## Facts

- Northern Pipe Line Company sought a certificate of public convenience and necessity from the Illinois Commerce Commission to construct and operate a roughly 200-mile, 24-inch crude-oil pipeline running across Illinois from Wood River toward Pine Bend, Minnesota.
- Northern’s affiliates operated a large refinery at Pine Bend; the pipeline’s primary function was to supply crude oil to that refinery and a nearby refinery, with excess capacity potentially available to other shippers.
- Midwestern refineries had relied heavily on Canadian crude oil, but Canada reduced exports and announced plans to end them, creating regional supply insecurity.
- The pipeline would carry interstate shipments, but as a common carrier it would be subject to federal and state requirements to provide nondiscriminatory service to qualified shippers.
- Iowa RCO Association was the only objector at the Commission hearing and argued that Northern was not a “public utility,” that the project was not for Illinois public use, that environmental concerns were inadequately addressed, and that the Commission mishandled evidence related to the Minnesota Energy Agency.
- The Commission granted the certificate; the circuit court affirmed; RCO appealed.

## Issues

1. Whether Northern qualified as a “public utility” under the Illinois Public Utilities Act and was eligible for a certificate of public convenience and necessity.
2. Whether the Commission failed to adequately consider environmental impacts of the proposed pipeline.
3. Whether the Commission’s evidentiary rulings concerning actions of the Minnesota Energy Agency required reversal.

## Decision

- The appellate court affirmed the circuit court and upheld the Commission’s order granting the certificate.
- The court held that Northern fell within the statutory definition of a public utility and that the Commission could treat the pipeline’s service as “public” given common-carrier nondiscrimination obligations.
- The court held the Commission sufficiently considered environmental evidence and did not act arbitrarily.
- The court held any error regarding the Minnesota Energy Agency evidence was non-prejudicial and did not warrant reversal.

## Legal Principles

- Orders of the Illinois Commerce Commission are prima facie reasonable; the challenger bears the burden to show error.
- A pipeline may be treated as a public utility for state regulatory purposes where it is legally required to provide nondiscriminatory common-carrier service, even if its operations are primarily interstate.
- Reviewing courts do not reweigh the evidence; they assess whether the Commission acted within statutory authority and whether findings are contrary to the manifest weight of the evidence.
- Evidentiary error in an administrative proceeding warrants reversal only upon a showing of prejudice.

## Conclusion

The court upheld the Commission’s certificate authorizing an interstate crude-oil pipeline, concluding the Commission reasonably found Northern to be a regulated public utility, adequately addressed environmental considerations on the record, and committed no prejudicial evidentiary error.


Iowa RCO Ass'n v. Ill. Commerce Comm'n, 409 N.E.2d 77 (Ill. App. Ct. 4th Dist. 1980)