Earth Island Institute v. Union Electric Co.

Earth Island Institute, doing business as Renew Missouri, and additional parties (collectively “Renew Missouri”) appeal the Public Service Commission’s determination that section 393.1050,1 a statute exempting electric utilities that met a certain renewable energy target on a certain date from any solar energy requirements, was not invalidated by the subsequent passage of a ballot initiative (“Proposition C”) that imposed solar energy requirements on “all electric utilities.” The Commission found that the two provisions could be harmonized by considering section 393.1050 a specific exemption…