August 25, 2006

Lisa Lotte Hardiman

3726 4^th Ave. North

Great Falls, MT 59401

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:

Comment on DEIS Highwood Generating Station. I agree with option 1, the No Action Alternative, not to build anything. Great Falls has five dams, Horseshoe Bend Wind Park on Gore Hill, a 50 megawatt wind farm in Judith Gap and another wind farm in Cutbank currently being developed. There is enough power being generated.

After going through the DEIS, I have these questions:

1) Why wasn’t Benton Lake Wildlife Refuge mentioned? I read about the Fish and Game concern over finding eagles poisoned by mercury and the impact on the Canadian Cougar, and a number of other birds and wildlife but no word on the Refuge. As a crow flies the Highwood Station is about 20 miles from the refuge. Already songbirds are found with unusually high concentrations of mercury in their blood and feathers. What will be the impact on birds in the refuge?

2) Why have a system that uses so much water? 1.7 billion gallons of water will be used per year. That is enough to meet the needs of 26,000 people. We are just getting out of a ten year draught. Neither ground nor waters have recovered yet.

3) Why do we need that much power 250 MW? In the April, 2005 scoping meeting I attended, SME spokesperson rules out Wind, solar and hydro, geothermal as infeasible and in the DEIS greatly hints that excess power will be going to WY to develop coal methane gas. Tim Gregori also stated in a Fort Benton meeting that excess power will be going to Bonneville Power to offset water level loss in the Columbia River going through the dams. In highest peak power use, including growth of 5 per cent a year in the Billings area, the maximum is 105 MW. Why do we have to have so much excess energy produced?

4) Doesn’t the USDA and DEQ check references? In the April, 2005 scoping meeting, Tim Gregori showed other coal plants that Bison Engineering built. One of those plants was Thompson Falls Generating Power Station. Bison Engineers with Stanley engineering built this 25 MW facility and it ran for 16 months only to be shut down by the DEQ for violating its own air quality permit. It was discovered that the equipment and turbines used in Thompson Falls plant came from a closed coal generating facility in Pennsylvania. The initial building was a pretense of new.

5) Why CFB and not IGCC? If coal is being crammed down our necks than why not IGCC? Countries like Ireland and Italy and Australia have this. It is a system that doesn’t release 73 toxic chemicals in the air. It uses 40 % less water, and there is less CO2 emissions.

6) Why more mercury? The Great Falls Tribune compared this plant to a CFB plant in Eastern Kentucky. Kentucky is on a high advisory of mercury in the fish where fish still exist. (Kentucky’s waters are mostly destroyed). Already 44 states have issued mercury advisory, including Montana. Doesn’t it make sense not to put 40 more pounds of it in the air?

7) There is a great understanding how these toxics from the proposed generating plant will impact the health in the interconnection of people and environment: (per year) 443 tons of sulfur dioxide, 994 tons of nitrogen oxides, 1177 tons of carbon monoxide, 366 tons of particulate matter (including arsenic, beryllium, cadmium, manganese, lead), 3,052,081 tons of carbon dioxide, 62 tons of sulfuric acid mist, 38 tons of volatile organic carbon, 24 tons of hydrochloric acid, 20 tons of hydrofluoric acid, 40 pounds of mercury and toxics in “fly” coal ash;

Is it right to continue the project when there are better and cleaner alternatives?