August 30, 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 am Mark Fix, chairman of the Board of Directors of the Northern Plains Resource Council. Northern Plains appreciates the opportunity to submit these comments. I am also a rancher and irrigator and live about 20 miles southwest of Miles City. I am a member and customer of Tongue River Electric Cooperative. Many Northern Plains members live in other cooperative service areas that would be serviced by the proposed power plant. Northern Plains organizes Montana citizens to protect water quality and quantity and we protect family farmers and ranchers and strive to retain the lifestyle we all love in Montana.

There are several issues that I would like to address regarding both the Environmental Impact Statement and also the process by which public comment has been solicited.

First, the process that has occurred with this proposed power plant seems one sided. All the scoping hearings and hearings for the draft EIS have taken place in Great Falls. We were not given notification of these hearings. Hearings should have been held in multiple communities that this power plant will service and impact.

I have been reading about this power plant in the Rural Montana Magazine. The July issue featured and article which explained that our contracts with Bonneville power will expire in the near future. Then, in the August Issue, Dave Wheelihan, CEO of the Montana Electric Cooperatives’ Association had an article praising the fact that Congress has initiated a resolution that requires that 25% of the nation’s energy needs come from renewable sources by 2025. Currently, most of our power comes from Bonneville Power and it is hydro-power which is renewable. It appears that we are going from almost 100% renewable power to almost 100% non-renewable power from a coal fired generation plant for almost a third of the State’s area. It doesn’t seem prudent to back pedal to the minimum renewable requirements, when we are currently meeting and exceeding expectations with reliable, renewable power.

Hydro-power appears to be the cheapest form of power and cost is a crucial factor for those of us in rural cooperatives. I personally use electric power to pump the water for irrigating about 250 acres on my ranch. If costs increase too much then I will look at alternative power sources for my pumping needs. I may use a diesel powered or biodiesel powered pump to irrigate with if I can save some money.

The EIS states that there are 5 hydro-power facilities near Great Falls. SME should look at purchasing these plants in lieu of spending vast quantities of money to build a new coal fired plant. Hydro power will work very well with wind power and other forms of add on power. Cost of power to the consumer needs to be the overriding factor considered in the decision to build and operate a new power plant. All costs must be considered including health. Carbon dioxide is becoming a very real concern to our environment. Global warming is occurring and this EIS needs to consider the consequences in more depth than the cursory comments given in the Global Warming section. The amount of carbon dioxide created by this plant is huge. Governor Schweitzer has taken many flights over the glaciers in Glacier Park to show people how global warming is affecting the glaciers.

The comments on page 4-54 reflect the true devastation from this power plant. Comments are made that there is not enough arable land in the world to sequester the carbon dioxide from this plant as well as other sources of greenhouse gases. This points out that we need to be going a different direction with power generation. If we cannot offset the carbon dioxide created from this plant then we should not be building it. This will only accelerate the global warming problem.

The EIS touches on the temperature rises and some of the effects of global warming. One of those effects is increased number of fires. We have definitely seen that this summer. The analysis in this EIS does not look at the increase in carbon dioxide from fires. It needs to account for the tons of carbon dioxide that were added to the atmosphere by the fires that burned over 613,000 acres in Montana so far this year. There were many additional tons of carbon dioxide added by the fires throughout the United States this summer. When discussing global warming, we must take into account the cumulative effects of power plants around the world, such as China and other developing countries. We have a chance to turn things around and use more renewable energy. The Judith Gap wind farms show what we can do to increase our renewable power sources. SME covers a vast area and if wind farms were spread out throughout the area the chances are better that the wind will be blowing at one location if it isn’t blowing at another location.

Developing our renewable energy sources is a better idea. Not only will this help mitigate the effects of global warming, but renewable energy also has the opportunity to spread rural economic development. The job possibilities throughout the state could be huge instead of adding all the new jobs in the Great Falls area.

When the Tongue River Dam was enlarged there was a proposal considering hydro-power. I believe that should be looked at again. Most of the water rights belong to the irrigators and the Northern Cheyenne tribe. However it could be a very good supplemental power source. The power could be generated when the water is released which is when we irrigate and need more power for our electric powered irrigation pumps.

In Montana, we need to develop decentralized power. It will build economic prosperity around the state and would enable us to utilize existing infrastructure. Several smaller power facilities would enable the cooperatives to utilize existing power lines and would not require building new power infrastructure.

Coal fired plants are not designed to utilize supplemental power very well. They are the most efficient when they are fully utilized. If communities elect to put a wind farms into the grid, a power plant should be able to adjust. As the demand for green energy increases, SME will need to supply the need and this coal fired plant will only hinder the development of green power.

The last legislature looked at taking back the dams near Great Falls. This is something that should be considered by this EIS and the next legislature. We cannot allow all of our hydro-power to be taken out of state.

This EIS compares buying power to providing your own power. It will always be cheaper to provide your own power versus buying power. Compare providing our own hydro-power to providing coal fired power. Obviously hydro-power will be much cheaper.

Another area that has not been fully considered is the cost of coal in the future. If coal costs increase, this will affect our rates. You cannot assume that coal will always remain cheap. Natural Gas has prices have increased dramatically and the analysis in the EIS discounts natural gas because of the cost. The costs to ship the coal to Great Falls will increase as the cost of diesel increases. How much will the coal cost if diesel goes to $5 or $6 per gallon? This will not only affect the shipping costs but it will affect the cost to get the coal out of the ground.

How much additional carbon dioxide will be added by the two trains that come to Great Falls each week? This needs to be added to the cumulative affects from greenhouse gases. Another area that needs to be looked at is the cumulative effects of increased power costs. I pointed out that if prices increase dramatically I could use diesel. Burning diesel will add to the global warming problem. A large increase in power consumption has been requested for operations in the coal bed methane fields. If prices are too high they may use diesel power or burn more natural gas. This will also add to the global warming problem.

In addition to the costs associated with development of coal there are also costs to reclaim the lands disturbed by coal strip mining. This takes additional diesel fuel which in turn increases the carbon dioxide emitted. The cumulative affects need to consider coal mining and coal shipping as well as coal burning.

The EIS seems to discount the problems associated with ash disposal. Near Colstrip water is seeping through the ash and has contaminated several wells of neighbors near the ash pits. Wells are becoming highly saline and may not be usable for stock. The EIS needs to take into account the ash seepage that may occur with this plant. It could reach the waters of the Giant Spring. The source is in the Belt Mountains and could very well go right under where the plant is proposed. This is very close to the Missouri as well. There will be a pipeline dug to the Morony reservoir. This will serve as a channel path for seepage from the ash storage area and could contaminate the water in the Missouri. It is not worth taking the chance of destroying these great water bodies in Montana.

Another aspect that is not looked at is the high sodium content of the Decker and Spring Creek coal. The high sodium content causes deposits in the generating plant that have to be removed by blasting. The fluidized bed process will be impacted by the high sodium content of the coal. The high sodium content in the coal is what made the ash problem more serious at Colstrip. Sodium is highly water soluble and rain will percolate through the ash pit and cause the sodium to migrate. The high sodium in the coal will also add more sodium to the water treatment facility. Can the city water treatment facility handle the additional sodium load from this water? What will the sodium level of the discharge water be? The Tongue and Powder Rivers and Rosebud Creek currently have salinity and sodium standards set. The Missouri will not be protected from sodium and salinity without these standards.

Water is another concern. Hydro-power is a non-consumptive use of water and that is why it should be preferred. Water is too precious and there are many downstream needs for the water that would be consumed by this power plant. The EIS states that this plant could use up to 3500 gallons per minute or 5600 acre feet per year. When I get a water right for a well the state limits me to .017 acre feet per cow per year. This would be enough water to supply over 329,400 cattle with water for one year. We need to conserve water, not unwisely waste it.

In conclusion, Northern Plains believes that more renewable sources of energy need to be considered before proceeding with a coal fired plant near Great Falls. This EIS does not analyze the hydro-power alternative or other alternatives closely enough to determine which alternative is truly the best. We need to replace the power we currently obtain from the Bonneville Power administration with power that is just as clean and renewable. We need to move forward in our power portfolio and not backward.

Once again thank you for the opportunity to comment on this EIS.

Sincerely,

Mark Fix

Chairman of the Northern Plains Resource Council

220 S. 27^th Street

Suite A

Billings, MT 59101