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

The following are my comments on the DEIS for the proposed Highwood Generating Plant.

1.  The range of alternatives in this DEIS is too limited for the scale and environmental effects of this project.  The applicants do not consider alternative coal burning technologies and cannot provide the public with a useful effects statement on such a narrow range of alternatives.

2.  Thus, the No action alternative is the only feasible alternative you should consider viable.  If a further analysis on a full range of viable alternatives including  IGCC technology (this document dismisses IGCC technology prematurely and without adequate justification for it’s dismissal) can be made for the final EIS, then I would believe the SME would have provided a workable document for public review.  As far as I’m concerned a Nuclear alternative should be considered as well given the attempt by the applicant to downplay any viable  alternatives except a conventional coal burning and obsolete technology. 

3.  Given current evidence of global warming, any permitting agency willing to permit the proposed action at the minimum requirements for permit regulations is working contradictory to public need and well being.  Any permit for a coal fired generating facility at a time in human history when overwhelming evidence exists that greenhouse gas is detrimentally effecting world climate and life on earth and the effects of other pollutants from such a coal burning plant are known to cause detrimental effects to human health  (e.g., mercury poisoning, primary and secondary affects) should be as stringent as allowable by law or a no action alternative must be selected.   

4.  I cannot find where the applicant has done extensive scoping and alternative review with the primary downwind communities in Montana and Canada.  This would include extensive discussions with the Indian Nation residing at Rocky Boy Reservation.   The Final EIS should include discussion and documentation of the public scoping and mitigation incorporated into the plan to give priority to the primary downwind recipients of the pollutants from the proposed plant.  To suggest that mercury, for example is carried long distances before it ‘falls out’ into the environment of someone else’s backyard is arbitrary and uninformed work prior to release of the DEIS.

I am opposed to the proposed project as described and analyzed in this DEIS.  Again, the no action alternative is the only viable alternative discussed in this plan as it is now presented to the public.

Sincerely,

Ronald A. Crete

1523 4th Ave. North

Great Falls, MT   59401