Windwalker ranch ‘natural beef’

Richard & Lynda liebert MT bqa certified

289 Boston coulee road (eden) #1056

great falls, mt 59405

HYPERLINK "mailto:406-736-5791/wwranch@3rivers.net" 406-736-5791/wwranch@3rivers.net

www.montanacatalog.com

August 28, 2006

MEMORANDUM FOR

Richard Fristik, USDA Rural Development, Utilities Programs,1400 Independence Ave. SW, Mail Stop 157, Room 2237, Washington, DC 22050-1571

Kathleen Johnson, Montana Department of Environmental Quality

PO Box 200901, Helena, MT 59602-0901

SUBJECT: Citizen Response to the Draft Environmental Impact Statement (DEIS) for the Highwood Generating Station, Great Falls, Montana

1. References. US Departments of Agriculture (USDA), Energy (DOE) and

US Environmental Protection Agency (EPA); Montana Department of Environmental Quality(DEQ); Governor Schweitzer; Montana Environmental Information Center; HYPERLINK "http://www.25x'25.org" www.25x’25.org; HYPERLINK "http://www.aeromt.org" www.aeromt.org; American Wind Energy Assoc (AWEA); National Center for Appropriate Technology (NCAT); MT Public Service Commission; MT Board of Investments

Background. As a citizen, agricultural producer and retired Army

officer, I have many questions as to why this type of plant is being proposed that will not truly benefit our economy, energy development, health, environment and national heritage. There are sound alternatives – if more thoroughly examined – that would prove feasible economically and provide Montana and America with a cleaner and affordable energy solution.

The staff members and consultants that composed and provided input for the DEIS are indeed professionally qualified. That alone should not diminish the caliber of responses from the general public that has been asked to provide questions, commentary and insights at public hearings and by documented correspondence. Since the public now fully knows who Southern Montana Electric (SME) and Electric City Power, Inc. (ECP) of Great Falls are, I would like to elaborate on my background since you and your staff may not fully appreciate my perspective.

Since I have been portrayed by others as a ‘radical’ naysayer (and worse) I wish to set the record ‘straight’ as to my own knowledge and skills relevant to my analysis of the DEIS (in regards to science, economics, energy, business, governmental process, mission analysis/decision-making and planning) I offer the following credentials:

BS degree, Agriculture, Purdue University and MBA earned on-line from Touro University while on active and reserve Army duty. I recently retired as a Lieutenant Colonel after 28 years of commissioned service to the Army, Army Reserve and Army National Guard in New York and Montana.

I have successfully owned and operated a sustainable, family farm/ranch operation since leaving active Army duty 15 years ago, developing a natural beef marketing enterprise to add value to my family’s agricultural production while in the midst of a long and severe drought, which we are just slowly recovering from, but is not over yet. That is why I am extremely concerned about water diverted from future value-added agricultural ventures like biomass development.

Through innovative, practical applications and plain ‘old’ persistence, my family has managed to stay on the land and that unique American ‘Can Do’ philosophy can help us provide cleaner, renewable energy opportunities balanced with existing fossil-fuel sources while we strive for better ways to create energy that will not contribute to climate change and Global warming – we have only one planet and “Good planets are hard to find.”

Renewable energy is not just a ‘fad’ for me, and I’ve been studying this field for at least six years while in the ‘grip’ of the drought and worked briefly with the county extension office in a wind energy study group. The loss of production capability was devastating, and any means to add value to farm production by marketing wind energy seemed and IS now very encouraging. I have the privilege of being appointed to the agricultural study group that will provide effective greenhouse gas reduction recommendations to Governor Brian Schweitzer’s Climate Change Advisory Committee (CCAC, HYPERLINK "http://www.mtclimatechange.us" www.mtclimatechange.us).

As a member of the Montana Farmers Union, I also serve on the state steering committee for 25 x ’25, a national renewable energy initiative ( HYPERLINK "http://www.25x'25.org" www.25x’25.org) that has set a goal that 25 percent of our energy will come from renewable sources by 2050. This plan has been heartily endorsed by Governor Schweitzer, our federal legislators, and many diverse agricultural, economic and environmental groups, to include the Alternative Energy Resources Organization ( HYPERLINK "http://www.aero.org" www.aero.org) of which

I was member many years ago and have since rejoined their ranks.

*At this point I will present my questions in ‘bold, italic’ format when the situation arises for my questions.

a. What has SME and ECP done to understand and contribute to the achieving the goal of 25 percent of our energy produced from renewable energy by 2025? ( HYPERLINK "http://www.25x'25.org" www.25x’25.org) I would expect the subordinate rural electric co-ops of SME to vigorously support 25x’25 in support rural landowners.

b. What has SME and ECP done to understand and contribute to Governor Schweitzer’s efforts to seriously reduce greenhouse gas emissions and promote locally established renewable energy opportunities? ( HYPERLINK "http://www.mtclimatechange.us" www.mtclimatechange.us)

c. How will the proposed action – HGS, Salem – contribute to the USDA’s goal of a new ‘Rural American Renaissance?’ That slogan ‘rings hollow’ as there are no large USDA RUS financed wind energy enterprises in the state of Montana. The existing wind farms have been commercially financed, and I find it disheartening that not ONE rural electric co-op in the state of Montana had the vision and boldness to attempt such a positive step. Selling farmland for a coal plant site does not contribute to a ‘Renaissance’ for Rural America and sustainable agriculture.

3. Method of analysis and inquiry. My questions and comments will proceed forward by paragraph identifier (i.e., 1.1; 3.3.6, etc).

Executive Summary, Page ES-7, ‘No Action Alternative’ Why can’t impacts at other power plants be specified or quantified or wouldn’t other effected communities want to know?

Page ES-8 What ‘cause for alarm’ is there for City of Great Falls residents, as they are still and will be customers of Northwestern Energy and would the effect still be adverse and significant?

Pages ES 8-14 Proposed Action.’ How can this, the Salem or Industrial site options be the ‘best’ when you consider that each has ten or more ‘Adverse’ classifications of 14 key areas examined? Adverse is defined as ‘unfavorable’ by the American Heritage Dictionary.

How many of the many alternatives screened out were categorized in the same manner and how many had fewer adverse findings?

1.1, ‘The Proposed Action.’ What precedents are there for other successful combinations of rural electric co-ops with municipalities throughout the nation and abilities to payback their loans?

‘Key Agency Roles, etc’ Why is the Department of Energy not

included in this entire assessment, particularly since the US Department of Energy has its own ‘Wind Powering America’ that could be exploited to fulfill and to complement the USDA’s efforts to increase RURAL economic development and protect the environment?

Where is the innovative synergy (that the USDA and DOE proposes in their 10-12 October 2006 Advanced Renewable Energy Conference to advance Renewable Energy: An American Rural Renaissance) that would offer better and cleaner ways for SME and ECP to fulfill their claimed needs? ( HYPERLINK "http://www.technologyforums.com" www.technologyforums.com) DOE and USDA are expected to focus on President Bush’s Advanced Energy Initiative (AEI), specifically biomass, WIND, solar research and how to reduce risks to investors, developers, and foster great inter-agency and commercial cooperation in finance, investment, state governments and elected officials.

Why wasn’t funding for this proposed action sought out also through the Department of Energy?

Is there a ‘rule’ that prevents combinations of funds, particularly when a municipality like Great Falls and ECP is engaged in this combined effort?

1.2.1 ‘USDA RD.’ When will the federal government reexamine the 1936 REA, as it is now seventy years old, and should be reexamined in conjunction with the DOE and EPA to effectively offer loans to Rural America, as jointly advocated by the DOE and USDA in ‘Advancing Renewable Energy: An American Rural Renaissance”?

1.4 ‘Purpose, Need for, and Benefit of the Action.’ How much energy does the City of Great Falls truly require for residential, commercial and governmental needs?

How does the City of Great Falls (ECP) expect to become the ‘default supplier’ of 60MW of power already provided by Northwest Energy?

What assurance does the City of Great Falls have from the Public Service Commission that ECP could become the primary supplier to all of Great Falls?

How does the City of Great Falls ‘hope’ to expect that the Montana legislature in 2007 would authorize the City of Great Falls to split away from the rest of Northwestern Energy’s default supply, particularly when HB 642 (Rep. George Golie, D-Great Falls and current board member of ECP) failed in the 2005 legislative session?

Why didn’t the City of Great Falls consider supporting and buying the power generated by the Horseshoe Bend Wind Park on Gore Hill that provides 6MW of energy going out of state to Idaho? That would have set a good example and successful model and have been more efficient, not losing electricity in transmission over long distances. Paris Gibson

Would have been proud of his City, but alas, another opportunity lost.

1.5.1.1 ‘RD Scoping.’ Where are the actual advertisements listed in the Great Falls Tribune, or where they merely legal size notices ‘buried’ within the daily papers?

Was the federal National Park Service/USDA Forest Service contacted in regards to the potential compromise of the Great Falls Portage National Historic Landmark?

Why was the Salem site even allowed to encroach within the actual portage route boundaries and what ‘scoping’ was accomplished to that end with landowners, historical groups and with the USDA and Department of Interior?

What did the City of Great Falls Civic Center charge the USDA RD to conduct an ‘Open House’ scoping meeting on 13 October, 2004?

What ‘scoping’ was done for citizens outside of the City of Great Falls to get their input, especially when many rural residents, ranchers and farmers already use Northwestern Energy, and where is our right to be heard, as this could effect Northwest Energy’s rate structure and service for Cascade County citizens outside the city?

1.5.1.2 ‘DEQ Scoping.’ How comprehensive was the effort to solicit public participation – other than printed notices – through neighborhood councils, civic groups, and through the electronic media through press releases to promote curiosity amongst radio and TV viewers?

1.5.2. ‘Forthcoming Opportunities for Public Participation.’ Why was the civic group, ‘Citizens for Clean Energy’ denied the ‘Right of Assembly’ to setup a table – not necessarily in close proximity to SME, ECP and commercial contractors – at 5PM, 27 July 2006 before the 7PM public hearing?

What did the Great Falls Civic Center charge the DEQ, USDA RD, SME, ECP and commercial vendors – even non-profit groups are typical charged a nominal fee – for the Open House on 27 July 2006?

How can a federal entity like the USDA RUS justify funding – with any level of confidence considering legal challenges - a project where 25% of the participants – the citizens of Great Falls – were denied the Right to Vote on participating in establishing the HGS-Salem site, when on 1 November, 2005, the city commissioners very ‘duped’ into repealing Ordinance 3861 that had provided for a public referendum

Process for the citizens, who ultimately are the end users of ECP’s

Power supply which by law cannot happen?

How can the City of Great Falls fiscal officer – Colleen Balzarini – also serve as the executive director of the Electric City Power, Inc and doesn’t that present a ‘conflict’ of interest and objectivity? For example, how can a military commander who brings a soldier up on charges for courts martial also sit on the same courts martial board? This of course is not allowed under the Uniformed Code of Military Justice, and ‘undue influence’ is something every public servant is aware of and even our federal Supreme Court judges have withdrawn themselves from vital court decisions if they believe they might compromise the integrity of justice.

2.1.1. ‘Power Purchase Agreements.’ Again, what is the basis of the City of Great Falls load requirement by 2011 and how is that even possible considering most residents already and most likely remain Northwest Energy customers unless the legislature – and unlikely – would let ECP be the ‘default’ supplier?

What other electric co-ops might offer SME long-term contracts, such as the remaining members of the other Montana rural electric co-ops or even out of state co-ops like Bison Electric in North Dakota?

If SME load demand for 250MW isn’t realized until 2022, why doesn’t SME consider several smaller plants (like scalable wind farms and biomass) as part of a portfolio with smaller power purchase agreements, a combination of two or more alternatives?

2.1.2 ‘Energy Conservation and Efficiency.’ Have any direct financial incentives been considered toward load reduction, alter peak and non-peak demand or load-leveling options so that for example, wind farms backing each other up when needed, as suggested by Governor Schweitzer at his Energy summit in Bozeman last October 2005?

2.1.3 ‘Renewable Non-Combustible Energy Resources.’ How were cost projections in Table 2-2 determined, as I question how capital costs and fixed O & M? The Judith Gap Wind Farm (highly praised in the DEIS),

cost 150 million dollars, for 135MW capacity with 90 turbines covering only 14 square miles. Governor Schweitzer ‘lauded’ the facility, and he himself stated the MWhour cost at $38, to include firming costs.

2.1.3.1 ‘Wind Energy.’ Doesn’t SME and ECP realize that Montana has the potential to provide 116,000 MW, and why doesn’t that motivate them to exploit that tremendous potential, even in SME’s our customer area where transmission lines are accessible? The DEIS itself states that wind energy is the fastest-growing renewable energy source in the WORLD. Wind energy is a clean energy source that has been endorsed by Senators Max Baucus and Conrad Burns, Representative Denny Rehberg and President Bush publicly and through policy guidance to the Departments of Energy and Agriculture. Advances in wind energy design have been dramatic and have created tremendous efficiencies, reduced noise pollution and reduction of adverse impacts on wildlife.

The DOE states Montana has wind resources consistent with utility-scale production with good-to-excellent wind sources in the eastern two-thirds of Montana (where SME has a large ‘footprint’), so Why

Does SME not exploit that could be built as load demand increases and provide rural landowners, farmers and ranches an opportunity to revitalize their communities as expressed in the USDA and DOE’s own ‘Rural Renaissance” vision? Russ Doty, himself a Yellowstone Electric co-op member and CEO of ‘New World Windpower.’ says co-ops could have their windmills paid for in 15 years or less and rebates returned to benefit co-op patrons.

Rural electric co-ops have the advantage in getting interest-free backed bonds for wind-power production and costs to co-ops get down to $3.8 cents per KWH, less than the 250MW HGS plant when considering future CO2 sequestration costs (1- 5 cents per KWH) is figured in.

Why does SME not take advantage of a renewable energy source (wind farms are ‘scalable’ and ideal to meet demand loads balanced with funding availability, which is more likely through DOE/USDA joint efforts in the future, and can be built in a matter of MONTHS, not years like coal plants), as SME itself states that within its own service area the potential to support large-scale wind farms is

Thirty percent?

Why does SME not consider the findings of DOE that it is technically feasible to develop wind farms (that’s plural, implying more and/or several locations and sizes depending on transmission links and siting) within the general SME service area? DOE’s ‘Windpowering America’ has been introduced through Rural America and even in Cascade County itself, according to county commissioner Peggy Beltrone. WPA is committed to providing ‘stakeholders’ effective information on large-scale wind energy projects, particularly for utilities, elected officials who lack experience in the field.

How did SME determine its 250MW ‘windfarm’ footprint’ – which is far too high – when compared to the Judith Gap Wind Farm, which has 90 turbines providing 135MW and covers 14,000 acres or nine square miles and is operational?

Any serious wind energy advocate knows that a 250MW ‘wind farm’ would not be practical as it cannot meet peak and load demands, so why did SME even speculate on a 205MW size wind farm, vs. a more practical approach like the proven 135MW Judith Gap wind farm the DEIS mentions extensively?

Why doesn’t the DEIS even mention the direct economic contribution to landowners, such as wind turbine lease payments that range from $2 – 4,000 dollars per turbine? According to HYPERLINK "http://www.nationalwind.org" www.nationalwind.org, rural land owners, particularly farmers and ranchers hit hard by our lingering drought, could reap the greatest benefits from wind energy development, AND also local county governments through property taxes.

Instead of investing in coal-burning generation plants, why doesn’t the City of Great Falls promote the domestic manufacture of wind turbine components and related equipment like the civic and economic leaders with vision as Fargo, ND is doing?

Why is Great Falls and Montana ‘sleeping at the switch,’ letting others build components while the Great Falls Development Authority could be actively involved in this, to take the lead in Montana (116,000 MW potential!) and be the LEADER, and instead provide dozens of high-paying jobs to build the wind turbines and also economic benefit for county citizens to operate and maintain the wind turbines? Paris Gibson helped develop the ‘Electric City’ and the city should rise to the challenge and meet it’s destiny with the wind and even reclaim its own dams, ‘stolen’ away through deregulation, greed and arrogance.

How will SME incorporate wind energy if the industrial park site would be the option decided upon?

How will SME obtain financing for the four wind turbines at the Salem HGS site? This will be addressed again later.

Why wasn’t the potential or cost impact percentage of a carbon tax ($11 per ton according to Northwest Energy) applied in the cost analysis of all the various energy sources, which would have given renewable energy a greater positive effect? The Northwest Power and Conservation Council estimated a 67% probability of a carbon tax being imposed and could be as high as $30 per ton of C02 by 2016. This makes the HGS costs less competitive with renewables and not including a potential carbon tax discriminates against renewable energy, the very energy sources embraced by the very agencies that will make the final loan recommendations regarding the HGS plant.

It is also understand that all generation sources need to be ‘backed’ by other resources, something Governor Schweitzer believed wind-power could do if distributed around the state to ‘back’ other wind sites when winds are blowing or not.

2.1.3.2 ‘Solar Energy.’ The DEIS does accurately present the expensive nature of solar energy, but the technology (particularly with nanotechnology) is improving rapidly, but as demand increases, the cost will continue to drop, particularly when cost of transmission is considered and the benefits of local, ‘customized’ load demands can be met. If the DOE had truly been ‘on the job’, we’d be way farther ahead than now and not in this predicament, but we can thank our ‘addiction to oil’ for that

and letting the oil companies suppress research and development when they should have been investing in that all along.

2.1.3.3 ‘Hydroelectricity.’ Instead of chasing the ‘coal train’, why doesn’t the City of Great Falls expend its energy to REGAIN its heritage, the dams on the Missouri River that Paris Gibson, the first mayor, had the vision to develop as clean, renewable energy which became the city’s namesake, the ‘Electric City?’

Why doesn’t SME – whose co-op members advocated and helped promote the disastrous deregulation of 1997 – and City of Great Falls collaborate to buy the existing dams from PPL?

2.1.4.1 ‘Biomass.’ Why doesn’t SME – whose co-ops are in farm country – exploit the opportunity to help promote the ‘Rural Renaissance’ and use the seeds, grains, crop residue and waste products typically produced in farm and ranch country, and start small at local levels to complement wind turbines, to help reduce

load needs in their service area? Choteau County is working on this

concept, a wind/biomass ‘closed’ system that would constant power up to 3MW for Fort Benton and county facilities. Commissioner Jim O’Hara is seeking funding from the federal government to that end. Wind turbines and biomass can be decentralized to reduce transport costs where feasible, be built in months as opposed to YEARS for a large, centralized coal plant. Decentralizing these operations helps not only economically, but reduces air emission effects.

2.1.5 ‘Non-Renewable Combustible Energy Resources.’ In regards to Table 2-6, how does SME arrive at the questionable ’42.8’ figure for an Integrated Gasification Combined Cycle (IGCC) plant, when which compared to Circulating Fluidized Bed (CFB) technology, is 42% higher than typical estimates of 20-30 percent, NOT 42%?

Why is SME only doing ‘selective’ research and marginalized IGCC technology, which the DOE has vigorously promoted and funded, and now even considered for further examination by the MT DEQ? The DOE also states IGCC may be one of the best ways to produce clean-burning hydrogen for cars and fuels cell and could offer better sequestering of C02 at lower cost and reducing greenhouse gas (GHG) emissions.

How does SME rationalize its belief that IGCC is ‘experimental,’ despite the fact that the Environmental Protection Agency strongly affirms that IGC uses 40% less water and has higher coal burning efficiency and is cost competitive?

Why can’t SME be flexible enough to realize that other states are becoming LEADERS in IGCC, particularly Colorado, where XCEL Energy is starting work on a 500 million dollar IGCC plant that will

Provide 300MW or more of energy, and has SME looked at what Bison Electric in North Dakota is doing to build an IGCC plant there?

When will ECP consult is prospective investors on what the financial community considers the ‘best’ coal-burning technology, which according to Standard & Poors, IGCC receives high marks? BearStearns, the firm the ECP intends to work with, has savvy and experienced energy investors who have greater depth and much more working knowledge than ECP will ever know, and surely understand that

IGCC has more than 385 units operating worldwide, not including fast paced development of IGCC now appearing in western states like North Dakota and Colorado.

Why has Governor Brian Schweitzer endorsed this CFB coal plant while other governors (Idaho’s governor and legislature have moratorium on coal plant production) are endorsing IGCC, like the President’s brother, Governor Jeb Bush of Florida who was pleased with IGCC technology, a technology that can still provide Great Falls citizens construction jobs and long-term jobs in the same numbers and even more than a traditional CFB coal plant model?

Why didn’t SME approach the Department of Energy and take advantage of the Clean Coal Power Initiative initiated by President Bush in 2002, supported by 10 billion dollars over a ten year period? EPA Secretary Colleen M. Castille also endorsed IGCC and its hydrogen production benefits and said, “by developing cleaner energy that uses a plentiful and economical domestic resource, we are ensuring energy independence and reducing pollution to protect the environment.”

2.1.6 ‘Other Coal-Fired Plant Site.’ It appears that the most crucial criteria was large quantities of water necessary for the CFB process, versus IGCC requiring 40% less according to the EPA and DOE.

2.1.6.1 ‘Decker Site.’ What criteria established that the Decker Site was more ‘expensive?

Was the ‘expensive’ nature of the Decker site related to prices expected by landowners to sell their land to SME?

How much less water did ‘junior users’ on the Tongue River go without and what actual percentage of river flow would be diverted to a CFB plant?

What is the estimated cost of 80 miles of new transmission lines and could SME apply for separate loans to build those lines under the REA?

2.1.6.2 ‘Hysham Site.’ Again, what criteria established that the Hysham Site was more expensive?

Was the ‘expensive ‘nature of the Decker site related to prices expected by landowners to sell their land to SME?

How much water in the Yellowstone River is already allocated and what percent of river flow would be diverted to the coal plant? It seems SME knows exactly what would be diverted from the Missouri River but not from these other tributaries?

2.1.6.3 ‘Nelson Creek.’ Again, what criteria established that the ‘Nelson Creek’ Site was more expensive?

Was the ‘expensive’ nature of the Nelson Creek Site related to prices expected by landowners to sell their land to SME?

Since Fort Peck and the Corps of Engineers have filed water rights claims, what consideration has been given for ‘downstream’ states like Missouri and Kansas who might petition the federal government to not allow any federal funding to any project on the Missouri River that might reduce downstream flow, vital to their own states recreation, commerce, barge traffic and irrigation?

2.1.7.2 ‘Discharging Wastewater into the Missouri River.’ How could any rational person or organization even remotely consider discharging wastewater into our majestic Missouri River without moral reservation?

2.1.8 ‘Conclusion.’ Why does the DEIS and SME ‘discriminate’ and ‘marginalize’ the merits of renewable energy, which could be built

in ‘scalable’ modules and in months, far ahead of when SME would lose its contracts with BPA?

Why does SME not truly reflect the ‘real numbers’ offered by the Judith Gap Wind Farm as to real costs in Table 2-8, where it doesn’t reflect the energy contract for $38 per MWH (with ‘firming cost included) or actual costs?

How did SME establish $50.60 MWH, whereas the real numbers (actually endorsed by Governor Schweitzer) from a world-class and proven wind resource like Judith Gap is actually $31.60, and adding $7.50 for firming costs brings the cost to $$39.10, much less than what Table 2-2 misrepresents, and doesn’t account at all for carbon tax and sequestration costs?

As asked before, How did SME overestimate a IGCC plant 42% over CFB cost, where the numbers are in the range of 20-30% more capital cost than a traditional coal plant, and the table doesn’t account for the EXCEL Energy plant cost projections being built in Colorado, where A 300MW ‘plus’ plant is to be built for 500 million dollars?

How did SME include the cost of a carbon tax and sequestration costs into the levelized costs, or if not, why did SME exclude these costs that are expected to be established in the future?

What rationale is in Table 2-9 (comparison of alternative power plants that meet purpose and need), that ‘claims’ IGCC is not worthy based on ‘cost-effective’ (which is now suspect, considering DOE endorsement and ‘real world’ IGCC construction in the West) and ‘high reliability.’

Wind energy advocates readily admit that wind alone couldn’t provide 250MW entirely, but it seems to indicate flawed comparison analysis if it was disqualified solely on not meeting baseload operation, which no serious stakeholder would consider, so why did SME again not generate a ‘fresh’ alternative to exploit the advantages with other alternatives to blend in?

Why did SME dismiss wind again, especially as the criteria admitted that ‘yes’ it can provide 250MW by 2009, which technically speaking, wind farms can be established in MONTHS as opposed to years for a coal plant?

2.2.2.2 ‘Operation at HGS-Salem.’ Would SME ever purchase coal locally in the old coal-mining area of Stockett, Sand Coulee and Tracy, particularly when an SME official ‘speculated’ on the possibility?

How much greenhouse gas emissions will result from vehicles having to deliver limestone to the HGS-Salem site from Limestone Hills, south of Helena in Townsend?

How does SME rationalize it’s ‘timid’ approach to integrating wind energy into its power supply portfolio while literally ‘surrounded’ by two of the state’s premier and proven (that could SME engineers ‘on-the ground experience NOW) wind farms on Gore Hill and at Judith Gap? SME itself stated that 30% of its own operating area has the real potential to harness wind energy!

‘Wind Turbines.’ Where will SME seek funding for its ‘greenpower’ wind turbines, since they are not – ironically – part of the RD application?

Wind cannot realistically supply 250MW, but it could amounts that could be scaled up, depending on financing opportunities, land use

Agreements, wind site potential, so why wasn’t Wind Energy

Encouraged more, but not on such a ‘tiny’ scale with four turbines?

How does the one hundred acres needed for four 1.5MW wind turbines ‘square up’ with the earlier estimate of 46,000 acres for 166 potential wind turbines (a rough estimate reveals that at 100 acres per four turbines, the result would be 4-5,000 acres or somewhat higher for spacing and efficiency, but nowhere near 46,000 acres)?

Why does Table 2-12 not reflect ‘real world’ wind costs at Judith Gap, and seeks to ‘alarm’ the reader by ‘highlighting’ $66.24 MWH, which was effectively explained earlier that the ‘firming’ cost of $7.50 added to $31.60 was accepted by Northwest Energy in a real contract?

If the Industrial Park site is the final site selected, how will SME integrate wind energy (since Industrial Park has no wind turbines) into its power supply portfolio as set by the Montana legislature?

How and who would SME establish a business contract to buy wind energy if it couldn’t produce it itself, a true irony?

How can SME seriously complain about detailed analysis required, extensive modeling, etc., while they’ve been ‘sitting on their hands’ while Bob Quinn and private investors got it DONE in Judith Gap as did United Materials in Great Falls on Gore Hill? Again, SME admits 30% of its area has good wind energy potential, so what’s not to like?

2.2.2.4 ‘Connected Actions.’ How are the ‘connected’ actions figured into the final cost estimates, and has the increased costs of fuel been considered in ALL transportation costs, whether diesel fuel for trucks hauling limestone, or locomotives hauling coal into HGS?

What is the actual HGS-Salem plant cost considering dramatic fuel cost increases and other commodities associated with HGS-Salem?


Why are the environmental impacts of transporting coal to any plant not factored into the Proposed Action?

2.2.3 ‘Alternative Site – Industrial Park Site.’ As with the HGS-Salem site, how many LOCAL workers would actually be employed of the 300-400 on the site at any one time, up to 550?

Why haven’t the locations of the transmission lines, water and wastewater lines been determined?

Where will fly and bed ash be sent to for disposal, since the county landfill is not an option?

What complications might occur with the proposed rail spur and existing rail lines leading to the malting plant (IMC), since there is an outstanding dispute on cost share of the IMC rail spur with the City of Great Falls?

3.1 ‘Soils, Topography, and Geology’ What is the USDA going to do about having baseline studies done on all soils surrounding the proposed plant, so as to determine possible levels of contamination from the CFB coal plant, no matter what site?

When will landowners adjacent to the either site be contacted to coordinate soil analysis and baseline studies to confirm or deny long-term effects of any possible airborne contamination?

3.2.1 ‘Missouri River.’ What consideration has been given to the over 1.7 billion gallons that will be diverted and ‘squandered’ to either coal plant options, especially when we are still in the ‘lingering’ grip of a national drought, and water is a precious asset, vital to recreation, irrigation (also downstream), commercial/residential needs and in particular, future value-added biomass enterprises that also need water?

What has SME done to ‘relook’ IGCC technology, especially as it uses 40% less water than traditional methods?

3.2.4 ‘Surface Water Quality.’ What provisions have been made for not only soil contamination monitoring, but for surface water, particularly as airborne contaminants could be landing on soil and surface water downwind and downstream of either site?

3.2.5 ‘Water Rights.’ What actual contracts have been signed by SME with the City of Great Falls and where is the actual contract for the public to examine?

3.3 ‘Air Quality.’ Although the DEQ and SME may agree that SME meets the ‘letter of the law,’ how does SME justify polluting the environment with 40 pounds of mercury, over three million tons of CO2, and increasing greenhouse gas by 7.5% in Montana by this plant alone?

How will SME compensate farmers for mercury contamination if ever detected, assuming the USDA – the farmer’s friend – is going to fulfill its charter and do soil analysis and baseline studies?

Why does SME ‘stay the course’ without taking a deeper look into using IGCC, which still contributes GHG, but less so and has greater potential for sequestration?

How will SME be a responsible organization to insure ‘New Source Review’ will not be abused or compromised as seen in the eastern US where coal plants lobbied to have regulations dropped or weakened?

3.3.4 ‘Air Quality in Class I Areas.’ Why does the federal government and state of Montana appear willing to ‘lower our standards’ and diminish Montana’s trademark ‘Big Sky’ (and clean sky) reputation, all for one coal plant while we Have wind energy potential up to 116,000 MW?

3.3.5 ‘Mercury in the Environment.’ What measures will be established to monitor air, water and soil for mercury contamination, to include testing of humans and fish?

3.3.6 ‘Global Climate Change.’ How will SME contribute to Governor Schweitzer’s initiative to reduce GHG and show leadership in considering IGCC technology that can incorporate C02 sequestration?

How can the USDA consider funding a coal plant that directly contributes to GHG, which in turn contributes to climate change which has directly impacted farmers suffering in severe droughts, and helping farmers is what the USDA is about isn’t it?

Who will show leadership by setting the example and will it be SME and Governor Schweitzer, and will they reconsider IGCC as a better coal-burning technology that will reduce pollutants, CO, and CO2

Sequestration?

3.5.1 ‘Noise Terminology.’ Where does the DEIS specifically state the actual noise decibel levels for the plant at either site?

Where is data showing the more ‘silent’ nature of wind turbines, which do make some noise, but hardly that of an old coal plant, complete with railcar noise and industrial processes.

3.6 ‘Recreation.’ As many Montanans and visitors appreciate, how can SME help preserve our clean vistas, fishing for ‘healthy’ fish and

ability to enjoy these unique treasures?

How many visitors would a coal plant get versus other communities that have windmill and derive tourists from that, as that situation has been observed in Judith Gap?

3.7.2 ‘Inventory Results (Cultural Resources)’ How could the SME planners ever consider placing any portion with or near the Great Falls Portage National Historic Landmark and how does that reflect upon initial site selection screening criteria and consideration of viewshed?

How could the HGS-Salem site compromise future development of the portage route if that would be considered for living history tours and field trips?

How can the USDA consider funding a project that will encroach upon its own area of jurisdiction, via the Forest Service, which operates the Lewis and Clark National Historic Trail Interpretive Center?

How will electrical transmission and water lines be ‘mitigated’ as they physical cross directly through the portage route?

What response does SME have to the Montana Preservation Alliance that has identified the portage route as among one of Montana’s most endangered historic places because of the HGS-Salem proximity, and stated that “this massive intrusion on one of the country’s most important Lewis and Clark heritage sites would be a devastating loss for all Americans, but especially the many local groups who worked recently protect the site from development?”

How can the federal government, through the USDA RUS or DOE, even consider funding a project that compromises a ‘national treasure’ such as the Lewis and Clark portage route?

3.8.2 ‘Salem Site (Visual Resources)’ What kind of trees does SME propose to install near their plant to mitigate the HGS-Salem plant’s ‘visual’ footprint on the beautiful Highwood Mountain landscape?

3.10.1 ‘Farmland’ What has been done to consider the impact of airborne contamination for the plant at either site, because neighborhood farms are very concerned, particularly organic farmers and ranchers?

3.10.2 ‘Zoning.’ What level of cooperation and coordination has been achieved between Cascade County and the City of Great Falls planning boards, since they were recently dissolved?

What are the jurisdictional, legal, and property tax issues that must be dealt with, since the City of Great Falls and Cascade County appear to be ‘salivating’ over the prospects, yet the County and State of Montana continue to tolerate protested taxes from another utility, PPL, to the amount of 13 million dollars?

What provisions will be emplaced to discourage SME and ECP from EVER protesting its taxes, as PPL has now shown they can protest

With impunity?

What liabilities would Cascade County assume if legal action were forthcoming on any issue, since the HGS-Salem site still physically is outside the city limits?

To what level is the City Planning/Zoning Board involved with annexing the site, and how will the public be provided the opportunity to comment on any proposed annexation?

3.10.4 ‘Industrial Park Site.’ What lessons have been learned from the International Malting Company (IMC), since they are in close proximity to the site and how will the issue of rail spurs be resolved, since there is a dispute now on who will pay for IMC’s rail spur?

3.11 ‘Waste Management.’ What landfills have been identified with county approval for the Industrial Park site option?

3.12 ‘Human Health and Safety.’ What will the State of Montana do to monitor the health and safety of citizens downwind of the HGS-Salem site, particularly residents of Fort Benton and Big Sandy, as the EPA examined the old mining site in the town of Neihert to assess health and safety of those residents?

What legal actions could the City of Great Falls AND Cascade County be exposed to and liable for if any health and safety problems that could be linked to the operation of either plant site?

3.13.1 ‘Cascade County and Great Falls (socioeconomic environment).’

As indicated on page 3-106, coal fields near Great Falls were mined for use in industry, so would that ever be considered again to provide

Coal to either CFB coal plant site, if the cost of rail transportation (and carbon taxes) were to present local coal as more economical for SME?

What kind of legacy and respect for Paris Gibson’s unique vision (the City of Great Falls was considered one of the best planned and robust urban areas in the late 19^th Century, the ‘Minneapolis’ of the Great Plains) of harnessing natural renewable energy has been left for current and future generations, in particular the TRAVESTY of losing control of the people’s heritage and connection with the Missouri River dams, now owned by PPL, a poor corporate citizen that has protested taxes for six years, denying Cascade County and school districts of vital educational funding?

3.13.3 ‘Cascade County and Great Falls – Economic Data.’ Despite promises and ‘deals’ arranged with local union representatives, how many jobs will ‘truly’ be offered to local unions and contractors and doesn’t anybody recall those types of promises when contracts at Malmstrom Air Force Base were let out, and in particular the IMC plant, where foreign workers were imported?

If SME were to consider a wind farm option instead of a coal plant, how many construction and permanent jobs might that create and also projected property taxes and financial benefits for landowners?

What amount of money is being offered to LANDOWNERS for either site, particularly when it will be PUBLIC funds provided via the USDA RUS and ECP, and who will actually ‘own the property deed,’ SME or ECP?

4.3.1 ‘No Action Alternative.’ Where are the facts or detailed assumptions of how SME would impact other communities and generating sites?

4.3.3.1 ‘Construction (Alternative Site-Industrial Park Site) Why will an ash disposal site NOT be constructed on the site and cannot a site be built there despite space constraints?

How will new track and railbeds be integrated with neighboring facilities like IMC, with is still disputing the cost of their rail spur, and how could this effect other commercial developments in the industrial

park being planned?

Where will an appropriate be found if the Industrial Park Site cannot establish an on-site ash monofill and why hasn’t the level of planning and foresight been addressed?

4.4.1 ‘No Action Alternative( Water Resources).’ What data can SME present to show the impact of using water resources elsewhere?

4.4.2.2 ‘Operations (Proposed Action).’ Considering the fact that Montana and the West is gripped by lingering drought conditions, How can the federal government, via the USDA RUS, seriously loan money to this project that would divert and ‘squander’ water – 1.7 Billion gallons a year from the Missouri River - away from irrigation, recreation, future residential and commercial needs, and especially potential value-added renewable energy enterprises like biomass, such bio-diesel and cellulosic ethanol, which gallon for gallon adds more value than in coal-fired production, and especially as the DOE and USDA desire to use renewables for a ‘Rural American Renaissance?’

How would SME reduce wastewater discharges into the city’s treatment facility if it ever exceeded the masimum allowable industrial loading numbers for heavy metals?

What is the possibility of mercury residue being processed through the city’s treatment facility?

4.4.4 ‘Conclusion.’ Since the overall impact on water resources for power plant operations is adverse with the potential for them to become significant, ‘How’ can this plant be justified, and doesn’t that make IGCC technology more feasible since it uses 40% less water?

4.5.2.2.1 ‘Emissions and Compliances with Regulatory Standards.’ What regulatory oversight does the EPA have regarding New Source Review, especially since it has been tampered with by Congress under the influence of lobbyists?

4.5.2.2.4 ‘Mercury Emissions.’ What levels of mercury could be expected in the type of coal that was mined near Great Falls, especially since SME ‘speculated’ that mining local coal could be a ‘remote’ possibility?

4.5.2.2.5 ‘Greenhouse Gas Emissions.’ How can the DEQ seriously consider allowing any permits, particularly air quality permits, when the Governor of Montana has convened a Clmate Change Advisory Committee (CCAC) and will DEQ wait for the findings and recommendations to the Governor before any permits are authorized?

How can Tim Gregori, CEO of SME, be on the Governor’s CCAC, a body which has a direct impact on the decision-making process of Montana’s executive branch and subordinate departments such as the DEQ, and doesn’t a member of SME on the CCAC present a conflict of interest?

How will the economic impact of carbon taxes and sequestration costs be factored into the ‘cost/benefit’ analysis, since SME cannot simply ‘wish’ that issue away since serious federal/state legislation has been proposed as measures to reduce GHG?

What are the actual costs and type of trees that can ‘absorb’ 1,602 pounds of CO2 and when will SME have the plan for urban reforestation, since scientists are now realizing that our forests are becoming more of an issue concerning C02 just as much as the Amazon Rain Forest?

4.6.1 ‘No Action Alternative (Biological Resources).’ What are the detailed estimates of the effect on biology elsewhere?

What has SME determined to be the best practice to reduce impacts on wildlife if it decides to consider a larger wind energy generation site?

4.12.2.1 ‘Construction (Farmland and Land Use).’ What is the accurate process for land annexation, since the checklist on page 4-103 is in error, since the Great Falls City-County Planning Board was DISSOLVED, thereby rendering the Jan 2000 date inaccurate?

4.15 ‘No Action Alternative (Socioeconomic Environment).’ How and why does SME present a specious argument that ‘senior citizens will freeze and the lights go out’, and why hasn’t SME approached other electric co-ops to negotiate contracts as possible option?

4.15.2.1 ‘Construction (Proposed Action).’ What construction costs have increased and is the 515 million dollar estimate accurate, especially for labor costs, fuel costs and other commodities?

How many construction and operator jobs are created by the four wind turbines at the HGS-Salem site and what economic benefit will that offer?

By comparison, what temporary and permanent jobs would a IGCC coal-fired plant offered, and what about jobs generated from the IGCC process associated with by-products?

How many easements has SME actually negotiated with local landowners?

Why is the the City of Great Falls and Cascade County ‘lusting’ for property taxes while the State of Montana is slow to deal with

PPL, another utility, which is protesting 13 million dollars?

The attraction of 65 well-paying jobs, plus the hundreds of temporary construction jobs for years is very appealing, but what is the long-term consequences socioeconomic effects if tourists and prospective residents and businesses bypass Great Falls due to the

‘negative’ perception of a smoke-filled ‘Big Sky’ and ‘scarred’ landscape, and has that been impact been quantified?

4.16 Environmental Justice/Protection of Children.’ In regards to children (only in the aspect of educational funding or neglect), would SME ever protest property taxes, denying school districts vital funds and indirectly effecting the quality of education for our children?

4.17 ‘Unavoidable Adverse Impacts.’ Why doesn’t SME consider IGCC

as a more effective means to use a vital natural resource, our water, and it would be more economical and socially responsible?

How can the federal government (or any investors, private or government) consider this a sound investment, since the DEIS presents in its abstract that there is only ONE adverse impact, that on the Lewis and Clark portage route, when there are eleven adverse impacts out of 14 key areas examine, an adversity rate of 78%?

4.18 Irreversible and Irretrievable Commitments of Resources.’ How would SME mitigate the loss and degradation of floodplain and wetland areas?

How would SME and the State of Montana morally justify to the Nation, particularly downstream states, that it is squandering water to promote greenhouse gas emissions?

4.19 ‘Short-Term, Long-Term Productivity, etc.’ What impact would occur if the either CFB coal plant site were to be shutdown for regulatory non-compliance or for any other reasons?

What comprehensive (socioeconomic, environmental, energy, etc.) ‘cost benefit’ analysis has been prepared to provide some sound conclusions and recommendations, factoring in GHG, carbon tax, sequestration costs, and lost opportunities to pursue with renewable energy enterprises, not only in operating them, but actually BUILDING the components?

5.2.1 ‘Past and Present Actions and Trends’ (Cumulative Impacts) What impact will Governor Schweitzer’s CCAC have on future economic and energy development?

Would the Great Falls Industrial Park Complex be a viable location to develop renewable energy, which everybody likes, but when it comes down to it the instant gratification and lure of ‘jobs and taxes’ overtake the real dilemma of finding clean and affordable energy?

What could happen to our forests, in regards to acid precipitation, if SME ‘leads the way’ with CFB technology, and how does that look to the rest of the nation and the world, who will say if SME and the USA

Can get by with doing it, what’s wrong with Red China doing the same with over a billion people, ready to vigorously embrace their

Own ‘industrial revolution’ and contribute more GHG?

Global climate change and drought is real and accepted by a majority of scientists, so how will SME consider these factors in the near and long-term?

5.2.2 ‘Reasonably Foreseeable Future Actions and Trends.’ What would the effect of a proposed transmission line from Canada to Great Falls have on the energy grid and SME?

How will SME deal with water diversion and depletion, particularly when American Indian Tribes in the Missouri River basin begin to exercise their Tribal water rights, and wouldn’t that make IGCC more practical as it uses 40% less water?

Wind Energy is the fastest growing renewable energy source and improvements have been made towards continued reduction of wildlife mortality, so why doesn’t SME see the this future trend and exploit it, as 30% of their own operations area has wind energy potential?

Mercury emission regulations are here to stay, and will become more severe, so why doesn’t SME reconsider using IGCC, and although initially slight more expensive in capital costs, those would be regained over the long-term?

5.3 ‘No Action Alternative’ Why is ‘impossible’ to isolate and quantify SME’s contribution to cumulative impacts and can they not at least provide estimates, i.e. water diversions, air pollutants, Megawatts diverted, etc?

5.4 ‘Proposed Action, HGS-Salem.’ How can a moderate socioeconomic benefit and virtually ‘outweigh’ all the other adverse and potentially significant impacts regarding water, air, human health and safety, cultural and visual resources, not to mention the ‘stigma’ Great Falls and Montana will incur when we ‘degrade’ our reputation, and lust for the Big ‘dirty’ Sky, and will we be the ‘Last, Best Place’ to ‘Live, Right, Here’ at the Great Falls Chamber of Commerce touts?

5.5 ‘Alternative Site – Industrial Park’ If the HGS-Salem site was disqualified, how would SME mitigate the noise and air pollution created by coal trains entering the city limits of Great Falls?

Where will the ash monofill be established and will that landfill require permits and by what agencies?

As with the HGS-Salem site, how can SME just the moderate benefit of ‘instant gratification’ via jobs and taxes, and how does that moderate socioeconomic benefit outweigh the adverse impacts to water, air (what IS the real impact of air pollution right in Great Falls proper?), health and safety, and is will SME’s ‘Stack’ become our new surrogate for the ‘Big Stack’ we lost years ago?

4. Summary. Renewable energy is the ‘path to take’ and our civilization cannot remain timid, and at least considering IGCC could establish an effective balance and ‘harmony’ as we transition from fossil fuels to renewables and hydrogen possibilities. I offer the inspiring words of Teddy Roosevelt, one of most visionary and greatest Presidents, who said

“Believe Passionately, Act Boldy, and Proceed Strategically.” Let us hope we as Americans and Montanans find the best way to clean and affordable energy, as the consequences are too severe not to and ‘good planets are hard to find.’

Sincerely,

Richard D. Liebert

Citizen, Veteran, Family Farmer