. Most upsetting is this company, a speculative merchant transmission line, was even eligible to apply to our Missouri Public Service Commission to become a utility company and take property through eminent domain.

As a farmer, you know the sacrifices involved to purchase a farm, nurture the land, and be good stewards to raise a crop or maintain pasture for cattle. We have implemented all of the technology to farm more efficiently and want to leave a legacy for our sons and grandchildren. The proposed GBE plan would devastate our operation as it is proposed to run through the middle of farms that are open and mostly tillable. The proposed 27 foot concrete piers below ground sickens us as we would lose our investment in conservation practices and production in the 200 foot easement, and anywhere the heavy construction equipment runs across the fields.
There are many other issues induding safety, inability to raise corn under the transmission line, loss of our technology (GPS), and the list goes on.

Missouri PSC has twice denied the GBE application. A third application is now in the hands of PSC commissioners for a decision. Now that GBE has started the sale of their company to lnvenergy, it seems very wrong for PSC to consider lnvenergy, a company that will not close on the deal with GBE until there is PSC approval, and the remaining 700 easements are obtained through eminent domain. Since Iowa has legislation to prevent eminent domain for merchant transmission companies, and Illinois Supreme Court has denied GBE and a sister company RICL as a utility, we are suspicious why lnvenergy would even want to buy GBE-Ciean Line. A more thorough investigation is needed.

We are not against renewable energy. But, wind does not need to be shipped in from Kansas, and not at the expense of destroying highly productive farmland in Missouri.

We are proud to have a Governor who stands for agriculture. Please take action within your power to protect property rights and landowners from GBE. We want to keep agriculture number one in Missouri.

Respectfully,
Kevin O'Bannon
Marilyn O'Bannon

PJM proposed a change to the way market efficiency projects are evaluated. PJM members were frustrated by the fact that few large projects were passing the metrics of their old formula. So they proposed relaxing the rules so that more projects would pass.

The implications of these changes are the primary reasons that this project is still being proposed by PJM today. Before this change, the benefit side of the B/C ratio was 75% based on the benefit across the entire PJM footprint (PJM uses the word “socialized.”) If a proposed project, such as the IEC, resulted in lower-rate “winners” and higher-rate “victims”, 75% of the calculation was made on the basis of netting the winners against the victims. After the change, 100% of the calculation for Lower Voltage projects, and 50% of the calculation for Regional projects, is based solely on the savings to the “winners”, without consideration to the higher rates incurred by the “victims.”

Both the IEC-East and IEC-West are able to carry more power than a Regional  345kV line, and taken together, move more power than many Regional double-circuit 500kV lines, a configuration that forms the backbone of the electrical grid.

Based upon the amount of capacity in those lines, the IEC clearly qualifies as a Regional project, as Regional was initially intended.

IF THE IEC WERE CLASSIFIED AS A “REGIONAL” PROJECT, HOW WOULD THE B/C CHANGE?
The benefits of the project would be subject to a 50/50 weighting of overall production cost to load energy payment. The $707M benefit that currently is weighted at 100%, would shrink to $353.5M. The other 50% of the weighting would be based on net production cost changes, a number that includes production cost increases as well as decreases. I have not been able to identify this value in the non-confidential public discovery record, and discovery is still pending. However, we know from OCA filings (SJR-3, p2), that many zones saw significant cost increases, and that the net change in load payment over 15 years was just over $-17M. Net production cost could not have decreased much more than that, or the savings would have been passed on to the customers who saw increased rates. Even assuming a generous $50M savings (which approximates the estimate in the optimistic 2015 14 RTEP presentation) would yield a benefit of only $353.5+(0.5*50)=$378.5M, far less than the $505M cost of the project, yielding a B/C ratio of 0.74.

“I’m excited to see what’s there,” said Rep. Scott Landry, D-Farmington. “I want to see what we can get for our community, though who knows if it’s going through or not with all the opposition out there.”

“Clean Energy Connect has the potential to significantly reduce New England’s climate-damaging emissions,” Sean Mahoney, the executive vice president and director of CLF Maine, said. “But any approval of the project must depend on CMP providing greater economic benefits for Maine families and businesses, better safeguards for our environment, and a clear path to boost local clean energy here at home.”

Public Advocate Barry Hobbins declined to comment Tuesday, but has publicly stated in the past that CMP should contribute $50 million to help low-income Mainers with electric bills, just like they're doing in Massachusetts.

In a statement Saturday, Sandra Howard, a spokeswoman for the opposition group Say NO to NECEC, said there is “no amount of short-term money” that could make up for the impacts to Maine’s natural environment and tourism.

“Parties that wish to settle for their own profit interests should dig deep into their conscience before selling out Maine to benefit corporate profit interests,” she said.

Mr. Baker testifies that "Transource PA feels that transmission line corridors are a common element in the landscape and that the presence of these features does not diminish the scenic aspects of an area for visual enjoyment from public rights of way."
Transource Statement No. 4-R at 37.

HOW DO YOU RESPOND?

As an initial matter, I am not aware that a corporation can have feelings. However, to the extent that Mr. Baker is expressing his own personal feelings, he is wrong. The proposed project would wholly diminish the scenic aspects of southern York County. The outpouring of opposition from the local community shows how the construction of another transmission line corridor would adversely affect the landscape in a damaging and permanent way.

Regardless of what efforts Transource may have undertaken to minimize the impacts of
the project...  the fact remains that the project would have significant and adverse impacts on...

Q.  WHAT IS THE PRIMARY TOPIC OF MR. SCHAFFER'S REBUTTAL TESTIMONY?
Mr. Schaffer testifies about Transource's interactions with landowners, explaining that
the approach to these interactions is described in its Internal Practices for Dealing with the Public on Power Line Projects, which is Attachment 13 to the Siting Application. He claims that "Transource PA strives to be honest and act in good faith with landowners."
Transource Statement No. 6-R at 1-2. Mr. Schaffer further suggests that in most cases,
"the negative interaction is the result of a misunderstanding" and that it makes additional information available in these situations. Transource Statement No. 6-R at 2. He also explains what Transource does when it learns of a negative interaction between one of its representatives and a landowner and describes some of the key elements of its internal practices. Transource Statement No. 6 at 2-3.

Q.  PLEASE RESPOND.
While Transource may have an approach to interactions with landowners that is documented in a manual, landowners have been subjected to numerous instances of negative interactions, including situations of dishonesty and acting in bad faith. Attached as Citizens Exhibit No. 1 is a letter stating that many landowners had already granted Transource access to the property to conduct surveys. That was an untrue statement, as the opposite is actually true. In other instances, agents who were seeking permission and right-of-ways told landowners that many of their neighbors had already consented when in fact only one has signed to this day, of which I am aware. As Transource prepares to conduct drill tests on the land, the agents are telling landowners that they only have to give 24-48 hours' notice, when Section 309 of the Eminant Domain Code plainly states they are required to give 10 days' notice. 

Also, I note that Mr. Schaffer does not suggest
that any landowners received apologies as a result of a "misunderstanding." Nor does he
provide any data to quantify the number of negative interactions that have been reported,
offer any detail about the nature of the so-called misunderstandings or explain what additional information was subsequently provided to the landowner. It is also telling that Mr. Schaffer does not describe any disciplinary procedure that Transource has in place, much less discuss any actions that have been taken.

HOW HAS MR. CAWLEY CHARACTERIZED THE THINKING OF OPPONENTS OF THE PROJECT?

Mr. Cawley has characterized the thinking of the project's opponents as "parochial," "self-interested," and "provincial." Transource Statement No. 9-R at 13-14.

HOW DO YOU RESPOND?
Landowners from York County have repeatedly testified that if the project was needed for reliability reasons and no other reasonable alternatives existed, they would not be in this proceeding - spending their personal retirement and college funds and committing vast amounts of their valuable personal time- to oppose construction of this high voltage
transmission line. But, it is not needed for reliability in Pennsylvania or in the region, and other reasonable alternatives do exist, in the form of currently underutilized lines running through the area. Frankly, given the way that the landowners of York County have united and organized their efforts to oppose the project shows the depth of their commitment to preserve the entire area's farmlands, businesses, environment, natural resources and viewshed - not only for their families but for future generations and for visitors to the region. Their attitudes are far from "parochial," "self-interested" and "provincial."

Dear Governor Parson,

I own a small business in Missouri, pay Missouri taxes, donate to Missouri charities, and lived in Missouri for more than 30 years of my life. I am adamantly opposed to Clean Line Energy’s Grain Belt Express (GBE) transmission line project, which would usurp my family-owned small farming business for the private gain of an out-of-state company. I write to ask that you support Missouri’s farmers by opposing Clean Line’s application for a Certificate of Convenience and Necessity from the Missouri Public Service Commission (PSC).

For over 40 years, my family has farmed in Ralls County, Missouri. More than a quarter century ago, my family initiated a 200+ acre habitat restoration project on Parham Farms in coordination with the U.S. Natural Resources Conservation Service, an effort which my brother and I continue to manage today. We
set aside this portion of Parham Farms for environmental protection because of its unique qualities. It is a rare swath of Missouri savannah habitat that plays a special role to biodiversity of the surrounding area. It is a hub for wildlife and includes prime habitat for the Indiana Bat, which is listed as endangered by both the State of Missouri and the U.S. Government. Savannah habitat—where the Eastern woodlands and Western prairies meet—was once predominant across Missouri. As savannah habitat declines, so does biodiversity across the state. Today, according to state and federal agencies, less than 1% of savannah habitat remains in Missouri.

Today, Parham Farms falls directly in the path of Clean Line’s planned GBE project, and Clean Line wants to condemn and forcibly take this property for their own use. That remaining 1% of native savannah habitat – which my family has painstakingly restored over decades – now faces destruction if the PSC approves Clean Line’s petition to build the GBE. I urge you to question if this is the kind of legacy that the PSC’s decision should leave.

The proposed route for the GBE would cut straight across Parham Farms – slicing through our most productive cropland. It would also disrupt prime habitat for the Indiana Bat, which depends on land covered
in mature, old-growth trees—exactly the type of habitat that we currently protect on Parham Farms. If the PSC allows Clean Line to take away our old-growth forest, it will take away the endangered Indian Bat population with it.

The PSC’s approval of Clean Line’s project will also tell large companies that Missouri welcomes out-of-state companies to forcibly repurpose family-owned small businesses for their own use—a truly dangerous precedent.

Clean Line does not have the right to tell me how my business should use my property, and the PSC should not grant it such authority. I ask for your support in protecting Missouri residents, landowners, farmers, and natural resources by not supporting Clean Line’s application for Certificate of Convenience and
Necessity.

Respectfully,
Austin Read Parham
President, Parham Farms

"We didn’t win the World Cup of transmission, which is what we were trying to do, but we put together great projects and [three of them] are [now] in the hands of people who can hopefully do them," said Skelly.

Skelly said: "Rock Island was killed by the Iowa legislature, which basically made above-ground HVDC illegal."