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The following opinion is presented on-line for informational use only and does not replace the official version. (Mich Dept of Attorney General Web Site - www.ag.state.mi.us)



STATE OF MICHIGAN

FRANK J. KELLEY, ATTORNEY GENERAL


Opinion No. 6311

August 9, 1985

PUBLIC SERVICE COMMISSION:

Authority to review the need for electric transmission lines

The Public Service Commission has authority, either on its own motion or upon complaint, to review the need for electric transmission lines which are proposed or under construction by a nonmunicipal public utility.

A nonmunicipal public utility must obtain a certificate of public convenience and necessity from the Public Service Commission as a prerequisite to the construction of electric transmission lines located outside of such utility's service territory, but need not obtain such a certificate as a prerequisite to constructing electric transmission lines within such utility's service territory.

Honorable George C. Furton

State Representative

State Capitol Building

Lansing, Michigan

You have requested my opinion regarding the jurisdiction of the Michigan Public Service Commission (MPSC) relative to the construction of electric transmission lines. Your question is:

'Does the Michigan Public Service Commission have the authority to act upon a complaint questioning the need for proposed transmission lines and . . . to make a determination as to the need for such a line?'

The above question is prompted by the Detroit Edison Company proposal to construct a 22-mile, 345 KV, heavy-duty transmission line within its service territory in southeastern Michigan. The line is called the Saratoga-Jewell transmission line, and will connect various Edison generating plants including the Saratoga station in Columbus Township, St. Clair County and extending through Richmond, Armada, Bruce and Washington Townships, Macomb County to Edison's Jewell station. The line will provide an alternate transmission route and become a part of the bulk power transmission facilities serving Edison's system including the newly constructed Belle River Power Plant.

In evaluating the jurisdiction and authority of the MPSC, the courts of our state have held that it is a creature of statute with no inherent or common law powers, and that its jurisdiction in any instance must affirmatively appear in a statute before it can be invoked or exercised. Taylor v Michigan Public Utility Commission, 217 Mich 400, 402; 186 NW 485 (1922), Sparta Foundry Co v Michigan Public Utility Commission, 275 Mich 562; 267 NW 736 (1936), Huron Portland Cement Co v Public Service Commission, 351 Mich 255; 88 NW2d 492 (1958). In determining the extent of MPSC jurisdiction it is also important to ascertain and give effect to legislative intent. Franks v White Pine Copper Division, Copper Range Co, 122 Mich App 177; 332 NW2d 447 (1982). 22 Callaghan's Michigan Civil Jurisprudence, 'Statutes,' Sec. 108, pp 379-380. Legislative intent is ascertained by looking to the language used in the applicable statutes, their subject matter, scope, purpose and any prior or related statutes. In re School District No 6, Paris & Wyoming Twps, Kent County, 284 Mich 132; 278 NW 792 (1938), Romeo Homes, Inc v Commissioner of Revenue, 361 Mich 128, 135-137; 105 NW2d 186 (1960), Schoolcraft County Board of Commissioners v Schoolcraft Memorial Hospital Board of Trustees, 68 Mich App 654; 243 NW2d 708 (1976), lv den 397 Mich 838 (1976).

The enabling statutes applicable to the MPSC indicate that the Legislature intended the MPSC to have broad jurisdiction and regulatory authority over public utility matters. Specifically, the public service commission act, MCL 460.6; MSA 22.13(6), states:

'(1) The public service commission is vested with complete power and jurisdiction to regulate all public utilities in the state except a municipally owned utility, the owner of a renewable resource power production facility as provided in section 6d, and except as otherwise restricted by law. The public service commission is vested with the power and jurisdiction to regulate all rates, fares, fees, charges, services, rules, conditions of service, and all other matters pertaining to the formation, operation, or direction of such public utilities. The public service commission is further granted the power and jurisdiction to hear and pass upon all matters pertaining to, necessary, or incident to the regulation of all public utilities, including electric light and power companies, whether private, corporate, or cooperative, gas companies, water, telephone, telegraph, oil, gas, and pipeline companies, motor carriers, and all public transportation and communication agencies other than railroads and railroad companies.

'(2) The commission shall have the same measure of authority with respect to railroads and railroad companies as is granted and conferred under the various provisions of law creating the Michigan railroad commission and its successor, the Michigan public utilities commission, and defining their powers and duties.'

Further, MCL 460.4; MSA 22.13(4), states, in pertinent part:

'All the rights, powers and duties vested by law in the Michigan public utilities commission, and in the Michigan railroad commission and transferred to the Michigan public utilities commission, shall be deemed to be transferred to and vested in the public service commission hereby created, and shall be exercised and performed by it. The public service commission shall have and exercise all rights and privileges and the jurisdiction in all respects as has been conferred by law and exercised by the Michigan public utilities commission under the laws of this state; . . ..'

The Legislature in the above statutes has expressly stated that the MPSC is vested with all the rights, powers, duties and jurisdiction previously conferred upon and exercised by the Michigan Railroad Commission and the Michigan Public Utilities Commission. Thus, the enabling statutes of the predecessor commissions are applicable to the present commission.

The predecessor Michigan Railroad Commission was granted widespread regulatory powers pursuant to the railroad act, MCL 462.2 et seq; MSA 22.21 et seq. For instance, MCL 462.22; MSA 22.41, grants the MPSC the power, either upon complaint or its own motion, to investigate adequacy of service, rate matters, utility practices, etc., and to hold hearings, issue cease and desist orders, and make binding orders regarding such matters. Further, MCL 462.44; MSA 22.62, goes so far as to vest the MPSC with the 'police powers of the state' over railroads and railway matters. By Executive Order of the Governor, 1975-1, MCL 247.822; MSA 9.216(102), regulation of railroads was transferred to the State Highway Commission. This executive reorganization does not diminish the substantive powers of the MPSC over utilities, particularly in view of MCL 460.54; MSA 22.4, and the above-quoted sections of the public service commission act, which authorize the MPSC to exercise the same authority over other utilities as it possessed with respect to railroads.

The jurisdictional authority of the predecessor Michigan public utilities commission is set forth in relevant part in public utilities commission act, MCL 460.54, 460.55 and 460.58; MSA 22.4, 22.5 and 22.8, as follows:

'[The Commission's] . . . jurisdiction shall be deemed to extend to and include the control and regulation, including the fixing of rates and charges, of all public utilities within this state producing, transmitting, delivering or furnishing steam for heating or power, or gas for heating or lighting purposes for the public use . Subject to the provisions of this act the said commission shall have the same measure of authority with reference to such utilities as is granted and conferred with respect to railroads and railroad companies under the various provisions of the statutes creating the Michigan railroad commission and defining its powers and duties. The power and authority granted by this act shall not extend to, or include, any power of regulation or control of any municipally owned utility; . . .' MCL 460.54; MSA 22.4

'The commission shall also have authority to make and prescribe regulations for the conducting of the business of public utilities, subject to the jurisdiction thereof, and it shall be the duty of every corporation, joint stock company, association or individual owning, managing or operating any such utility to obey such rules and regulations.' MCL 460.55; MSA 22.5

'Upon complaint in writing that any rate, classification, regulation or practice charged, made or observed by any public utility is unjust, inaccurate, or improper, to the prejudice of the complaint, the commission shall proceed to investigate the matter. The procedure to be followed in all such cases shall be prescribed by rule of the commission: Provided, however, That in all cases reasonable notice shall be given to the parties concerned as to the time and place of hearing. . . . Upon the completion of any such hearing, the commission shall have authority to make an order or decree dismissing the complaint or directing that the rate, charge, practice or other matter complained of, shall be removed, modified or altered, as the commission deems just, equitable and in accordance with the rights of the parties concerned.' MCL 460.58; MSA 22.8

The above statutes, and particularly MCL 460.58; MSA 22.8, clearly grant the MPSC authority to investigate, hold hearings and issue binding orders regarding complaints filed against utilities.

Additional statutes detail the commission's jurisdiction to regulate electric utilities and the transmission of power. MCL 460.551 et seq; MSA 22.151 et seq, confers upon the MPSC certain powers in regard to regulating the transmission of electricity, the charges for such, and the rules and conditions of service under which said electricity shall be furnished. Relevant portions of this statute provide:

'When electricity is generated or developed by steam, water or other power, within one (1) county of this state, and transmitted and delivered to the consumer in the same or some other county, then the transmission and distribution of the same in or on the public highways, streets and places, the rate of charge to be made to the consumer for the electricity so transmitted and distributed and the rules and conditions of service under which said electricity shall be transmitted and distributed shall be subject to regulation as in this act provided.' MCL 460.551; MSA 22.151

'The Michigan public utilities commission, hereinafter referred to as 'the commission' shall have control and supervision of the business of transmitting and supplying electricity as mentioned in the first section of this act and no public utility supplying electricity shall put into force any rate or charge for the same without first petitioning said commission for authority to initiate or put into force such rate or charge and securing the affirmative action of the commission approving said rate or charge.' MCL 460.552; MSA 22.152

'Every person, firm or corporation erecting any lines for the transmission of electricity in or through the highways, streets or public places of one (1) or more counties of this state shall, from time to time, as and when required to do so by the commission, prepare and file with the commission such data and information as shall be required relative to the method and manner of the construction of such lines, the franchise or consent under which said lines were constructed or are being maintained, and such other information as the commission may reasonably require.' MCL 460.554; MSA 22.154

The remainder of MCL 460.554; MSA 22.154, goes on to require the providing of detailed specifications regarding the type of construction of transmission lines, the requirement for prior approval thereof by the MPSC, and adherence by utilities to commission orders and regulations regarding line construction.

MCL 460.555; MSA 22.155, grants the MPSC power to inspect electrical apparatus and to investigate and issue binding orders regarding 'the method employed by persons, firms, or corporations transmitting and supplying electricity.'

Pursuant to the above sections, among other statutory provisions, the MPSC has promulgated regulations governing the construction of electrical transmission lines, which include requirements for the filing with the commission of detailed specifications regarding proposed transmission lines and the procedures for obtaining prior MPSC approval of such lines. MAC 1979, R 460.581 et seq. The MPSC has also promulgated rules governing the underground placement of certain electric distribution lines. MAC 1979, R 460.511 et seq.

MCL 460.557; MSA 22.157, reiterates the commission's authority to act on complaints against electric utilities:

'Upon complaint in writing by any consumer or city, village, or township, by its duly constituted common or village council or township board, or other duly constituted authority of such city, village or township, relative to the price of the electricity sold and delivered in such municipality, or with reference to the service rendered or any other matter of complaint, the commission shall investigate such complaint and may by its agents, examiners, inspectors, engineers and accountants inspect the system and method used in transmitting and supplying electricity and examine or cause to be examined the books and papers of such person, firm or corporation pertaining thereto. . . . After such investigation and hearing, the commission within lawful limits may by order fix the price of electricity to be charged by such person, firm or corporation, . . .. Said commission may also by order establish such rules and conditions of service as shall be just and reasonable.'

Further, MCL 460.501 se seq; MSA 22.141 et seq, prohibits a nonmunicipal gas or electric utility from beginning the construction or operation of any public utility plant or system in a territory already receiving similar service from another utility without first obtaining from the MPSC a certificate that public convenience and necessity requires or will require such construction, operation, service or extension. Relevant portions of the Act provide:

'No public utility shall hereafter begin the construction or operation of any public utility plant or system thereof nor shall it render any service for the purpose of transacting or carrying on a local business either directly, or indirectly, by serving any other utility or agency so engaged in such local business, in any municipality in this state where any other utility or agency is then engaged in such local business and rendering the same sort of service, or where such municipality is receiving service of the same sort, until such public utility shall first obtain from the commission a certificate that public convenience and necessity requires or will require such construction, operation, service, or extension.'

MCL 460.502; MSA 22.142

'In determining the question of public convenience and necessity the commission shall take into consideration the service being rendered by the utility then serving such territory, the investment in such utility, the benefit, if any, to the public in the matter of rates and such other matters as shall be proper and equitable in determining whether or not public convenience and necessity requires the applying utility to serve the territory. Every certificate of public convenience and necessity issued by the commission, under the authority hereby granted, shall describe in detail the territory in which said applicant shall operate and it shall not operate in or serve any other territory under the authority of said certificate.'

MCL 460.505; MSA 22.145

The Legislature has also referenced the MPSC's jurisdiction and expertise to make necessity determinations regarding electric transmission lines by providing that, in those instances wherein a MPSC certificate of necessity is required, the granting by the MPSC of a certificate shall be given prima facie effect by a court conducting related condemnation proceedings with respect to the need for a particular parcel of land. In this regard, the Uniform Condemnation Procedures Act, MCL 213.56(3); MSA 8.265(6)(3), as quoted in In Re Acquisition of Lands, 137 Mich App 161, 169; 357 NW2d 843 (1984), lv den 422 Mich 861 (1985), states:

"With respect to an acquisition by a private agency, the court at the hearing shall determine the public necessity of the acquisition of the particular parcel. The granting of a permanent or temporary certificate by the public service commission shall constitute a prima facie case that the project, in furtherance of which the particular parcel would be acquired, is required by the public convenience and necessity."

Taken as a whole, the above statutory provisions clearly indicate legislative intent to grant the MPSC broad powers over electric utilities and the transmission of power, and specifically, to investigate, hold hearings and issue binding orders, pursuant to complaint or its own motion, with respect to matters involving nonmunicipal utilities, including electric utilities under its jurisdiction. It is not necessary to the exercise of such jurisdiction that the statutes delineate each specific topic or issue which may be the subject of a commission investigation, hearing or order. It is sufficient that the issue under consideration in a proceeding involves a nonmunicipal public utility and a subject matter which is under the commission's jurisdiction. Chesapeake & O R Co v Public Service Commission, 59 Mich App 88, 97; 228 NW2d 843, 1v den 394 Mich 818 (1975).

The above conclusion is buttressed by court decisions which emphasize the MPSC's powers to investigate, hold hearings, and issue orders regarding utility matters. For instance, in Chesapeake & O R Co v Public Service Commission, pp 94-95, the Court of Appeals upheld the MPSC's authority to initiate investigations, hold hearings, and issue appropriate orders regarding freight service, rejecting the railroad's contentions that the MPSC by statute could only act upon a complaint charging inadequate service. In reviewing the statutory history of the MPSC, the court concluded that the MPSC was 'created to vigorously regulate all public utilities' and possessed broad powers to protect the consumer:

'The history of the Public Service Commission manifests a clear legislative intent that the commission should be able to conduct investigations without a prior complaint by a consumer. The Commission was originally established to protect the consumer. The Legislature sought to remedy the imbalance between utilities and the consumer by creating an agency which would be a watchdog for and representative of the consumer.' 59 Mich App at 94

The courts have also specifically upheld the MPSC's power to determine the need for proposed or ongoing utility construction projects. In Attorney General v Mich Public Service Commission, 412 Mich 385; 316 NW2d 187 (1982), the Michigan Supreme Court reviewed the question as to whether the Utility Securities Act, MCL 460.301; MSA 22.101, which provides the MPSC with jurisdiction over certain utility security issuances, required the MPSC to review the need and necessity for construction projects being financed by the proposed securities. While the Supreme Court held that the Utility Securities Act itself did not provide for a MPSC determination regarding the need for the project to which funds will be devoted, the Supreme Court did affirmatively find that the MPSC possessed the power to review and determine the need for utility plant construction pursuant to its ratemaking authority and various enabling acts which grant the MPSC the power to investigate and resolve complaints involving utilities:

'The intervenors' assumption that the utility securities act provides the only means of inquiry into the reasonableness of plants during construction is inaccurate. At least two statutory methods, other than a securities issue proceeding, provide an opportunity for review of the ongoing construction of a power plant.

'The commission holds lengthy rate hearings under the transmission act [fn MCL 460.522; MSA 22.152], approximately every year, during which it evaluates ongoing construction. In requesting a rate increase, a utility must file with the commission a detailed report of its construction projects [fn omitted]. In addition, the utility can request that Construction Work in Progress (CWIP) be included in the rate base [fn omitted]. If, during a rate proceeding, the commission finds continued construction of a power plant unreasonable, it can exclude the cost of unjustified construction from CWIP.'

Moreover, the commission, in exercise of its supervisory powers, set forth in the general enabling act [fn MCLA 460.58; MSA 22.8], may conduct pre-construction review without regard to whether the utility seeks to have the plant's costs included in the rate base. The general enabling act creating the commission directs it to conduct an investigation '[u]pon complaint in writing that any rate, classification, regulation or practice charged, made, or observed by any public utility is unjust, inaccurate, or improper, to the prejudice of the complainant [fn MCLA 460.58; MSA 22.8]. In its rules prescribing the contents and kinds of complaints, the commission authorizes a 'person', i.e., 'an individual, partnership, corporation, association, body politic, or state agency', [fn MAC 1979, R 460.11(d)] or the commission itself to challenge 'unreasonable acts' of a public utility. [MAC 1979, R 460.31)]'

'The core of the intervenors' argument is that a securities issue proceeding provides an appropriate and perhaps the only forum for review of the construction of the plants in question before their completion. However, both the investigation procedure outlined in the general enabling act and a rate hearing under the transmission act provide an opportunity for commission review of the wisdom and reasonableness of plants during construction.' 412 Mich at 411-413

Michigan court cases relating specifically to the construction of electric transmission lines indicate that jurisdiction over key determinations affecting transmission lines is split between the MPSC and the local governments through which the proposed line passes. In Detroit Edison Co v City of Wixom, 382 Mich 673, 682-683; 172 NW2d 382 (1969), the Supreme Court stated:

'The commission's interest is in 'the character of the construction' as it relates to the safety of the proposed line, the capacity of the line, the need for the line, and its total relation to the maintenance of electric service to the people of southeastern Michigan.

'The commission is not interested--nor should it be--in the effect which the construction will have on the development of the communities through which it passes.

The city, on the other hand, has a legitimate though narrow area of concern.

[A] city does have an interest in the location and route of a high tension electric power line. It is a specific land use which is not compatible with other land uses. It is a land use which characterizes the neighborhood and influences the development of adjacent real estate.

'The public service commission statute does not vest the commission with authority to determine the routes of high tension lines except as those routes bear upon 'rates, fares, fees, charges, services, rules, conditions of service' or the 'formation, operation or direction of such public utilities.' [Citation omitted] The first sentence [of MCL 460.6; MSA 22.13(6)] vests the Commission 'with complete power and jurisdiction to regulate all public utilities in the state . . . except as otherwise restricted by law." (Emphasis added.)

It is thus clear from the above statutory and case authority that the MPSC does possess jurisdiction and authority, either upon its own motion or pursuant to a complaint, to review and pass upon the need or necessity for proposed or ongoing construction projects of nonmunicipal utilities. This conclusion is based not only upon the statutory and case law regarding the MPSC's investigatory powers, but also upon the MPSC's substantial and broad ratemaking powers. Pursuant to MCL 460.557; MSA 22.157, among other statutory provisions, the commission must establish 'just and reasonable' rates for electric utilities. Transmission line construction can directly impact capital and financing costs of a utility, and the rate base upon which a return may be earned, among other relevant aspects of the ratemaking formula. The need or usefulness of electric transmission lines is thus relevant to the setting of proper rates. Further, there is no statutory provision or other indication of legislative intent that any inquiry regarding the impact of utility construction upon rates must await the completion of the construction, whether proposed or in progress.

The Supreme Court has emphasized the importance of the MPSC's ratemaking powers. For instance, in Detroit v Michigan Public Service Commission, 308 Mich 706; 14 NW2d 784 (1944), the Supreme Court reviewed a MPSC order issued in a rate proceeding commenced by a complaint filed by the City of Detroit, wherein the MPSC held that it had no specific statutory authority to disallow for ratemaking purposes amounts lawfully paid by Detroit Edison for excess profits taxes. The Supreme Court reversed the MPSC, finding that the MPSC possessed widespread ratemaking powers to review and exclude the expense, stating in relevant part:

'It is the duty of the commission, under its statutory power, to fix a just and reasonable rate. This can be accomplished only by balancing the interest of public utility investors and the consuming public. Federal Power Commission v. Hope Natural Gas Co., 320 U. S. 591 (64 Sup. Ct. 281, 88 L. Ed. ----).

In the instant case the commission disclaims that it possesses any power to consider this matter. It thus completely ignores its discretionary authority to exclude those items from public utility operating expenses which place unnecessary burdens upon the consumer. Obviously in so doing the commission failed to balance investor and public interests.

Without discretionary power to exclude any and all unnecessary elements of expense in determining a just and reasonable rate, the Michigan public service commission would be an impotent body. It could not have been the intent of the legislature that the commission should lack any necessary power to fix reasonable rates, and the commission should not be permitted to declare itself impotent. It clearly possesses such discretionary power, and that power should be exercised.' 308 Mich at 716-717

Similar to the situation in Detroit, utility expenditures for plant construction, including that involving electric transmission lines, is directly related to the setting of proper rates, and thus the MPSC has broad powers under its ratemaking functions to investigate, hold hearings, and issue appropriate orders regarding such plant construction. The MPSC's powers in this regard are continuing, since the MPSC retains continuing and ongoing jurisdiction over the rates of a utility subject to its jurisdiction. City of Lansing v Public Service Commission, 330 Mich 608, 612-613; 48 NW2d 133 (1951).

It must also be noted, however, that the Legislature has established a distinction regarding a utility's prerogative to commence construction of an electric transmission line depending upon whether the proposed construction is to be located within or outside the utility's service territory. Specifically, MCL 460.502; MSA 22.142, requires nonmunicipal electric and gas utilities to obtain a certificate of public convenience and necessity from the MPSC prior to undertaking construction projects located outside of the utility's service territory, which requirement has been construed to be unnecessary with respect to projects located within the utility's service territory. This distinction was clarified in Indiana & Michigan Electric Co v Miller, 19 Mich App 16; 172 NW2d 223 (1969), lv den 383 Mich 781 (1970), a condemnation case involving the proposed construction of an electric transmission line, wherein the court held that an electric utility is not required, pursuant to MCL 460.502; MSA 22.142, to obtain a certificate of public convenience and necessity from the MPSC prior to construction in circumstances where the utility is not proposing to render electrical service within any municipalities outside of its present service area. The Supreme Court in Miller cited Huron Portland Cement Co v Public Service Commission, 351 Mich 255; 88 NW2d 492 (1958), finding that the purpose of the Act was to prevent needless multiplication of companies serving the same territory. In Huron Portland Cement Co, the Supreme Court explained the statute's requirement that a utility obtain a commission certificate of public convenience and necessity before constructing electric transmission lines located outside of its service territory, by quoting a recognized treatise on public utility regulation:

"The requirement of a certificate of convenience and necessity may enable the commission to prevent the needless multiplication of companies serving the same territory, and at the same time to avoid a wasteful duplication of capital facilities, thus keeping the investment at the lowest figure consonant with satisfactory service. By protecting the utility from unnecessary competition, the risks inherent in utility investments are reduced and the cost of capital is thereby kept as low as the conditions of the investment market permit.' 351 Mich at 267-268.

Similarly, the Michigan Supreme Court in Attorney General v Michigan Public Service Commission, supra, concluded that advance approval by the MPSC is not required as a prerequisite to a utility commencing a construction project within its service territory, as indicated from the following portion of its opinion:

'It may be wise, in this era of multi-billion-dollar power plants, for the commission to pass upon the necessity for any such plant before construction begins. The policy question whether the Commission should be required to approve the construction of additional generating capacity before construction begins is properly for the Legislature, and not this Court, to decide.

'We cannot confidently predict that the Legislature would today conclude that the reasonableness of a utility construction project should be made the subject of a pre-construction hearing [fn omitted]. The Legislature might conclude that the public interest is better served by the present system which requires a utility, its shareholders and bondholders to shoulder the responsibility and risk involved in deciding to construct additional generating capacity.

In a word, the Legislature may conclude that the present regulatory scheme is more consonant with the concept of a private public utility system subject to public regulation than a scheme requiring the regulatory agency to prognosticate future energy needs and to assess the relative advantages and disadvantages of the means by which to meet these needs.' 412 Mich at 417-418.

The above distinction permitting a utility to commence construction of facilities within its service territory without the issuance by the MPSC of a preconstruction certificate of public convenience and necessity, while requiring such a certificate as a prerequisite for construction projects located outside of the utility's service territory, does not indicate legislative intent that the MPSC's power of inquiry is to be eliminated or curtailed with respect to proposed or ongoing construction projects within a utility's service territory. The only difference is that with respect to plant construction within its service territory the utility has somewhat more leeway because construction can proceed without a prior affirmative order by the MPSC although the construction project remains subject to potential review if a proceeding is commenced pursuant to a complaint or by the MPSC's own motion.

It is my opinion, therefore, that the Michigan Public Service Commission, pursuant to its powers to set rates and initiate investigatory proceedings under the various enabling acts referenced above, possesses jurisdiction and authority to act either upon its own motion or upon a complaint questioning the need for proposed electric transmission lines and to make determinations as to the need for such a line.

Frank J. Kelley

Attorney General


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