CCE

Citizens for Clean Energy

51 Prospect Drive

Great Falls, MT 59405

August 28, 2006

Richard Fristik

USDA Rural Development, Utilities Program

1400 Independence Avenue, SW

Mail Stop 1571, Rm 2237

Washington, DC 22050-1571

Kathleen Johnson

Montana DEQ

PO Box 200901

Helena, MT 59620

re: Draft EIS, Coal-fired Highwood Generating Station, Great Falls, MT.

Dear Mr. Fristik and Ms. Johnson:

I am writing to register my strong opposition to the coal plant that has been proposed for my hometown of Great Falls, Montana. I urge you to accept the No Action Alternative. My comments come from my perspective as an academic and community pathologist, a tenured scientist who spent nearly a decade at the National Institutes of Health, and as an interested and informed citizen taxpayer.

Considering the far reaching and longterm adverse impacts of the coal plant, the amount of time given to the public to weigh in on this issue has been woefully inadequate. We appreciate the two weeks extension of the deadline, but because this issue is so complex and because the public comment period falls within the busy timeframe of summertime vacations, we feel the public has been shortchanged in this process. It is clear that the more informed people have become, the greater their level of opposition to the coal plant. We hope the RUS and DEQ will consider further extending this deadline for at least another 60 days, leading up to the November elections so that our politicians can weigh in on this important decision.

For the past 18 months I have devoted hundreds of hour studying this issue, reading texts and scientific papers from the peer reviewed literature and interviewing a variety of public officials and experts (including mechanical, electric and alternative energy engineers, a climate scientist, a public service commissioner, the CEO of a competing rural electric cooperative, the General Manager of the Tampa Electric IGCC facility, and several Great Falls City Commissioners and Administrators).

I feel so strongly about this issue that I became a founding member of a spontaneous grassroots network of concerned citizens from around the state. For more information about this group please visit the web site for Citizens for Clean Energy (http://homepage.mac.com/neiltaylor1/cce/index.html). I have also helped to initiate a formal petition drive against the coal plant, signed by hundreds of opponents, and in collaboration with the Montana Environmental Research Center I have help to arrange for a number of educational public forums on this topic (in Great Falls, Fort Benton, and on the Rocky Boy Indian Reservation).

My opposition is multifactorial and can be broadly divided into concerns about the impact of the coal plant on health of humans and other living creatures, the many adverse ecologic effects, the degradation of the quality of life that we enjoy in the open spaces of northcentral Montana, and the likely adverse financial impact of the coal plant on the federal taxpayers, the local community, the customers of Southern Montana Electric (SME), and the rural utility service (RUS) electrification program in general.

I. Serious Financial Concerns:

Southern Montana Electric and the City of Great Falls have proposed that the RUS guarantee repayment of a loan from the Federal Financing Bank for 75% of the estimated $515 million cost of the coal plant. The RUS was created during the last century to bring electrification to rural areas, and this goal has been largely met in Montana by the purchase of power contracts and the installation of transmission lines. Despite its public claims that it has “60 years of experience” in providing electricity to rural Montana, SME has had NO experience in the competitive and complex world of power generation and has had no experience in managing the round-the-clock grid transmission. In fact, SME was formed on May 31, 2004, following its “divorce” from Central Montana Electric Power Cooperative (CMEPC); this separation was triggered by irreconcilable differences in opinion about the coal plant proposal. Of the 14 original members of CMEPC, the overwhelming majority of member cooperatives (9) refused to participate in the risky plan to build a coal plant. The remaining 5 cooperatives formed SME. For background information, the RUS would be very well served by communication with Mr. Thomas R. Huntley, General Manager of Central Montana Electric Cooperative, 501 Bay Drive, Great Falls, MT 59404; phone 406-268-1205; email tom@cmepc.org.

The SME proposal calls for shipments of coal from southeastern Montana using an expensive captive rail service that relies on diesel fuel for the locomotives; when queried about the expense of shipping coal so far from the mine and where the bulk of the electricity is to be used, SME executives indicated they might purchase their own 110 car coal train (to run on the competitor’s rail lines). Is the cost of a coal train factored into the $515 million price tag for the coal plant? Is SME aware that Burlington Northern/ Santa Fe is already 61,000 coal cars backordered (private communication), and delays in the delivery of low sulfur diesel fuel has already adversely affected the shipments of coal from the Powder River Basin? Coal trains are hard on rails; who is going to be responsible for maintaining the rails? Because coal trains are so long and have lesser priority than commodity trains, who is going to lengthen the sidings (so trains can pass one another)? Where is the funding coming from to build the miles of heavy duty steel rails around the new coal plant (at approximately $1 million per mile).

SME’s customer base is in southern and eastern Montana, so it appears that not only is it inefficient to haul the coal hundreds of miles, but also it is inefficient to transmit the electricity back to energy-rich southeastern Montana and northern Wyoming. The City of Great Falls’ historical usage is relatively small (5-8 MW); to help justify building the coal plant the City also hopes to provide longterm power contracts to area businesses (totaling approx. 65 MW). What business is going to jeopardize its future by signing 20-30 year contract for power at an unknowable cost? It is far from clear that SME will be successful in providing electricity cheaper than the default supplier with its established hydropower and coal plants and with increasingly abundant wind power coming on line. How can SME prevent these businesses from canceling their contracts? Does the City of Great Falls expect the local taxpayers to subsidize rates to commercial establishments? If the customers are not under contract for 20 years or more, how can anyone be sure there will be customers for the electricity? What will happen if the electric needs of these businesses change due to their own ability to generate their own power through solar panels, conservation, or use of fuel cells (as just happened in a Billings hospital)? Is it part of the RUS mission to enable rural cooperatives to get into competition with the default supplier for the electric needs of Great Falls’ businesses? In contrary to the perception of area residents, the citizens of Great Falls as a group will not be customers of SME, since they will continue to be supplied by the default supplier (as required by state law). I question whether SME recognizes this fact when it boasts that it will serve “120,000 people” (Are they including the entire population of Great Falls in this inflated figure?).

The proposed combustion circulating fluidized bed (CFB) coal plant appears to be a gross mismatch of size of plant with SME’s need. This apparently has more to do with the manufacturer’s boiler size than with market demands. The amount of electricity produced by the plant (250 MW) exceeds SME’s documented recent need (approximately 65 MW) by fourfold, providing evidence that this is a merchant plant. Despite the claim that SME’s electricity will power Montana farms and ranches, their largest potential commercial growth is to increase the profit margins of developers of natural gas and coal bed methane in Northern Wyoming and SE Montana. SME's October 2004 System Load Forecast, Opening Comments, Section I, subsection 1.2.2 Commercial and Industrial, cites upward pressure on Beartooth's commercial energy requirements in northern Wyoming related to increasing the profit margins on natural gas development (also discussed in the Beartooth Electric Cooperative narrative by Mr. Robert Walker, see in particular section E, "we are being deluged with requests for new services in the Clark Wyoming area for new services in the Badger Basin Oil field and for natural gas development on the eastern front of the Beartooth Mountains..."). Indeed, SME states that the pumping stations of the Fergus electric system and the methane gas industry in the Tongue River Electric service area next to the Powder River Basin Coal fields represents a projected 40% increase in the large commercial segment of SME's load base. Refer to http://www.usda.gov/rus/water/ees/pdf/smeloadforecast_2004.pdf.

Coal bed methane developers have not been traditional allies of agriculture; is it appropriate that such enterprises be indirectly promoted by loan guarantees from the USDA? It is far from clear that these potential customers would leave their present electric supplier, whose generation facilities are much closer to the coal source and who will likely be able to offer more competitive rates than SME. For these and other reasons it is not clear where and how the excess “off peak” electrical production will be sold, and SME’s current assumptions about price for this excess energy appear overly optimistic.

Because of this impracticality and expense of hauling coal on captive rail lines, we are concerned that once built, the Highwood coal plant will petition for an amendment in its air quality permit in order to combust the lower quality, more highly polluting lignite coal that is abundant in northcentral Montana. We have an audiotape of Mr. Gregori saying as much, during the April 18, 2006, work session of the City Council. It will be an ironic travesty for the USDA to enable SME to churn up productive agricultural land to scavenge coal for power that isn’t even required to meet Montana’s needs. Shouldn’t the citizens living near the known coal fields of Stockett, Sand Coulee, and Tracy be alerted to the possibility of open pit coal mining before rather than after the fact?

There is a precedent for this type of “bait and switch” tactic. Bison Engineering, the Montana firm contracted to prepare the plans for the SME coal plant, “sold” the idea of its Thompson Falls Cogen to the public by promising to create jobs by generating electricity from burning scrap wood; once built they ended up burning coal in a refurbished third world boiler. Following considerable community opposition (now in its fifth year), the 16 MW Thompson Falls Coal Plant has been shuttered for nearly a year, fined $2 million by the Montana DEQ (only a portion of which has been paid), and incurred substantial additional costs trying to bring the facility into compliance with Montana’s environmental laws.

II. Jeopardizing the Rural Utility Service (RUS) electrification program.

As best we can determine the RUS is being asked to guarantee a loan of millions of dollars on a “trust us” basis without being given a complete business plan. Although there have been optimistic prognostications by SME and the City, we have been unable to locate or document any contractual arrangements for the purchase of coal, the hauling of coal or limestone, power purchase agreements, transmission line agreements, written agreements with labor unions, or even a bond prospectus (the City’s 25% share of the plant will theoretically be funded through the sale of revenue bonds). Does the RUS have a business plan from SME? If so, why hasn’t it been made available to the public despite repeated requests? What will happen to the project if the City is not successful in selling these revenue junk bonds that are not backed by the taxing authority of the City? Shouldn’t these issues be settled before any money is loaned to SME?

What happens in the scenario that construction begins but cannot be completed due to cost overruns? Is the RUS prepared to add millions of dollars more to finish this project? While the country has seen dramatic increases in labor and transportation costs and the cost of borrowing capital has risen significantly, the $515 million price tag for the coal plant construction has remained (unrealistically) stagnant for more than a year (the initial 2004 cost projection was $470 million).

Is it within the mission of the RUS to fund a merchant power plant? If the RUS guarantees loan money for such a venture and if federal tax dollars are lost as a consequence, this entire RUS program will justifiably come under broadened congressional scrutiny. Thanks to this twentieth century RUS program, rural America has already been electrified, and many rural customers could have access to the default electricity supplier. As part of its overall agricultural mission how much better it would be for the RUS to use its twenty-first century federal tax dollars to fund futuristic distributive renewable energy sources such as the emerging biofuels industry, windfarms, and small hydropower, thereby bringing addditional “crops” to stuggling family farms. One need only look at the successful Judith Gap wind farm as a model of synergism between the energy industry, agriculture, and city/county government. This type of activity is a much better longterm investment than funding a second rate coal plant that will help to transform Great Falls into a western version of Appalachia. Rather than serving as an economic stimulus to our area, this coal plant will drive away the kinds of people and entrpreneurial clean energy projects that will make for a brighter economic future in central Montana. Why would the RUS even consider loaning money for a second-rate CFB coal plant that will not only be non-economic but also obsolete before the plant is built?

It is also reasonable to ask why the plant is being sited in Great Falls instead of the Billings area. The primary reason appears to be the availability of water, thanks to the generous water rights owned by the City of Great Falls. The City is understandably anxious to prove up on these water rights, since in these drought stricken times the value of the water is readily apparent. The coal plant will use up to 3200 gallons per minute (half of what the entire populace of Great Falls uses on a winter day). This amount of water each day would fill 115,000 bathtubs! Most of the 1.7 billion gallons per year will be evaporated, making it unavailable for agriculture and contributing to visual haze. It is surprising to us that the Department of Agriculture, knowing the importance of water to farming, would collaborate in this unnecessary squandering of our precious water resource. It is also surprising to us that our City, with its hefty water bills to area consumers, would sell the water to a coal plant at markedly reduced rates. Wouldn’t it be better to use this water instead to support a biodiesel or biomass electric generating facility? Won’t the use of this water by SME be detrimental to downstream agricultural, tourism, fishing and barge industry interests? If coal plant has to be built, wouldn’t it make more sense and in the end cost far less for SME to purchase ranches with ancient water rights for a location along the Yellowstone River, which is closer to both the coal and its customers?

Studies have not as yet been completed to demonstrate that contaminants from the stored fly ash and bottom ash (225 tons per day) from burning 1,177 tons of coal per year will not find its way back into the Missouri River and or the underground aquifer. Despite claims of the effectiveness of the natural clay liners for the encapsulated waste, the possibility of fractures and leakage exists and with the location of the plant so close to the Missouri River, even a small risk of groundwater/aquifer contamination must be taken seriously. Will these prudent studies be completed before the permit is issued? Will baseline levels of mercury, arsenic, beryllium, cadmium, manganese, and lead be obtained from water and land samples in a 100 mile radius of the plant? Will baseline pH determinations be made of the agricultural land around the coal plant to assure that emissions do not harm crops with acid rain or toxic heavy metals. Will organic farmers and local gardeners suffer adverse economic and health consequences? Will there be real time monitoring of the pollutants with data made available to the public? SME needs to be prepared to compensate farmers and ranchers for reduced agricultural land values and to compensate individuals for diminished real estate values for the industrialized and contaminated landscape. Will they be required to post a bond to cover the cost of future cleanup of the site?

III. Climate change

Most legitimate climate scientists agree that humans are having an impact on the weather by the production of greenhouse gases that have contributed to global warming. Global warming in our area of the country has a significant negative impact on agriculture through drought, increasing storm severity, fires in parched forests, and increased populations of insects. This coal plant is being permitted to release 3,052,081 tons of carbon dioxide equivalents per year, in the form of C0₂ and nitrous oxide. Nitrous oxide has a global warming potential of 296 times that of CO₂. Because of its long lifetime (about 120 years) it can reach the upper atmosphere, depleting the concentration of stratospheric ozone, an important filter of UV radiation. Nitrous oxide is emitted from fluidized bed coal combustion and at rates greater than a traditional pulverized coal combustion plant. Clearly, this is not the “best available control technology” in the common sense use of the phrase. This coal plant will be permitted to release the carbon dioxide equivalent of 561,000 cars; from a greenhouse gas perspective this is akin to importing the exhaust from all the traffic in Seattle.

A hefty carbon penalty tax is likely in the foreseeable future, adding substantial increased cost to the generation of electricity by a CFB coal plant that is incapable of sequestering CO2 (unlike an IGCC plant). SME hopes to mitigate some of its deleterious effect on greenhouse gases by planting trees, citing the incorrect estimate of 0.8 tons (1600 pounds) of C02 annual reduction per tree. According to the Montana Department of Natural Resources and Conservation, the average mature yard tree cleans 330 pounds of CO2 from the atmosphere each year. The RUS should not accept false data as a basis for funding an outmoded coal technology that damages agriculture, human health, and the planet.

Furthermore, this coal plant appears to solve a nonexistent problem. Montana is already a net exporter of electricity. The lights are not going to go out in SE montana if this coal plant is not built. We have been assured that the Central Montana Electric Power Cooperative would reintegrate SME’s customer base, should this coal plant be abandoned.

Furthermore, SME’s proposal is woefully inadequate and out of date in its investigation of alternative energy sources. The initial feasibility study capped wind power at 3% of an energy portfolio (Montana law mandates 15% renewable energy by 2015); the Judith Gap Wind Farm already provides 8% of Northwestern Energy needs. Will the Great Falls coal plant use up so much of our current transmission capacity that it will discourage the development of new wind farms or the generation of electricity by ranchers who could produce wind or hydropower as new “crops”?  Conversely, because new wind farms can be brought on line much faster than coal plants, will transmission of electricity from the wind generators being put up by the counties, the proposed 500 MW wind farm north of Glasgow by Wind Hunter, and by Northwestern Energy/Babcock and Brown leave any transmission capacity for SME?

The RUS would be remiss in accepting the incorrect data cited in the DEIS regarding the comparative reliability and emissions standards of an IGCC coal plant facility (Table 2-7). Harry Jeagher, the editor of Gas Turbine World , cites a January-February 2006 reference that documents 90% reliability. Having personally interviewed John Thompson of the Clean Air Task Force and James Childress, Executive Director, Gasification Technologies Council, I am convinced that Bison Engineering and Stanley Engineering have not kept abreast of current developments in clean coal technology. At our invitation, Mr. Thompson presented educational forums on IGCC in Great Falls and at the Governor’s Office in Helena, and Mr. Childress wrote an opinion column for the local newspaper (please see attached Tribune article, July 26, 2006). On this basis alone, I think the RUS would have justification in determining SME’s application to be out-of-date and incomplete.

Given the many uncertainties in the production process, it is impossible to predict that this plant will successfully produce energy at a competitive end-user price. I certainly wouldn’t make a financial investment in this coal plant as a part of my retirement plan, and I think that most individuals within the RUS would feel the same.

IV. Degradation of the quality of life in northcentral Montana

People move to Montana (or return to Montana as I did) because we value the clean air, the Big Sky, the open space, the access to diverse recreational pursuits, the absence of traffic jams, quality educational facilities, good healthcare, and a strong sense of community pride. Folks move to Great Falls to raise families or to retire, not because there are coal-fired plants; in fact a coal plant will be a significant negative for many to come (or to stay).

In addition to the natural beauty of the landscape is a sense of pride in the history of our region. Another area of concern is the location of the coal plant within the Lewis and Clark National Historic Landmark, where it creates a class IV (of IV) visual and auditory eyesore that seriously detracts from the pristine nature of this historic area at the base of the scenic Highwood Mountains. There has not been adequate time allowed in this public comment process to alert Lewis and Clark supporters across the country and to seek their input. Federal agencies should not be using federal tax dollars to jeopardize significant national resources such as historic landmarks. This type of view shed will become increasingly valuable with increased population growth.

The coal plant will have an adverse visual effect on the quality of air for many miles, including the Gates of the Mountains Wilderness Area and the Ulm Pishkun Buffalo Jump. It will diminish the view of the Highwood, Little Belt, and Rocky Mountain ranges. The impact on the fish and fishing and tourism industry has not been accurately evaluated. Montana’s reputation as “the last best place” will be further tarnished by fish advisories that further reduce levels of fish consumption due to mercury contamination.

Recent reports indicate that songbirds may be adversely affected by mercury poisoning. The coal plant is in close proximity to Benton Lake Bird Refuge. Mercury is especially toxic to those birds that eat fish like bald eagles. The draft EIS greatly downplays this risk; area bald eagles are already dying from mercury poisoning. The National Audubon Organization has not been given adequate time to weigh in on this process.

Coal plants belong in industrial sites, not on prime rangeland adjacent to the Missouri River. This coal plant establishes a precedent for “finger annexation” of Cascade County agricultural property by the City, hardly something to be encouraged by the USDA. Indeed, if we have to have a coal plant, a more modern IGCC facility could be placed in the Industrial Park north of town that was created for this purpose. An IGCC plant would require less coal to produce the same amount of energy, use much less water, produce commodities that could be used in agriculture, transportation, and and provide a ready source of wintertime heating for other facilities within the Industrial Park. Unlike the CFB coal plant, an IGCC facility has the potential to sequester greenhouse gases such as C02 (and even makes the C02 available for sale for enhanced oil recovery), produces less acid rain, makes purified sulfur available for agriculture, can generate hydrogen for fuel cells, can be used to make natural gas when the need for electricity is low, can make diesel fuel (syngas) and can be throttled back or ramped up to firm up the wind power that will become increasingly prevalent in our windy area.

V. Important health concerns- Mercury

As a M.D. physician (pathologist) and as past Chair of the “Committee on Public Health and Well Being” for the Montana Medical Association, I am particularly concerned about mercury pollution. Mercury is a poisonous neurotoxin that is especially damaging to babies in the womb. SME’s public statements about the quantity of mercury emissions (0.9 lbs per trillion btu) don’t match permit (1.5 lbs per trillion btu). Despite repeated promises to our City Commissioners and the public that SME will install specific mercury controls (activated carbon injection) the plant as permitted has no specific mercury controls and only a stated intention of possibly adding this control after 18 months of operation “if it’s needed”.

Mercury enters the food chain through consumption of fish tainted with mercury. Fish bioaccumulate methyl mercury, which is mercury in its most dangerous form. Fish are an important source of dietary protein and essential fatty acids, so while at the same time we are advising patients to increase consumption of heart and brain healthy fish, we are also giving conflicting advice, warning patients to limit the amount of fish they eat, depending upon the size and type of fish and the location of where the fish was caught. This conflicting advice is especially challenging for women of child bearing age, since essential fatty acids are needed for normal brain development in the unborn child, yet mercury is so slowly excreted from the body that much of the damage could be done before the woman even realizes that she’s pregnant. Many of Montana’s lakes already have fish advisories that limit consumption of fish because of mercury contamination. At nearby Tiber Reservoir it is recommended that a young woman not eat more than one 6 oz. serving of walleye a month. The amount of mercury in a single teaspoon can make the fish in a 1000 foot-acre lake unfit for consumption.

During the last century mercury emissions worldwide increased 2 to 5 fold. According to the United Nations Environmental Program, 70% of worldwide mercury emissions are now caused by human activity. Coal plants are the largest single source of manmade mercury contaminating our environment, accounting for approximately 48 tons of annual mercury pollution in the United States. Coal plants are poisoning our planet with mercury and need to be strictly regulated. The residents of Quaanagg, Greenland, located far above the Arctic Circle, have mercury blood levels as high as 12 times the recommended US guidelines for this toxic metal. They do not create this mercury pollution themselves; this is a “gift” to them from the industrialized world as they subsist on a diet of whale, seal, and fish contaminated by global deposition of mercury (L. Greer et al, “Curtailing Mercury’s Global Reach”, Worldwatch Institute, State of the World 2006, p 96).

Mercury is very dangerous to embryos and fetuses, where it is concentrated in the placenta and enters the body of the unborn child, where its damaging effects are most evident within the developing brain. One out of six American women of child bearing age already have blood levels of mercury that exceed federal guidelines. This puts approximately 600,000 babies at risk in the US alone. Why is mercury particularly dangerous to unborn babies? It is concentrated in the placenta and it crosses the blood brain barrier of the developing baby and arrests dividing cells by affecting the microtubules of the spindle of chromosomes. Babies so affected have fewer brain cells, and this is an effect that is irreversible and lifelong. The extent of damage is dependent upon the dose of mercury and host genetic susceptibility factors. Since we don’t subject children to brain biopsies to count the number of neurons, this is an effect that can only be measured indirectly, by loss of IQ, learning disabilities, and behavioral problems. The National Academy of Science has stated that neurologic damage to children exposed to mercury in utero will result in increased numbers of children requiring special education and remedial classes. Mercury exposure may also continue in infants by contamination of breast milk.

When the mercury dose is very high the effects are dramatic, and have been proven in tragic industrial accidents, such as occurred in Japan and Iraq. I want to emphasize that these are extreme examples of exposures much greater than from eating Montana fish, but they clearly demonstrate the serious toxic effects of mercury.

a. Minamata’s disease- The coastal waters of the cities of Minimata and Niigata, Japan were contaminated with mercury during the 1950’s. There were 21,000 claims of injury and 600 fatalities. Among those affected were 22 pregnant women who gave birth to children with severe anomalies, mental retardation, cerebral palsy, and seizures.

b. Iraq grain- During the 1970’s mercury was used as a fungicide for stored grain and was inadvertently consumed instead of planted. Of the 6,530 affected individuals, 439 died. There were 83 women who were pregnant at the time of exposure. These women underwent tests for mercury in their hair, and the adverse effects in their offspring were seen in mercury levels as low as 10 parts per million.

There is a correlation of mercury emissions with rates of autism and special education needs for young children in Texas. Children more readily absorb metals than adults. In a preliminary study performed by Dr. Claudia Miller and colleagues at the the University of Texas Health Science Center in San Antonio, Texas, there was a 17% increase in the rate of autism for every 1000 pounds of environmentally released mercury and a 43% increase in the rate of special education services.

As if the cost in human suffering isn’t enough to justify the expense of mercury controls, public health researchers at the Mount Sinai School of Medicine, Harvard Medical School, and Albert Einstein College of Medicine have quantitated the lost productivity to society from methyl mercury toxicity at approximately $8.7 billion, as referred to in the Feb. 2005 NESCAUM (Northeast States for Coordinated Air Use Management) and the Harvard Center for Risk Analysis. See also: L. Trasande, P. Lanrigan, and C. Schechter, “Public Health and Economic Consequences of Methyl Mercury Toxicity to the Developing Brain”, Environmental Health Perspectives, vol 113, #5 (2005) 590-596.

Mercury has an adverse impact on the immune system in people of all ages. Mercury replaces trace metals in some enzymes and binds to sulfhydryl groups. Mercury inhibits lymphocyte functions and is linked to increased allergies and autoimmune reactions.

Two preliminary studies show that mercury conveys cardiovascular risk to middle aged men (studies not yet complete in women). Mercury has no known beneficial physiologic effects. Mercury promotes formation of damaging free radicals. Mercury disables the body’s most powerful natural antioxidants (glutathione, superoxidase dismutase, catalase), and it inactivates the beneficial effect of selenium. All of this has the net effect of damaging cell membranes and making cholesterol more likely to deposit in plaques. In one European study of 400 men there was a correlation of increased levels of mercury and risk of heart attacks and coronary artery disease. In a separate study there was a 50%-70% increased risk of heart attack and coronary artery disease in patients with increased mercury levels.

At high concentrations neurologic damage occurs in people of all ages. The culprit here is not only methyl mercury, but also elemental mercury or mercury salts.

1. The expression “mad as a hatter”, which was popularized in Lewis Carroll’s Alice in Wonderland, comes from the occupational hazard of using mercury compounds to make felt hats during the 1800’s.

2. In the mercury mines in Spain the miners are asked to draw a line in-between two narrow lines before they descend into the mines. When their tremor becomes so bad they can no longer stay between the lines they lose their job.

As recently shown in the Steubenville Ohio study, mercury disproportionately settles locally. Federal Agencies are required to examine possible disproportionate impacts on children and on minority and low income populations. Children are clearly disproportionately affected by mercury pollution. The Rocky Boy Indian Reservation with a population of several thousand Native Americans is directly downwind and downstream from the proposed coal plant. Inhabitants of the Reservation have registered their strong opposition to the coal plant, as evidenced by their written testimony and by hundreds of signatures on the petitions opposing the coal plant.

VI. Other Important health concerns- Particulate Matter 10 microns and less:

A 2006 television HBO documentary, “The Air We Breathe”, graphically demonstrates the marked increase in the rates of asthma in children living adjacent to coal plants. The Highwood Generating Station is permitted each day to release one ton of dangerous, respirable PM 10 particulates, laden with toxic heavy metals such as arsenic and lead. We now have evidence that very small particles not only endanger people’s lungs, but also hearts and arteries (Science News, August 2, 2003, p.72). Why would we do this to our children, ourselves and our planet, when better and cleaner alternatives exist?

Conclusions

A lot of the work and expense by the proponents has already gone into this project. We admire the spirit of independence of SME and the City for tackling such a huge project and wanting to bring economic prosperity to our community and state. However, the road to disaster is often paved with good intentions, and we believe that their plans for a CFB coal plant are misguided. If as a physician I used outdated technology when a clearly superior alternative exists (even if it costs more), I’d be sued for malpractice.

THE RUS SHOULD NOT PROVIDED LOAN GUARANTEES FOR ANY NEW COAL PLANT UNLESS IT EMPLOYS THE ZERO EMISSION INTEGRATED GASIFICATION COMBINED CYCLE (IGCC)TECHNOLOGY OF THE 21st CENTURY. An IGCC coal plant removes mercury in such a pure form that nearly all the mercury from one year’s supply of coal would easily fit in a closet, instead of being scattered in our air, deposited on our land and incorporated into the fish of our scenic waterways. Industry may complain that IGCC is too expensive (they can’t afford not to do it); that it can’t be financed (IGCC plants are currently being planned by Exergy, Basin Electric, and numerous others); that IGCC is “unreliable” (see above). The reality is that Idaho has declared a 2 year moratorium on coal plants, Wyoming Governor Freudenthal submitted a proposal for a $1 billion IGCC plant, citizens in Utah have stopped an older style coal plant like the one proposed near Great Falls by going to court, the locals prevented a 500 MW coal plant from being built in Austin, Texas, and California Governor Schwarzenegger has indicated that California will refuse to buy electricity from coal plants unless they sequester greenhouse gases, something that is feasible with IGCC but not with older style coal plants like the facility being planned for near Great Falls.

In this circumstance the people appear to be ahead of the politicians; our President has abdicated responsibility while apparently succumbing to the lobbying pressures of the established fossil fuel industry. As a society “We need to get it right!” Many citizens have already expressed their displeasure with the coal plant through letters to the Editor of the Great Falls Tribune (enclosed). Our elected leaders and public officials must not perpetuate the problems of mercury and other toxic heavy metals, greenhouse gases, and particulate contaminants for future generations.

If we in the most prosperous nation of the world and in a state with the strongest constitutional guarantee to a “clean and healthful environment” can’t set the example for making a decision in the best interest of public health and the planet, what hope do we have for impacting the 750 coal plants that will be built in China and India during the coming decades. A modern world needs electricity, but we also need clean air and water. With the help of agencies whose were designed to safeguard our health and well being, we can have both. Please do your job for the people who pay your salaries, and “Just say No!!”

Sincerely yours,

________________________________

Cheryl M. Reichert, M.D. , Ph.D., Pathology and Biological Chemistry

p.s. I am sending this letter electronically via email, to be followed by signed hard copies with the enclosures. I am requesting that these enclosures also be included as part of the formal record.

encl: Great Falls Tribune, July 26, 2006, James Childress, Executive Director, Gasification Technologies Council

encl: Letters to the Editor of the Great Falls Tribune , dated 5/4/05, 5/5/05, 5/14/05,12/22/05, 4/16/06 (three letters),4/21/06,4/27/05,4/29/06, 5/02/06 (two letters), 5/03/06, 5/21/06, 6/10/06, 6/20/06, 6/21/06, 7/04/06, 7/14/06, 7/22/06, 7/26/06, 7/29/06 (Quote of the Week), 8/4/06, 8/10/06, 8/13/06, 8/22/06 (two letters), 8/24/06