Missouri Revised Statutes

Mo. Rev. Stat. § 229.100 (2026)

Improvements along public roads

✓ current as of May 2026
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  229.100.  Improvements along public roads — location — control. — No person or persons, association, companies or corporations shall erect poles for the suspension of electric light, or power wires, or lay and maintain pipes, conductors, mains and conduits for any purpose whatever, through, on, under or across the public roads or highways of any county of this state, without first having obtained the assent of the county commission of such county therefor; and no poles shall be erected or such pipes, conductors, mains and conduits be laid or maintained, except under such reasonable rules and regulations as may be prescribed and promulgated by the county highway engineer, with the approval of the county commission.

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(RSMo 1939 § 8573)

Prior revisions: 1929 § 7924; 1919 § 10712; 1909 § 10515

CROSS REFERENCES:

Electric transmission lines, placing by rural electric cooperative on public thoroughfares, 394.080

Telephone and telegraph companies, construction of lines along highways, 392.080

Underground water mains, construction along highways by water company, 393.020

Notes of Decisions
Cited in 7 cases (1 in the last 5 years), 1964–2024 · leading case: Grain Belt Express Clean Line, LLC v. Pub. Serv. Comm'n, 555 S.W.3d 469 (Mo. 2018).
Grain Belt Express Clean Line, LLC v. Pub. Serv. Comm'n, 555 S.W.3d 469 (Mo. 2018). · cites it 20× “In addition, when publicly owned county roads are impacted, assent is also required under section 229.100 from those counties before construction may begin.”
Mo. Landowners All. v. Grain Belt Express Clean Line LLC, 561 S.W.3d 39 (Mo. Ct. App. 2018). · cites it 17× “To build the Missouri segment of the line, Section 229.100, RSMo 2016, 2 requires Grain Belt to obtain the assent of the county commissions in each of the eight counties where it proposes to build the line on or across county roads or highways.”
StopAquila. Org v. Aquila, Inc., 180 S.W.3d 24 (Mo. Ct. App. 2005). · cites it 3× “County Franchise Authority Aquila bolsters its contention that counties have no authority over the construction of an electric power plant by citing section 229.100, which Aquila contends prohibits a county from issuing a franchise for such construction.”
Neighbors United Against Ameren's Power Line v. Pub. Serv. Comm'n, 523 S.W.3d 21 (Mo. Ct. App. 2017). · cites it 10× “” Additionally, Neighbors United argued that ATXI’s application should be dismissed because ATXI did not have the requisite approvals from the county commissions of the counties its proposed transmission line would traverse as required under section 229.100 and Commission Rule 4…”
State Ex Rel. Pub. Water Supply Dist. No. 2 of Jackson Cnty. v. Burton, 379 S.W.2d 593 (Mo. 1964). · cites it 3× “(NS) 33 , the Commission recognized that the permission granted by a county court, pursuant to Section 229.100, RSMo 1959, V.A.M.S., to a public utility to use the county roads is a “county franchise,” supplying the consent required by Section 393.”
Grain Belt Express, L.L.C. v. Chariton Cnty., Missouri (Mo. Ct. App. 2024). · cites it 58× “4 and its relationship to Section 229.100, which requires corporations to obtain the assent of a county commission before erecting poles 1 All statutory references are to the Revised Statutes of Missouri 2016, unless otherwise indicated.”
Missouri Landowners All. v. Pub. Serv. Comm'n (Mo. Ct. App. 2019). · cites it 2× “On transfer, the Missouri Supreme Court concluded that the Commission had erred in finding it could not lawfully grant a CCN to 3 Unless otherwise indicated, all further statutory references are to RSMo (2016), as amended.”
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