Filed with the Iowa Utilities Board on February 17, 2020, E-22386

STATE OF IOWA BEFORE THE IOWA UTILITIES BOARD IN RE: ) ITC MIDWEST LLC ) DOCKET NO. E-22386 DAIRYLAND POWER COOPERATIVE ) ______

Reply Brief of Linda E. Grice in Opposition to the Cardinal Hickory Creek Project

I. Introduction

The CEI Intervenors, a group of well-funded lobbyists wants to silence the voices of citizen and ratepayer intervenors in the CHC Project because they do not feel their voices are relevant or credible. They say citizen intervenors lack basis.

The Iowa Office of Consumer Advocate is afraid that when the truth gets out concerning how, poorly they defend the rights of Iowa Citizens that Iowans will become discouraged and not contact their office for help.

The Applicants and the CEI say that wind energy is cheap yet can’t put a number on its’ cost.

CEI opines on the fact that MS Grice objects to what she claims is Iowa’s transformation from an agricultural state into an “industrial energy generation complex” without citizen input. (Grice

Pre-Hearing Brief at 3.) CEI states Ms. Grice ignored established state law that helped facilitate this.

The argument in this brief will address these issues and provide documentation to support the conclusions.

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II. Argument

The CEI wants to eliminate citizen and ratepayer voices so their argument cannot be refuted. In the Dubuque hearing of the CHC Transmission line four citizen intervenors stood alone against large sums being spent to silence them. One of the groups spending the large sums was the Clean Energy Intervenors, a group of well-funded lobbyists. Now that group wants to silence the voices of two of the citizen intervenors because they don’t like to hear the truth.

The CEI Post Hearing Brief Page 23 states:

II. THE BOARD SHOULD GIVE NO WEIGHT TO INTERVENOR TESTIMONY OPPOSING THE

PROJECT.

Chris Klopp and Linda Grice intervened in this case to oppose the project and identified concerns about the consequences of building the project. The Board should give no weight to their testimony because they have no basis, lack credibility, and lack relevance to required Board findings in transmission franchise dockets.4 (CEI Post-Hearing Brief, p. 23)

Intervenor Ms. Grice’s testimony is relevant as that of a citizen of Iowa, a taxpayer, and a ratepayer. Ms. Grice is an Iowa resident, a landowner, and a rate-payer unlike the CEI who are paid lobbyists for large energy companies with an out-of-state main office. Because many CEI members are not Iowa residents, do not pay taxes in Iowa, and are not Iowa ratepayers Ms.

Grice believes it is the CEI that has no basis, lacks credibility, and lacks relevance because their interest is their wallot and making money for their clients the huge energy companies and

Berkshire Hathaway. As such, the CEI is in no way concerned with the interests of ratepayers

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or taxpayers as is MS Grice or MS Klopp. It is clear, the CEI would like to eliminate any and all opposition possible.

Ms. Grice’s opinions are relevant because her interest is in protecting Iowans’ quality of life, economic future, and the future of our state agricultural heritage for our children and our grandchildren. MS Grice’s opinions reflect those of many Iowan’s in her walk of life and, therefore, her opinions are relevant. Ms Grice’s opinions are credible because she lives and owns property in the areas the line affects, pays utility bills and property taxes there, and she understands the hardships which would be imposed upon herself and her neighbors if the line were to be approved. As a farmer, MS Grice understands how the farming operations of the

Deutmeyers’ and the Goebels’ and others along the line will be affected if the line is built. Ms.

Grice’s opinions are relevant because she is affected by the transmission line and has friends and neighbors affected by the line.

Ms. Grice argued that the transmission will lead to wind turbines, and wind turbines inevitably lead to higher electricity rates. Ms. Grice did not submit any testimony in this case or substantiate any of her claims in the record and they should be given no weight. (CEI Post-Hearing Brief, p 26)

The first fact that CEI disagrees with, “that the transmission will lead to wind turbines” is a fact substantiated by multiple witnesses testifying for the applicants and their own post-hearing brief. The MISO plan is to build wind generation facilities and then transport the energy long

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distances. The testimony given by multiple witnesses for the applicants said the transmission line is necessary for increasing the wind energy output in Iowa. The CEI brief states:

The primary driver of these benefits are the wind resources being added in Iowa, Minnesota, North Dakota and South Dakota. (POST-HEARING BRIEF OF CLEAN ENERGY INTERVENORS IOWA ENVIRONMENTAL COUNCIL, CLEAN GRID ALLIANCE, MINNESOTA CENTER FOR ENVIRONMENTAL ADVOCACY, AND FRESH ENERGY-P 12)

The turbines are a part of the CHC transmission line decision because the Applicants have stated numerous times that the transmission line is needed to carry wind energy to the east and without it wind energy will suffer. Because the CHC line is necessary for the turbines it is relevant to talk about the efficiency and intermittence of wind energy and what effect those consequences will have on our state’s economic future as well as the state’s desirability as a place to reside. Afterall, what use is it to build a line for a failing wind energy sector?

MS. Grice’s claims that Wind turbines will lead to higher electricity rates can be substantiated by numerous sources and some were listed on the docket as objections prior to this. MS Grice will take this opportunity to introduce multiple resources confirming that wind energy use leads to higher electricity rates.

Solar panels and wind turbines are making electricity significantly more expensive, a major new study by a team of economists from the University of Chicago finds. Renewable Portfolio Standards (RPS) "significantly increase average retail electricity prices, with prices increasing by 11% (1.3 cents per kWh) seven years after the policy’s passage into law and 17% (2 cents per kWh) twelve years afterward," the economists write. It (the study) compared states with and without an RPS. It did so using what the economists say is "the most comprehensive state-level dataset ever compiled" which covered 1990 to 2015. Previous studies were misleading, the economists note, because they didn't "incorporate three key costs," which are the unreliability of renewables, the large amounts of land they require, and the displacement of cheaper "baseload" energy sources like nuclear plants. The higher

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cost of electricity reflects "the costs that renewables impose on the generation system," the economists note, "including those associated with their intermittency, higher transmission costs, and any stranded asset costs assigned to ratepayers." (EX 29: Forbes, Energy, Michael Shellenberger, Study by Michael Greenstone, Richard McDowell, and Ishan Nath, University of Chicago, 22 AUG 2019)

The true cost of wind power, however, is what consumers and society as a whole pay both to purchase wind-generated electricity and also to subsidize the wind energy industry through taxes and government debt. The true cost includes both traditional cost accounting and the seen and unseen costs of policies that seek to artificially bolster renewable energy development and production. When examined more closely, many claims about wind energy are found to be indefensible.

COST OF ONSHORE WIND ENERGY PRICED LOW TO HIGH

LAZARD NREL EIA HAMILTON MODIFIED GIBERSON TANTON/TAYLOR

Total Cost ($/MWh) $59 $72 $80.3 $97 $149 $151

The studies examined show a market where subsidized wind is competitive, and one where unsubsidized wind is much less viable. Wind energy is dependent on subsidies, and when these are removed from the calculation, the costs of wind energy increase enough to make it an unfavorable choice in the energy market. (EX.22 Simmons, Yonk, & Hansen. July 2015, Institute of Political Economy, Utah State

University)

At the hearing it was determined that there has been no analysis of the economics of the CHC project standing apart from additional projects and plans of MISO. One has to wonder if that is because a true economic analysis would decrease ratepayers’ enthusiasm for wind energy that is purported to be “free” or nearly so by the developers.

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Without the PTC, many private investors would have no incentive to invest in wind energy because such investments would no longer be profitable. Warren Buffett, who has invested billions in renewable energy, stated, "[W]e get a tax credit if we build a lot of wind farms.

That’s the only reason to build them. They don’t make sense without the tax credit.”(EX 23

BUFFET) Thus, when the PTC is allowed to expire, investments in wind energy plummet.26

(EX.22 Simmons, Yonk, , Hansen , July 2015, The True Cost of Wind, Institute of Political Economy, Utah State University}

(EX 23 Markets Insider, December 30, 2019, Theron Mohamed)

Federal subsidies for wind power lead to an economic phenomenon called “negative pricing,” which is when the seller pays the buyer to receive the product. In the case of wind energy, negative pricing works this way: demand for electricity is lowest at night, which is when wind blows most powerfully in most geographic regions.27 This means high levels of wind power are being produced when demand for electricity is lowest.28 Electricity produced from wind cannot easily be stored, and if more is produced than is being demanded, the only way wind energy producers can get rid of the excess electricity is to pay utilities to accept it.

The PTC pays wind producers $23 for every megawatt-hour of electricity produced, regardless of market factors like supply and demand. Wind producers can then pay utilities (up to $23 per megawatt-hour) to take their power while still making a profit or at least breaking even.

Subsidies, and the negative pricing they cause, distort the market for electricity and flood it with subsidized wind power. In some cases, this drives more conventional producers of electricity, such as nuclear plants, out of the market.29 Conventional energy sources are also more reliable. When they are forced from the market by subsidized competition, the overall reliability of the supply of electricity is threatened. When the supply of any commodity is threatened, its price increases. Here is another hidden cost of wind energy—consumers may pay higher prices for energy because of government policies they are required to fund with their taxes. (EX 22 P.10, The True Cost of Wind, Institute of Political Economy, Simmons, Yonk, and Hansen, July 2015, Utah State University)

Regardless of how cost factors are considered, the true cost of wind energy in the United

States is, on average, 48 percent higher than most estimates claim. This is because generating

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electricity from wind power entails many hidden costs. A true estimate of the cost of wind power to the American public must account for the following factors:

The federal PTC, a crucial subsidy for wind producers, has distorted the energy market by artificially lowering the cost of expensive technologies and directing taxpayer money to the wind industry.

States have enacted Renewable Portfolio Standards (RPS) that require utilities to purchase electricity produced from renewable sources, which drives up the cost of electricity for consumers.

Wind resources are often located far from existing transmission lines. Expanding the grid, whether by private or public funding, is expensive, and the costs are passed on to taxpayers and consumers.

Because wind power is unreliable, conventional generators must be kept on backup to meet demand when wind is unable to do so. This drives up the cost of electricity for consumers, as two plants are kept running to do the job of one.

Billions of taxpayer dollars are used to subsidize the wind industry.

Allowing consumers to pick which energy to use, based on price, would result in greater economic efficiency than allowing government to decide how the resources of consumers should best be allocated.

The true cost of wind energy is higher than most cost estimates calculate. Mandates requiring the use of wind energy increase electricity costs for consumers, and subsidies mask the actual cost of doing so. RPS require intermittent renewable energy to exist, but at the expense of utilities and consumers. The PTC makes wind power cheaper for utilities and consumers, but at the expense of taxpayers. Through such policies, U.S. policymakers have essentially decided that electricity consumers will have wind power, even if it is more expensive. The cost of this

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decision has fallen to U.S. taxpayers and consumers of electricity. When weighing the costs and benefits of wind power, not including all of the hidden costs makes wind power appear to be a more attractive option than it actually is. Energy policy decisions, however, should be based on a more complete estimate of the cost of wind energy.

FEDERAL POLICIES STATE POLICIES CAPITAL COSTS OPPORTUNITY COST OPERATION & MAINTENANCE COSTS REDUCED RELIABILITY CAPACITY FACTOR BASELOAD CYCLING TRANSMISSION COSTSCAPITAL COSTS SOCIAL AND ENVIRONMENTAL COSTS EXPLICIT COSTS + IMPLICIT COSTS = TRUE COST OF WIND ENERGY

(EX 22 P.10, The True Cost of Wind, Institute of Political Economy, Simmons, Yonk, and Hansen, July 2015, Utah State University)

McKinsey issues its strongest warning when it comes to Germany’s increasingly insecure energy supply due to its heavy reliance on intermittent solar and wind. For three days in June 2019, the electricity grid came close to black-outs.

“Only short-term imports from neighboring countries were able to stabilize the grid,” the consultancy notes.

As a result of Germany’s energy supply shortage, the highest observed cost of short- term “balancing energy” skyrocketed from €64 in 2017 to €37,856 in 2019.

“It can be assumed that security of supply will continue to worsen in the future,” says McKinsey.

Renewables are causing similarly high price shocks in other parts of the world including Texas,

Australia, and California.

And Britain and Australia have faced similar energy supply problems in recent years as they have attempted to transition to intermittent renewables.

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“Wind generation, solar and interconnectors are different to the conventional electricity generation sources,” Britain’s National Grid said in a report after lightning knocked a wind farm and natural gas plant off the grid in August, causing a black-out in London.

Australia electricity regulators in August sued four wind farm operators for contributing to a huge blackout in 2016.

Bloomberg News, which strongly advocates renewable energy, last week called the supply problems a “warning shot to the rest of the world.”

(EX 20, Renewables Threaten German Economy & Energy Supply, McKinsey Warns In New Report, Forbes, 5 September 2019)

Is this what we want for our future in Iowa?

“We have to have systems in place to make sure we still have enough generation on the grid — or else, in the best case, we have a blackout, and in the worst case, we have some kind of grid collapse,” Severin Borenstein, a University of California energy economist told Bloomberg. (EX. 20. Renewables Threaten German Economy & Energy Supply, McKinsey Warns In New Report, Forbes, 5 September 2019)

It seems that this talk of cheaper electricity is just more hot air. What is referred to as the

"levelized cost of electricity" is the process of making an apples-to-apples cost comparison of new renewable energy sources with existing coal-fired electricity. The analysis that shows renewable energy being less expensive did not include the costs that renewables place on traditional – dispatchable - energy sources. Renewable energy is dependent on favorable weather conditions and that variability requires utilities to maintain baseline backup sources of electricity. When all costs are factored in, the LCOE for existing coal plants is about $41 per

MWh, less than half the $90 cost of new wind and solar projects. It seems that this talk of cheaper electricity is just more hot air. What is referred to as the "levelized cost of electricity" is the process of making an apples-to-apples cost comparison of new renewable energy sources with existing coal-fired electricity. The analysis that shows

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renewable energy being less expensive did not include the costs that renewables place on traditional – dispatchable - energy sources. Renewable energy is dependent on favorable weather conditions and that variability requires utilities to maintain baseline backup sources of electricity. When all costs are factored in, the LCOE for existing coal plants is about $41 per

MWh, less than half the $90 cost of new wind and solar projects.

Despite the math, some lawmakers in Minnesota are pushing to double the state’s Renewable

Energy Mandate. The good folks at Minnesota-based Center of the American Experiment have crunched the numbers and found that a 50% Renewable Energy Standard would cost each household $1,200/ year. Not quite the savings you were expecting. (Betty Grande: A Dangerous Push

Towards renewables, Inforum, 16 February 2020) Before any decision for a new investment in transmission is made it just seems prudent that decision-makers have all the facts before them.

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CEI claims Ms. Grice also objects to what she claims is Iowa’s transformation from an agricultural state into an “industrial energy generation complex” without citizen input. (Grice Pre-Hearing Brief at 3.) In making this claim, Ms. Grice ignored established state law that helped facilitate this transformation. State policy, adopted by elected legislators, calls for the state to “attract the development of electric power generating and transmission facilities” and to “encourage the development of renewable electric power generation.” (Iowa Code §§ 476.53, 476.53A.) State policy specifically encourages the development of alternative energy production facilities, which by definition include solar and wind generation. (Iowa Code §§ 476.41, 476.42.) ( CEI Intervenors Post- hearing Brief p. 29.)

CEI Intervenors forget to note there are many, many individuals and groups in the State of Iowa, citizens of the state, working to fight the very laws CEI refers to. The laws referred to were made in haste, dictated by clean energy lobbyists unbeknownst to the people, and without regard for THE approval of those who are affected. These laws do not adequately address property rights and

Iowan’s being forced to live too near turbines and transmission lines and will result in many lawsuits if not amended to protect property rights. Current laws do not address the health issues of turbines or lines. The laws do not address decreases in property values caused by adjacent lines or turbines where nearby property values may decrease by 50% or more. (EX 28 Appraisal Goche) (McCann EX 26)

Much needs to be done to protect property rights of Iowans in this regard. Citizens of Iowa are protesting this law as have citizens in other states.

Iowa’s neighboring state, Missouri, is in the midst of a battle to prevent the developer of the

Grain Belt Express transmission line from acquiring farmland via eminent domain. The fight is now in the hands of the Missouri Senate.

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Two weeks ago, the Missouri House of Representatives passed by a 118-42 margin a bill sponsored by Rep. Jim Hansen, R-Frankfort, whose district includes Ralls and Monroe counties. His bill will prohibit developers of the 4,000-megawatt a day high-level transmission project from forcing landowners to sell property. (EX.27 Hannibal Courier-Post, Feb 5, 2020)

On 24 July 2019 the Attorney Generals of both Illinois and Michigan filed an Amicus Brief against the CHC Line in Wisconsin because they don’t want to have to pay for it. (EX 25 Amicus

Brief Illinois and Michigan State Attorney Generals) They requested a full current review. In addition, there have been numerous appeals filed against the Public Service Commission of Wisconsin’s decision regarding the CHC line and one of the commissioners has resigned. At present the

Wisconsin portion of the CHC is indefinite. The Wisconsin CHC is an extension of the Iowa

CHC.

Among the changes that necessitate a full, current review of the project are:

1. Load growth has slowed down considerably since 2011, with load shrinking or remaining constant year-over-year. As a result, the growth in demand and for capacity that the line anticipated have not occurred.

2. Distributed generation, such as local solar generation, reduces the demand on long distance transmission lines. Existing and proposed solar projects in Wisconsin will affect the need for additional transmission capacity, and should be considered as part of the analysis of the need for and the costs of the line.

3. Technical developments in battery storage, especially when combined with expanded wind and solar renewable capacity, can be expected to reduce the need for additional transmission capacity, and should be considered as part of the analysis of the need for and the costs of the line.

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4. The growth of renewable energy capacity in Wisconsin as well as in Illinois and Michigan since 2011 should be considered in assessing whether the transmission line is needed to meet

Midwest renewable energy goals. The extent to which the line is needed to import wind energy from other states must be balanced against the fact that the proposed line is an “open access” line that any type of generation can use, not just wind. The line is not limited to renewable power. The lack of recent peak load growth, associated with the expansion of distributed solar, wind and battery technologies, creates a very different situation from that analyzed in 2011 when the line was originally proposed. It is necessary to consider recent alternatives to determine whether the transmission line is needed. (EX 25, States of Michigan and Illinois

Amicus Brief filed against the Wisconsin CHC proposed transmission line, 24 July 2019)

Both Michigan and Illinois as well as Wisconsin are installing more and more local solar and community solar and do not need or want Iowa’s wind energy making the CHC line unnecessary….A LINE TO NOWHERE!

Citizens all over the country are standing up for their rights that are being taken away for the profit of large companies and government.

Iowa’s laws or economic analysis also do not address the massive cleanup that will be required once the green energy scam is revealed.

The wind industry is like the partying college students that trash their parent’s house, never sparing a thought about cleaning up the mess afterwards.

With subsidies being slashed across the globe, the great wind industry ‘party’ will inevitably draw to a close. And the adults will need to raise the tricky issue about who cleans up the mess? And who pays? (EX. Rusting Monuments to Stupidity: Staggering Cost of Cleaning Up the Wind Industry’s

Giant Mess, Stop These Things, 25 Jan 2020)

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Thousands of 45-70m blades are being ground up and mixed with concrete used in the bases of other turbines erected later or simply dumped in landfill. Which should worry locals: the plastics in the blades are highly toxic, and contain Bisphenol A, which is so dangerous to health that the European Union and Canada have banned it (EX. 31, The Renewable Green Energy Myth:

50,000 Tons Of Non-Recyclable Wind Turbine Blades Dumped In The Landfill, Steve St. Angelo, SRS Rocco Report, January 9,

2020)

What is this doing to our groundwater? What is it doing to the rich, precious soil where we grow our foods? This is toxic waste being buried all over Iowa’s rich, food producing soils and contaminating our water supplies!

Iowans’ homes are also being threatened and Iowans’ quality of life diminished by the “green” energy debacle. Noise and vibrations rock what were once peaceful bucolic landscapes. Iowans’ property values are decreasing. No one wants to live in the middle of and industrial energy complex.

The home in the photo above was made uninhabitable by wind turbine noise and vibration. The family who once lived here were forced to abandon their home in 2006. Three years later, it remains empty and unsold. (EX.26, Mcann, P 82)

There is presently broad public outcry in Iowa regarding citizen’s property rights which are being infringed upon by the transmission easements and by the turbines which emit infrasound damaging to

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human and animal health , shadow flicker, ice throw, blade throw, and just plain noise. Now we have learned there is toxic waste in the form of ground up turbine blades in the turbine foundations.

The turbines destroy forever farmland that is used for food production. Just as the Germans rebelled against the utility companies’ destruction of rural property rights so are America’s rural communities beginning to rebel against the scam the utility companies have pulled on our elected officials.

Iowans expect more of our elected officials. Iowans expect them to study in depth before they make decisions and to allow the people a say in decisions that essentially transform rural Iowa prime agricultural land and residences into an industrial energy complex/ toxic waste dump.

Iowans or Americans are not the only ones protesting the wind lobby claims.

Despite phony wind lobby surveys claiming that over 90% of Germans support an expansion of wind power (and only a 5% fringe oppose), German wind park projects have hit the brick wall of intense citizens’ protest. (EX. 30, German Wind Projects Hit Intense Citizens’ Protests, Dividing Once

Harmonious Communities, No Tricks Zone, Pierre Gosselin, 28 January 2020)

OCA is concerned that statements by MS Grice on record will tarnish their reputation. MS. Grice disagrees that it is statements SHE has made that tarnish OCA but, rather the actions or lack thereof, of OCA to represent the citizens of Iowa that tarnishes their reputation.

OCA disputes certain statements in the Grice Objection regarding OCA’s work and positions taken by OCA in transmission-related proceedings. OCA is concerned that Ms. Grice’s non-record assertions could discourage members of the public from contacting OCA with questions or concerns about transmission-related matters. The record must be clear on this: OCA values and

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encourages input from Iowa consumers and members of the Iowa public.

(OCA Post Hearing Brief, P 3)

Facts from the hearing and Mr. Bents’ testimony leave great doubt as to whether or how the OCA represents Iowa Citizens. Mr. Bents gave virtually no answers at the hearing to indicate he even knew if or how he represents the public in this decision. He also had very little knowledge of the case and could not answer numerous questions posed to him. His seeming lack of knowledge of the situation leaves Iowans to wonder just WHO is representing the citizens of this state?

OCA is the only entity in the MISO list of strategic partners that represents the public interest. (EX

24 MISO Current Members by Sector.) Yet, despite questioning through Direct and Re-Direct plus questions directed at OCA at the hearing MS Grice has been unable to ascertain that the OCA is representing interests of the ratepayers or taxpayers in this case. In fact, Witness for OCA Bents testified that he does not vote in MISO planning. In addition, he could give very few answers that could shed any light on the situation.

A Witness Bents: Based on my experience, yes, the public consumer sector typically abstains on votes when it comes to transmission projects as well as MTEP. (T-P 692, lines 9-11).

So where is the voice of the ratepayers? WHO is representing the ratepayers in transmission line planning?

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OCA RESPONSE [to Grice Data Request No 4]:

A) OCA is not a member of MISO. OCA employees have served as a Public

Consumer Sector representative of PAC for approximately ten years. The Public

Consumer Sector has a vote on the Planning Advisory Committee. A vote of the

Public Consumer Sector is not a vote of OCA.

B) OCA does not maintain a record of the Public Consumer Sector representative

votes on PAC items. For voting items such as this, which will result in transmission

franchise applications to various state regulatory commissions, Public Consumer

Sector representatives would typically abstain.

(C) OCA representatives who may have participated as PAC representatives at

meetings concerning PAC approval or disapproval of MISO Transmission Expansion

Plans include: Larry Shi, Jennifer Easler, John Long and Scott Bents. OCA does not

maintain a record of these votes. 9(RESPONSE OF OFFICE OF CONSUMER ADVOCATE TO

INTERVENOR LINDA GRICE DATA REQUEST NO. 4 SUPPLEMENTAL)

Q. Intervenor Isenhart: The Office of Consumer Advocate, can you define their role for us in terms of their general responsibilities?

A. Witness Bents: The OCA's role is to represent the Iowa ratepayer in all proceedings before the Board. (T-P660, lines 19-23)

Q. Intervenor Isenhart: Did the Consumer Advocate participate in the proceedings in regard to the approval of those lines?

A. Witness Bents: Yes, they did.

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Q. And in those proceedings, did the Consumer Advocate conduct any public meetings with ratepayers in or around where those lines were to go?

A. I'm not aware of that.

Q. Are you aware of whether the MISO, MidContinent Independent System Operator, had any public information meetings specifically in Iowa to discuss those projects?

A. No, I'm not aware of that, either. (T-P661, lines 14-25)

Q. As a stakeholder in MISO, would you have had the ability or opportunity to ask that MISO come to,say, Dubuque County for a public information meeting on this project?

A. I don't know if the OCA would have the ability to ask--I'm sure the OCA could ask MISO to do it, but I don't know if OCA could convince MISO to do it.

A. The direct economic impacts to ratepayers at the retail level have not been studied.

(Tr p667 line 25 and P 668, line 1)

Chairperson Huser: Do you consult with ratepayers?

THE WITNESS: Yes, we do.

CHAIRPERSON HUSER: Do you know whether or not you consulted with ratepayers as it relates to any MISO votes that occurred in the years 2011 through 2017?

THE WITNESS: I don't recall.

(T-P 680, lines 19-25 and P 681, line 1)

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So who is representing ratepayers??? The OCA does not have answers to this question.

Obviously, it is not MS Grice that is tarnishing OCA’s reputation of not representing the public but the non-actions of the OCA itself!

Electric rates have been increasing in Iowa over the last few years despite the purported efficiencies of wind energy.

CEI-Prehearing –Brief-7

This provides Iowa and regional electricity customers with access to lower-cost wind energy by allowing more customers to access some of the least expensive wind resources in the MISO footprint. (CEI Goggin Direct at 13.)

The public questions, with all of the wind power present in Iowa and the percentage of wind used being high, why are Iowa electric rates going up? This is a phenomenon observed in all regions wind energy has been implemented. Wind being low-cost is empty rhetoric with no proof by the

CEI or anyone else.

LT. Governor Peggy Flanagan and other lawmakers recently traveled to Germany to supposedly learn about Germany’s “Energy Transition,” and bring home useful lessons that can be gleaned for Minnesota’s energy future.

From what I can tell, the group didn’t get their money’s worth, because almost all of the media covering Germany’s attempt to close their nuclear plants and rely on wind and solar are saying that the policy is a disaster.

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It’s not just people who work at think tanks, either. In fact, consulting giant Wood McKinsey wrote that Germany’s energy policy poses a significant threat to the nation’s economy and energy supply (EX. 21, Renewables Threaten German Economy & Energy Supply, McKinsey Warns In New Report, Isaac Orr,

Climate, Energy, and Environment, 20 September 2019)

Regardless of how cost factors are considered, the true cost of wind energy in the United States is, on average, 48 percent higher than most estimates claim. This is because generating electricity from wind power entails many hidden costs. A true estimate of the cost of wind power to the American public must account for the following factors: The federal PTC, a crucial subsidy for wind producers, has distorted the energy market by artificially lowering the cost of expensive technologies and directing taxpayer money to the wind industry. States have enacted Renewable Portfolio Standards (RPS) that require utilities to purchase electricity produced from renewable sources, which drives up the cost of electricity for consumers. Wind resources are often located far from existing transmission lines. Expanding the grid, whether by private or public funding, is expensive, and the costs are passed on to taxpayers and consumers. Because wind power is unreliable, conventional generators must be kept on backup to meet demand when wind is unable to do so. This drives up the cost of electricity for consumers, as two plants are kept running to do the job of one. Billions of taxpayer dollars are used to subsidize the wind industry. Allowing consumers to pick which energy to use, based on price, would result in greater economic efficiency than allowing government to decide how the resources of consumers should best be allocated. (The True Cost of Energy: Wind Power, Simmons, Yonk, & Hansen; Strata, Key Findings, July

2015, Utah State University)

Iowa needs to take a look at the true cost of building transmission assets to facilitate green energy development.

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Filed with the Iowa Utilities Board on February 17, 2020, E-22386

According to the US Energy Information Administration (EIA), nearly two thirds of the energy that goes into the U.S. electrical power grid is lost through conversion to mechanical energy and transmission distribution before it reaches users.

(‘EX. 33, Green Energy’ Capacities Are Overblown Hot Air, News Max, Larry Bell, 9 December 2019)

There are many other ways to conserve energy and limit CO2 emissions without adding on debt and disaster for future generations. Individual and community generated electricity with battery storage does not require transmission over long distances that leads to the loss of 2/3 the amount of energy originally generated. It also gives local people a say in their property rights and their legacy to pass to future generations. It allows communities and individuals to determine their own futures instead of having big utility companies (ITC is over 90% foreign-owned) and government determine our future. Many states and communities are subsidizing individuals and small businesses for energy assets instead of subsidizing dependence on large foreign companies.

By doing so taxpayer dollars are returned to the citizens instead of being transferred to large corporations.

No economic analysis has been done on this specific project so it does not meet Iowa Code 2019,

Chapter 476.53(2) To do an economic analysis all the costs need to be included including costs to taxpayers and ratepayers over the lifespan of the project. If this were done the smaller, low- cost alternatives of individual and community generation and storage would outshine the CHC transmission line by far. As a farmer, MS Grice knows the worst economic situation she can get into when hard times come is having too many expensive unnecessary assets. She can’t imagine it would be much different for our state. This economic analysis is vital to our state’s future.

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Filed with the Iowa Utilities Board on February 17, 2020, E-22386

Economic analysis of a project standing on its own is an important part of any business that is successful. The utility business is no different than any other business except that, if it sidesteps planning analysis and fails to meet its projected goals, ratepayers and taxpayers will be on the hook for massive amounts of money. As a result, taxpayers and ratepayers should be involved in these decisions through their vote. At present, there is no step in the process that gives those paying for this utility build-out a voice in the process.

III. Conclusions

A utility buildout of MISO proportions is a matter for the people responsible for paying to decide. Those people are the ratepayers and taxpayers of Iowa…not huge energy companies or well-paid attorneys opposing citizens’ interests. This proposed utility build-out has huge implications on the people’s lives it touches and their very futures as well as those of generations to come.

Taxpayers and ratepayers need to hear all the facts…not just the oftentimes misleading information put out by the utilities through their paid lobbyists such as the CEI. Taxpayers and ratepayers need to see a true and COMPLETE economic analysis of this build-out…not the deceptive figures presented by the utility companies and lobbyists. Taxpayers and ratepayers need to have a chance to determine whether or not they want their homes and communities to become an industrialized utility complex with utility debt that can never be paid off. Few

Iowans do want this outcome…they chose Iowa to live and work in because of its agricultural

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Filed with the Iowa Utilities Board on February 17, 2020, E-22386

heritage and they want to keep it that way. They want our legislators and decision-makers to be fiscally responsible. Iowa’s future depends upon it!

AFTER this true and COMPLETE economic analysis is complete Iowa communities should be given a vote on what they perceive as their communities’ future. Each community should be given a choice on whether or not they want to become a part of this massive industry-scale utility build out. If one community wants its future to be large-scale energy production let that community invest in transmission, industrial wind, and industrial solar. If another community wants to retain its authenticity and reduce debt load let that community retain it. Property rights are a valuable heritage in America and in Iowa and should not be stripped away by big energy. big government, and lobbyists.

Eminent domain is a very serious matter. It takes away people’s property rights and interferes with their ability to make a living for themselves and their families. It decreases property values all around the vicinity. It should never be undertaken at the whim of greedy utility companies in cohort with lobbying organizations who are seeking huge personal gains at the expense of rural

Iowans.

Citizen Intervenors should be valued for their first-hand knowledge of the effects of a large-scale transmission build-out. Such a build-out affects communities where people live and work, it affects property values and wellness. Instead the CEI wants to squelch citizen intervenors’ voices and make decisions concerning our properties, our futures, and our health from their cushy office chairs while they are being paid huge sums of money to silence us. They want to

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Filed with the Iowa Utilities Board on February 17, 2020, E-22386

make decisions about our lives and our properties because they think they know better than we do what is best for us. Iowans know what is best if they are given the tools to analyze the future.

Hiding part of the economic facts will only come back to bite the perpetrators in the future.

It is time the citizens and ratepayers of Iowa have a say in their futures. Decisions made by big government, big corporations, and paid lobbyists in an effort to control our properties is unacceptable in America. Control over these matters needs to be given back to the voters at local elections to determine the future of our communities.

It is for these reasons and the reasons MS Grice has previously stated that Ms Grice asks that the

IUB deny the CHC Franchise.

/s/ Intervenor Linda E Grice

25739 170th St,

South English, IA 52335-8636

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Filed with the Iowa Utilities Board on February 17, 2020, E-22386

Exhibits Included:

EX 20 Renewables Threaten German Economy & Energy Supply, McKinsey Warns In New Report - American Experiment EX 21 Full-Report- The True Cost of Wind, Institute of Political Economy, Simmons, Yonk, and Hansen, July 2015, Utah State University) EX 22 Unreliable Nature Of Solar And Wind Makes Electricity More Expensive. (Simmons, Yonk, & Hansen. July 2015, Institute of Political Economy, Utah State University)

EX 23 Warren Buffett is spending billions to make Iowa 'the Saudi Arabia of wind' — but climate change isn't the reason, Theron Mohamed, Markets Insider, 30 DECEMBER 2019

EX, 24 MISO Current Members by Sector, Docket E-22386, 2 Jan 2020 EX. 25 Amicus Brief, Attorneys General States of Michigan and Illinois EX 26 McCann Appraisal, LLC-Setbacks-property-values

EX 27 Grain Belt Express fight moves to Missouri Senate, Hannibal Courier-Post, 5 Feb 2020

EX 28 Appraisal-Goche, 14 JUNE 2016, IUB Docket E-22116

EX 29 Unreliable Nature of Solar And Wind Makes Electricity More Expensive, New Study Finds (Forbes, Energy, Michael Shellenberger, Study by Michael Greenstone, Richard McDowell, and Ishan Nath, University of Chicago, 22 AUG 2019)

EX.30, German Wind Projects Hit Intense Citizens’ Protests, Dividing Once Harmonious Communities, No Tricks Zone, Pierre Gosselin, 28 January 2020)

EX.31, The Renewable Green Energy Myth: 50,000 Tons Of Non-Recyclable Wind Turbine Blades Dumped In The Landfill, Steve St. Angelo, SRS Rocco Report, January 9, 2020 EX. 32, Rusting Monuments to Stupidity_ Staggering Cost of Cleaning Up the Wind Industry’s Giant Mess – STOP THESE THINGS, 25 January 2020

EX. 33, Green Energy’ Capacities Are Overblown Hot Air, News Max, Larry Bell, 9 December 2019

EX 34: Betty Grande: Grande: A dangerous push towards renewables, Inforum, 16 February 2020

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