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Pursuant to Rules 211 and 214 of the Rules of Practice and Procedure of the Federal <br /> Energy Regulatory Commission, 18 C.F.R. § 385.211, 214 and the Commission's Notice of <br /> Extension of Time issued in this Proceeding on November 26, 2013, the Midwest <br /> Municipal Transmission Group respectfully moves to intervene on behalf of itself and its <br /> members and submits the following Comments. <br /> I. MIDWEST MUNICIPAL TRANSMISSION GROUP COMMENTS <br /> MMTG files these comments to remind the Commission of the importance of <br /> comparable hypothetical capital structures for some municipal systems in connection with <br /> issues that are raised herein. Comparability is the hallmark of Order No. 888. <br /> MMTG represents the interests of over 77 cities and governmental entities in Iowa <br /> and Minnesota and one in Illinois that depend upon adequate and equitably priced <br /> transmission. Some of its members own considerable transmission in the Upper Midwest. <br /> Its members are also transmission-dependent. MMTG supports and encourages municipal <br /> (and other)transmission investments on fair, non-discriminatory and non-preferential terms <br /> and at just and reasonable rates. <br /> MMTG members are municipally-owned electric utilities that generate, sell and <br /> purchase electricity at wholesale and at retail for the benefit of residents and businesses in or <br /> Promoting Wholesale Competition Through Open Access Non-Discriminatory Transmission Services by <br /> Public Utilities; Recovery of Stranded Costs by Public Utilities and Transmitting Utilities,Order No. 888,61 <br /> Fed.Reg. 21,539(May 10, 1996),FERC Stats.&Regs.¶31,036(1996), clarified, 76 FERC¶61,009(1996), <br /> modified,Order No. 888-A,62 Fed. Reg. 12,274(Mar. 14, 1997),FERC Stats.&Regs.¶31,048(1997), order <br /> on reh'g,Order No. 888-B,62 Fed. Reg. 64,688(Dec. 9, 1997),81 FERC 1161,248(1997), order on reh'g, <br /> Order No. 888-C, 82 FERC¶61,046(1998),aff'd in part and remanded in part sub nom. Transmission Access <br /> Policy Study Grp. v. FERC,225 F.3d 667(D.C. Cir.2000),a[)'d sub nom. New York v. FERC, 535 U.S. 1 <br /> (2002). <br /> 2 <br /> 110 <br />