August 29, 2006

re: Highwood Coal Plant draft EIS

Dear Mr. Fristik and Ms. Johnson:

My name is Charles Bocock. I reside in Great Falls, Montana. I am a retired business man and a concerned Citizen for Clean Energy.

For two years I have read through the City’s and SME’s numerous ways of presenting a colorful array of spin and disinformation about the coal plant. For example, they assert that for CO2 mitigation one newly planted tree will remove 1,600 lbs. of CO2 per year, which is impossible. Another example of their misinformation is the statement that this plant will remove as much mercury from the air as an IGCC plant can do.

The Draft EIS documentation that has been provided, while lengthy, is woefully inadequate. It does not address many health, environmental and financial concerns. There are numerous missing documents. Where is the complete current “Up to Date” business plan, allowing the R.U.S. to compile their due diligence, which would show this loan to be viable and not a financial scam using taxpayer’s money? This “Up to Date” plan has not been available to the public for study, and no “Up to Date” financial report was submitted to the R.U.S. Somehow R.U.S. has to be able to show to the public how this money will be repaid in a repayment schedule and over what time period?

Where are the documents in this draft EIS showing “The Itemized Use” of these tax dollars?

There are also missing documents which would show allowance for contingencies and inevitable cost-over runs; this is important for the R.U.S. financial lenders. How much in cost-over runs is the R.U.S. allowing? All the cost estimates for this plant are older than one year. Is the R.U.S. going to require current cost bids? The business plan for a loan of this size should have the signed contracts included and summarized for the R.U.S. to check out for their validity as part of the “Due Diligence Study”. Letters of hope that S.M.E. can someday acquire contracts from electrical customers showing estimated income projections are not good or viable information and very bad business planning in trying to obtain a loan of this size. The RUS needs and should require solid information that can be checked out for this nearly half billion dollar loan.

What are the plans and the public documentation provided by the R.U.S. showing how the R.U.S. will provide the complete financing of the Highwood plant if the City of Great Falls does not participate financially?

Taxpayers want to see “ALL” “UP TO Date” and present day documents concerning this loan at our Public Library. This is a big project and the documentation for the public would be all the financial information and permitting regarding this project, like the signed water contract from the City of Great Falls Montana to S.M.E. showing the price that will be paid for the water and exactly how this is going to be taken from the Missouri River? If the water must be taken out of the Missouri River and mostly evaporated by the coal plant, why doesn't the R.U.S. insist that “Discharge” water from the City of Great Falls Sewage Treatment Plant be used before it enters the River instead of taking out water downstream (which includes a substantial contribution from the much purer water from Giant Springs)? The City claims it has cleaned up the sewage discharge water being returned to the River, so this water source should be perfectly adequate for the coal plant cooling towers.

The City cites a plan to build water and sewer lines to the plant. The R.U.S. can strongly suggest to add another line for the discharge water from the sewage plant for the evaporation process. The health issue of the mercury pollution being shown to the R.U.S. is incomplete. The DEIS should include how the coal plant will further adversely affect the fish that citizens eat. Is the R.U.S. aware that there are already mercury fish advisories regarding human consumption of fish caught in Montana lakes and streams, and this coal plant will make the problem worse. This is especially important for residents of the nearby Rocky Boy and Fort Belnap Indian Reservations, where fish comprise a greater portion of the diet.

The Audubon program in Montana is very concerned about the recent ten Bald Eagles poisoned by mercury. Is the DEIS going to adequately address this concern about federally protected Eagles, as well as Ospreys, Pelicans and other fish-eating birds?

Is there a loan adjustment plan for USDA farmers whose crops have a lower market value from mercury and other assorted pollutants caused by the fallout of these toxic emissions from the Highwood Coal Plant?

Will the R.U.S. ask for a solid number for the amount of mercury to be released? Will the R.U.S. require complete detailing cost of the mercury controls and insist that specific mercury controls must be installed during plant construction? Mr. Tim Gregori in numerous public meetings has indicated that the activated carbon injection process would be installed during plant construction. Why is the R.U.S. going to allow eighteen months of pollution before mercury controls are installed?

This delay of installing mercury controls will affect the Montana Fish Wildlife and Parks, and the US Forest Service, along with the State of Montana’s constitutional rights to “a clean and healthful environment” for all the citizens of Montana.

Capitalizing this plant will require certain loan security of this large loan. Will the R.U.S. require the documents showing the origin of the boiler, the boiler cost, the condition of being new or used? Also how much of the plant will be allowed to be used equipment?

The fly ash storage has not been fully addressed. Will the R.U.S. make public all the documents showing the cost of each storage site needed for the 225 daily tons of solid waste from combusted coal? Is the R.U.S. requiring documentation and the assurance that the water aquifers under the ash in the storage areas will stay in as pristine a condition as they are now?

Since there are currently no Montana laws governing toxic solid waste from coal plants, how can there be any enforcement actions if there is groundwater or aquifer contamination?

How many trucks will be needed to continuously deliver limestone and haul the ash? What type of road will be used; will gravel roads be paved to reduce dust? Is Cascade County responsible for the roads being used by the coal plant during different seasonal conditions and around the clock usage?

Is the R.U.S. going to require legal documents showing the actual purchase of the land needed for the plant, the annexation of the property by the City and agreements between the City and the Cascade County?

Is the R.U.S. going to permit water discharge containing heavy metals, poisons and other pollutants from the coal plant to enter the City of Great Falls sewage treatment plant, which will be cycled by the sewage plant and returned to the River?

Where is a list of all the chemicals discharged into the water being sent to the City? What percent of these chemicals will be discharged from the sewage treatment plant into the Missouri River once the Highwood Plant is operational? Does the City have the expertise, equipment and the permits to handle this type of industrial pollution?

The entire premise that SME needs to build a coal plant to prevent “the lights from going out in SE Montana” is untrue. The “Due Diligence” studies required for a loan of this type would uncover the fact that Mr. Ron Harper, CEO of the billion dollar company known as Basin Electric Cooperative, headquartered in North Dakota, has met with S.M.E. and the Governor of Montana and has offered to sell electricity to S.M.E. at longterm and low electric rates. Basin has also offered to build transmission lines to serve southeastern Montana. The R.U.S. should contact Mr. Ron Harper, CEO of Basin Electric, to verify this offer (www.basin electric.com; phone 701-223-0441).

The R.U.S. needs to learn firsthand that there are S.M.E. members who do not want this loan. They do not want to own a coal plant that they are financially responsible for, and they do not want to assume the associated considerable financial risk.

Is it the policy of the R.U.S. to loan monies of this magnitude to a rural utility company that is in turmoil and not in full agreement? Will the R.U.S. request a vote of all the S.M.E. members before allowing such considerable indebtedness? Also will the R.U.S. inquire about the plans of Basin Electric to build an I.G.C.C. plant in the very near future?

Will the R.U.S. also please contact Mr. Thomas Huntley, C.E.O. of the Central Montana Electric Cooperative, which is a composed of nine smaller cooperatives and find out why they feel that the Highwood Coal Plant is a bad idea and a financially risky plan (406-268-1211)?

How will the R.U.S. show in court that this loan is justifiable and even needed?

Does the R.U.S. want this type of publicity, showing that they have no regard as to how or why they would grant this loan that is not needed for power that is already being offered? Does the R.U.S. feel that additional pollution and health problems are warranted even with all the data that is being made available to them?

Will the R.U.S. make available these taxpayer dollars for this loan knowing they are harming Federal tax dollars already spent on the “National Historic” portage site of Lewis and Clark? How will this be handled by the Federal courts representing the National Trust for Historic Preservation, The United States Park Service and the State Historic Preservation Office?

The R.U.S. needs to do a complete “Due Diligence” study with all the current information in order to protect the tax paying public from “Misinformation”, bad planning and severe and longterm health problems for citizens of all ages.

There needs to be a complete new draft EIS. The R.U.S. is morally obligated under standards of Good Business Practices to tell SME and the City of Great Falls that no loan guarantee of any type will be forth coming until such time as a new document could be prepared with up to date cost, time schedules, complete business plans, signed contracts showing length of negotiation and price and quantity of product delivered. Such documentation should include all avenues of power supplied and types of help offered from different electric companies. THe R.U.S. must require that accurate information is given in every aspects of the new document.

The R.U.S. and its staff are not going anywhere and S.M.E. can get electrical contracts for what ever timeframe they might need.

Please let’s take the time to find out all the “answers” and “do it right”. The courts are not the place to do this.

Thank you.

Sincerely yours,

Charles Bocock

#51 Prospect Drive

Great Falls, MT 59405