Hilary Ransdell

2304 Second Avenue South

Great Falls, MT 59405

(406) 771-0631

August 28, 2006

Richard Fristik

USDA Rural Development, Utilities Programs

1400 Independence Ave. SW

Mail Stop 1571, Room 2237

Washington D.C. 22050-1571

Kathleen Johnson

Department of Environment Quality Director's Office

P.O. Box 200901 Helena, MT 59620-0901

RE: Draft Environmental Impact Statement

Highwood Generating Station

Great Falls, Montana

I herewith submit my comments on the DEIS which has been produced pursuant to Southern Montana Electric’s (SME) proposed “Highwood Station” Coal-Fired electricity generating plant near Great Falls, Montana. I do so with a combination of discouragement and hope. I feel discouragement, because there has been precious little opportunity for a proper degree of meaningful public input on this plant; our local government has been highly resistant to giving out any information on their dealings in regard to this plant; our governor has done a surprising about-face and come out in support of this project, possibly in response to local labor pressure; and our state laws in regard to the efficacy of the EIS process in having any actual effect on such an ill-conceived project have recently been severely gutted. I feel hope only because I refuse to give it up, even in the face of seemingly overwhelming odds. I hope that this process of commenting on the DEIS will actually be meaningful. I hope that this ridiculous, ill-conceived, possibly illegal and even dangerous project is not a fait accompli, as it seems. I hope that the will of the people in this country still counts for something. I hope that the “powers that be” are able to be far-sighted enough to do what is right, not what is expedient or what they hope will put money in their pockets to the detriment of this community and indeed of this planet.

This DEIS is a lengthy and detailed document. As such it was not easy for me to grasp it fully within the time frame allotted. I cannot honestly say I do grasp it fully. But one thing at least is very clear to me: It is strongly biased towards SME. This is one failing of this DEIS. While presenting itself as a scientifically unbiased analysis, in reality it deals only in information provided by SME. I have been following this project for nearly two years now, and I have listened to the same dog and pony show trotted out by SME ad nauseam, so I recognize this material. A true evaluation of the environmental impacts of this project would also evaluate other types of projects that would accomplish the same ends. In other words, it would not reject consideration of (at the very least) Integrated Gasification Combined Cycle technology, at least as a comparison. One of our main objections to this project is that SME summarily dismissed many much better and more economically sound alternatives to this particular plant, even before this project was unveiled to the public.

One of the alternatives considered in this DEIS is that of not building the plant. I believe the comments under that heading are also biased. While it does admit that not building it would result in no negative impacts locally, it goes on to say essentially that the power that we here will be using has to be generated somewhere, and wherever that power is generated will have negative effects on that locality. In the first place, this is very misleading and places a falsely negative light on not building the plant. Such power as we will be using in case of the plant not built is essentially the same as the power we are using now. Not building the plant will not increase a negative effect. Secondly, this assessment essentially admits (or assumes) that the generation of power is going to have a negative effect, and seems simply to say that if you want power generated you had better be prepared to be polluted. This is certainly true of this type of coal-fired generation.

However, at this point in the history of this planet, we cannot afford to accept pollution in exchange for power. And we do not have to, as other viable alternatives exist, including conservation and efficiency. Global warming has progressed to the point at which we must all make a concerted and focused effort now to reduce carbon emissions, or face unparalleled negative impacts to the ability of this planet to sustain life. Mercury is an unacceptable pollutant at any level. Acid rain will have a deleterious effect on wheat farming here in the Golden Triangle.

One of the perceived positive impacts of building the coal plant is its hoped-for boost to the local economy in the form of jobs to build and jobs to run the plant. It is true that this project will provide the hoped-for jobs. But is this the only kind of project that will provide such jobs? This DEIS does not even point out that while this may indeed be considered a plus, it is not unique in providing that kind of plus. It seems that one of the main reasons for local support of this plant is this perceived economic boost. The DEIS does consider this kind of impact; therefore it is remiss in not addressing alternatives, or at least not pointing out that while this is a perceived positive impact, it is not unique to this plant and therefore cannot be considered a deciding factor in its favor, especially in light of the many negative impacts in other areas

In addition, the DEIS does not stress the possible negative economic impacts this plant will produce in this area. Great Falls is in a position to become a destination city and center for tourism. We have this wonderful river (if we would only care for it and recognize it for the blessing and boon it is!). We are a “gateway” community to the Upper Missouri Breaks National Monument, Glacier National Park, the Highwood and Little Belt mountain ranges, and the Rocky Mountain Front, home of some of the most pristine wilderness in the lower 48 states. The vicinity of our great river is the home to a large population of bald eagles, our national symbol, now recovering from decline. The river flows to Fort Peck Reservoir, where they are even now working to save an endangered species of sturgeon, the eggs of which are valued as caviar and the marketing of which is an economic boon in that area. How ironic that we would build this coal plant here, which would contribute to the melting of the glaciers in the park and would obliterate the pristine condition of the views and countryside we are trying to preserve, would endanger the eagles by increasing the mercury in the fish they eat, and would work counter to the conservation and economic efforts downstream! People want to come here to see the scenery and breathe the air. Here in Great Falls, the sky is still the glorious Big Sky. Why would we want to put this disgusting blot here? We already have a stinky refinery; we got rid of a polluting and dangerous smelter (but we still have the Superfund site); do we just miss the stack, so that we have to build another one? With the haze from this coal plant, we will not even be able to see the Highwoods half the time, let alone the Rocky Mountain Front. Furthermore, while Mr. Urquhart may profit from the sale of his land, others in surrounding areas will suffer an economic loss because of pollution and loss of esthetic value of property. We are deceiving ourselves if we think this plant paints a rosy economic picture. If economic development is our target, we are shooting ourselves in the foot.

These issues and more need to be analyzed in the EIS and compared to the economic plan for the plant; and the economic plan for the plant needs to be laid out in the EIS so that this comparison can be made. And the economic plan for the plant needs to include not only the above-mentioned concerns but such things as the following: Who is buying the power? At what price? What is the price for coal? What is the price for coal transport? Once the business plan is well laid out in the EIS, then it should be compared to other alternatives, such as conservation and efficiency, solar (revolutionary new technology is now available and being used in San Francisco, which enables industrial-scale manufacture of solar panels at one-tenth the current price), wind, hydroelectric from the dams in Great Falls, and IGCC, remembering that the IGCC process produces salable by-products that can be used to offset the slightly higher initial cost of the plant.

If the citizens of Great Falls and of southeastern Montana really, really needed this plant, it still should not be built as planned. If it must be coal, it would be imperative for IGCC technology to be considered. But the fact is that we do not need this plant. SME does not need it; there is plenty of power to go around in eastern Montana, but SME split from the other co-ops over this coal plant question. That makes this a false emergency. SME’s customers can again be served by the same suppliers that will be serving the other co-op, and probably at lesser rates.

We do not need it in Great Falls. There is no reason for us to be part of this cooperative, certainly not without a public vote. If we need a little extra power, or if we want to be more secure or independent, we can look into wind or solar or conservation. Biodiesel and/or the building of a biolubricants plant in our agricultural industrial park (instead of this coal plant!) would serve our needs and provide the jobs sought.

In Montana, our Constitution guarantees us, its citizens, the right to a clean and healthful environment. Our city government, in involving itself (and us perforce) in this misbegotten idea and in steadfastly refusing to consider any other options, is violating that guarantee. I am hoping that the entities drafting this EIS will create a truly unbiased document which contains all the necessary data showing the impacts of this plant locally, including baseline studies of our local air, water, and land. This is the only way a good decision can be made. I also hope that you do not slavishly consider adhering to the current environmental standards, which are wholly inadequate to the purpose. I believe that before this plant would become operational, more stringent standards will be in place. It would be stupid to build a plant you immediately have to retrofit.

I have lived here for 19 years, and I raised my daughter here. I have set my roots down. I am an avid gardener, and while I am probably not an expert, I enjoy learning and my gardens give me a source of joy, relaxation, beauty, and organic produce. I thought you might enjoy some pictures of what I have going on here. I don’t want my gardens polluted by this plant. I want the rains to refresh the nourish my garden, not impair it or render my produce I work so hard to raise organically unfit for consumption. I don’t want to have to leave Great Falls because this thing is built here.

Somehow in this process there has to be a way to stop this debacle and protect the citizens from the disastrous environmental and economic consequences that will surely follow.

Sincerely,

Hilary Ransdell

2304 Second Avenue South

Great Falls, MT 59405