August 28, 2006

Kathleen Zivic Gessaman

1006 36^th Ave NE

Great Falls, MT 59404-1263

Richard Fristik

USDA Rural Development, Utilities Programs

1400 Independence Ave. SW

Mail Stop 1571, Room 2237

Washington, DC 22050-1571

Kathleen Johnson

Montana Department of Environmental Quality

PO Box 200901

Helena, MT 59602-0901

Dear Richard Fristik and Kathleen Johnson:

The Environmental Impact Statement (EIS) for the Southern Montana Electric Generation and Transmission Cooperative, Inc. (SME) Highwood Power Plant, clearly shows that this power plant will be a substantial source of new and hazardous air and land pollution. I support the no action option as noted in section 2.2.1 No Action. I do not believe the contention that the original electrical cooperative group would not allow the SME splinter group to rejoin the cooperative. In the “real” world of profit–motivated businesses, SME’s customers would not be left to “simply ‘do without.’”

New Source Review Permitting Program (Chapter 3 pg. 26)

This power plant does not comply with the directive of the NSR program to assure people “that any large new industrial source in their neighborhoods will be as clean as possible.” Mercury pollution is a major concern of local citizens. The proposed SME Highwood plant does not have an electrostatic precipitator upstream of the bag–collector or an activated carbon injection stream between the two to improve mercury collection. The following reference, “Results of Activated Carbon Injection for Mercury Control upstream of a COHPAC Fabric Filter” May 2003 [http://www.hamon-researchcottrell.com/industry_Power.asp], describes using this equipment sequence to reduce mercury pollution. Of course, the air pollution control industry has many different ways to reduce air pollution, but a best effort has not been exerted to date.

The amount of mercury (40 lbs - from the revised draft air quality permit) and lead (560 lbs) to be released by this power plant each year is of particular concern to citizens with children living in the vicinity or downwind of the power plant. Over the course of fifty years, what will the estimated 2,000 lbs of mercury and 28,000 lbs of lead deposited on Golden Triangle farmlands and cities do to our health and the environment?

Hazardous Air Pollutants (HAPS) (Chapter 3 pg. 28)

The high levels of air pollution generated by this power plant should be unacceptable. Take hydrogen fluoride (HF) emissions as an example. HF alkylation units may be in violation of environmental regulations if only 10 lbs/year of HF escapes from a typical plant inventory of 20 tons of HF. The proposed Highwood plant plans to emit 20 tons of HF annually into our relatively pristine air for the next 30-50 years. Just one drop of HF on bare skin will burn a human until the calcium in a bone neutralizes it. What will 1,000 tons of HF gas do to our people, farms, grasslands, and forests over 50 years?

The revised draft air quality permit for the Highwood plant shows it will emit 62 tons of Sulfuric Acid Mist per year, 24 tons of Hydrochloric Acid Gas per year, 20 tons of Hydrofluoric Acid Gas per year, 944 tons of Nitrogen Oxides per year, and 443 tons of Sulfur Dioxide per year. These chemicals are all contributors to acid rain. Who will pay for acid rain damage to vehicles, steel-sided building, etc., located within a fifty–mile radius of the power plant or downwind of the plant? Will the tourists still come to see Montana’s beautiful landscapes when acid rain ravishes them like the emissions from Midwest power plants are currently doing to the New England forests?

How will data on acid rain, mercury, lead, volatile organic compounds, etc., be collected in areas outside the power plant property? Who will collect this data in ten–mile, concentric–rings increments around the plant? Will the state oversee this data collection? Will this data be available to the public in a timely manner?

5.0 Cumulative Impacts

Table 5-1 is a summary of direct and indirect impacts associated with the various options. This table appears to address only the plant site area and leaves out the plant’s impact on the surrounding area. The 400-foot stack SME plans to build conveniently disperses the pollutants from the power plant far and wide. Table 5-1 is misleading because it does not address the entire dispersal area. The Soils, Topography, and Geology section should include irreversible adverse soil impact from mercury, lead, and other heavy metal releases. Potential acid rain harm to forests within the dispersal area should be documented.

Under Air Quality, I fail to see how the large quantities of mercury, lead, hydrofluoric acid gas, hydrochloric acid gas, sulfuric acid mist, volatile organic compounds, carbon monoxide, nitrogen oxides, sulfur dioxide, particulate matter, carbon dioxide, arsenic, beryllium, cadmium, and manganese emissions can be deemed negligible to minor. Will area organic farmers agree with the assessment that the effects of these chemicals are inconsequential?

E. Coal Fuel Processing, Handling, Transfer, and Storage Operations (Appendix I - Draft Air Permit pg. 6 supplemental PD 6-30-06)

Currently even moderate wind gusts result in Great Falls being coated in dust and dirt. Any coal pile will be another source of particulate. How will SME keep dust from its emergency coal pile(s) from blowing all over the countryside? Will the water allocated for spraying on the coal pile(s) automatically adjust for wind speed/direction?

The Lewis and Clark portage route is presently located in mostly pristine areas. How will SME keep coal dust and contaminants from coating this area?

I am concerned about the cumulative impact of the proposed Highwood power plant on the long–term health of citizens and the global climate. We do not yet know at what level the various pollutants contribute to cancer, autism, birth defects, etc., in humans or when too much carbon dioxide and nitrous oxide will cause irreversible harm to the earth’s atmosphere. The draft EIS does not demonstrate a convincing need for another merchant power plant in a state that already has an energy surplus. Companies such as Nanosolar (backed by Google’s two founders, the insurance giant Swiss Re, and others) are beginning to produce inexpensive solar cells. Within five years environmental and health damaging coal power plants, such as the one proposed by SME, may be totally obsolete.

We the citizens of Montana do not need to degrade the health and future of our land and our people to produce electricity for out–of–state consumption. Electricity can be generated or conserved in countless ways that have less of an irreversible impact than the SME Highwood power plant will have on our state. Every citizen of Montana has a duty to uphold our constitution which states in Article IX, Section 1 “(1) The state and each person shall maintain and improve a clean and healthful environment in Montana for present and future generations.”

Sincerely,

Kathleen Z. Gessaman