"It is clear that the Alliance will seek to make this process unnecessarily burdensome and overly complicated before the board can even make its initial determination on whether the franchise should be granted," the company's lawyers conclude.

Clean Line does not object to the Alliance's limited intervention at this stage; however, Clean Line reserves the right to request specific limitations be placed on such participation depending upon the participation of other parties who may have the same interest as the Alliance. Such limitations may include but shall not be limited to prohibiting the Alliance from preparing direct testimony, submitting exhibits or other evidence, or conducting cross examination of witnesses. If the Alliance seeks to "advance the mutual arguments of all its members" as stated in its Petition to Intervene, limiting its participation to briefing legal arguments will satisfy the Alliance's goal.

...the motive of the Alliance is clear: to make sure Clean Line does not build this  transmission line. A recent statement
from the Alliance Board President Carolyn Sheridan to the Alliance members concisely details the strategy:
"From the Board President
Think about it: Imagine you're [Rock Island Clean Line ("RICL")] and you have to file all
this information about a parcel of land in a distant location: How much time would it take
you to learn the names and addresses of all persons with an ownership interest in the land?
How much work would it be for you to prepare a map showing the location of all electric
lines and supports within the proposed easement; and the location of and distance to any building w/in 1OOft. of the proposed line? A lot of work. Multiply that by hundreds; and
you have an idea of how important it is to the success of RICL's project that it obtains.
The more parcels upon which RICL has to do all this work, the less likely this project is to
succeed. Every parcel upon which it has to do all this work is one more shovel of dirt on
the grave of this RICL line. Join the opponents of the line. DO NOT sign an easemnts
[sic] with RICL.
Carolyn Sheridan
Board President"

Without bifurcation, it is clear that the Alliance will seek to make this process unnecessarily burdensome and overly complicated before the Board can even make its initial  determination on whether the Franchise should be granted.

The Alliance seeks to force Clean Line to waste time and resources, and consequently also the time and resources of the IUB, with the hope that Clean Line eventually gives
up on the project.

Mr. Glotfelty also noted that there could be circumstances under which the Grain Belt Project could find it necessary to depart from the cost recovery model described and instead seek cost recovery through regional or inter-regional cost allocation mechanisms.

Mr. Berry testified that while Petitioner currently has no plans to seek cost recovery for this Project through regional cost  allocation, Petitioner is not in a position to make an irrevocable commitment not to seek cost allocation. He stated that such a  commitment would be premature and would potentially go against the public interest. If regulations change in the future, an irrevocable commitment not to recover costs in a certain manner may compromise the ability of Petitioner to complete the Project.

D. Public Outreach
Public outreach and active stakeholder involvement are key components of Applicant’s approach to development of the Project. Beginning in 2010, Grain Belt Express implemented an extensive, methodical, multi-level public outreach strategy across Kansas, Missouri, Illinois, and Indiana, which has resulted in more than 1,000 in-person meetings across the Project area as of November 2013. Grain Belt Express also has maintained an active presence online and through social media. The Project’s website, www.grainbeltexpresscleanline.com, has been actively updated since the beginning of the Project in 2010. Among other information, the website contains: a project 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; an FAQ section for all stakeholders to learn greater details about the Project; a section on how local businesses can learn about opportunities to participate in the construction of the Project; and information regarding Project meetings, maps, studies, regulatory filings, and third-party resources. In addition, Grain Belt Express distributes a newsletter on a regular basis to hundreds of stakeholders. These newsletters provide information on Project milestones, recent events and meetings, as well as upcoming Project activities. The newsletter is available to anyone who is interested in receiving a copy. Applicant’s participation in multiple state regulatory proceedings also has publicized information regarding the Project.
E. Project Schedule
Applicant continues to work closely with land use and routing experts as well as landowners, local government officials, state and federal agencies, and other stakeholders in the areas where the Project will be built in order to gather input and determine the specific route for the transmission line in each state that it will traverse. Applicant is consulting experts on topics such as threatened and endangered species, archaeology, and cultural resources to ensure that appropriate considerations are taken into account in the routing decisions. Applicant expects to obtain all necessary authorizations from federal, state, and local governments and agencies for the Project by 2016.

Applicant is assuming all market risk associated with the development and construction of the Project, and Applicant does not have and will not have any captive customers. Accordingly, Applicant has no ability to pass through the Project’s costs to captive ratepayers.

Once the Project is completed, Applicant will turn over operational control of the Project to an RTO, which will operate the line pursuant to a FERC-approved non-discriminatory rate schedule filed under the RTO’s OATT.

On a recent day, the men stood behind ropes tied across the path leading to the outpost, smoking cigarettes and watching for construction workers they feared would come at any time. Three nooses dangled from nearby pine trees. “To hang them or be hanged,” the men said.

The women have also taken a fatalistic turn, building trenches in front of their tents they say will serve as their own grave sites if the authorities try to remove them. Ms. Sohn said she recently tried to prepare her children for the worst.

“When they called me the other day, I said, ‘I will die fighting,' ” she said. “That way, I would be less ashamed when I met my dead ancestors.”

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