August 29, 2006
Richard Fristik
USDA Rural Development, Utilities Programs
1400 Independence Ave. SW
Mail Stop 1571, Room 2237
Washington D.C. 22050-1571
Kathleen Johnson
Montana Department of Environmental Quality
& the Air Resources Management Bureau
P. O. Box 200901
Helena, MT 59620-0901
RE: Comments Air quality Permit #3423-00
AFS#: 030-013-0038
Proposed Highwood Generating Station
Proposed Highwood Generating Station DEIS
Dear DEQ-ARMB,
I'm writing to express my concerns about the above.
I have lived in Great Falls since 1972 at 615 Third
Avenue North and have enjoyed the benefits of the relatively clean environment
here. I oppose the DEQ issuing the
above air quality Permit.
Furthermore, I believe the DEIS is flawed, that there should be no ROD
issued until the DEIS has been corrected, and finally I oppose the REA, of the
US Dept of Agriculture providing guarantees, loans, and moneys for the
development of the Highwood station.
My reasons are as follows:
1. NEPA
requires the providing of a range of alternatives and analysis of each in the
EIS sufficient for the deciders to make a substantive determination of whether
the project should go forward as proposed. The range of alternatives considered in the DEIS as
currently drafted is inadequate for the federal deciders to issue a ROD which
would not be "arbitrary and capricious." The following sub items are
needed to be considered under the DEIS:
a. The
economic viability of the project has not been established nor has it been
discussed in the DEIS. Clearly SME
and the City of Great Falls must have a business plan, but they have not given
that out to the public. How can
the DEIS analyze the economic viability of the alternatives without being
provided the business plan? How
can the DOA decide on a plan to guarantee a project without allowing the public
to review the business plan for the various alternatives? Questions such as cost of coal,
its cost of transport, costs associated with a carbon emission tax, all need to
be set out and compared with other alternatives. Global warming is real and the
costs associated with a carbon tax have not been considered by plant
developers. It is my understanding
that other new coal plants being proposed around the country have considered
such costs. It is irresponsible to
approve building the plant before CO2 discharge costs are considered.
b. The DEIS
does not provide a monitoring plan to validate and address the effects of
airborne pollutants on local surface waters and aquatic organisms. To begin with, background monitoring
would be needed to establish baseline levels of mercury and other pollutants in
strategic sampling locations (streams or ponds) within the primary fall-out
zone of the plant's emissions.
Fish from resident (non-migratory) populations should also be sampled to
determine potential bio-concentration of mercury as it moves up trophic
levels. Control sites could be
selected to help differentiate between the proposed generating station's
effects and other major pollution sources. Without an aquatic monitoring plan, it will be impossible to
know the ultimate fate of released toxins and the associated human health risk
to downwind Montana communities from surface water contamination.
c.
Studies from Steubenville, PA by the federal Environmental Protection
Agency show that 70% of Mercury depositions occur close to the plant. Mercury is a known health risk not only
to developing fetuses and babies, but to middle-aged men as well, increasing
their risk of heart attacks. I had
a heart attack about five years ago and do not need to have the additional risk
caused by this plant. I do not see
where in the DEIS the mercury depositions from the plant are being measured as
effects the human population centers and compared with other alternatives such
as wind, hydro, conservation, solar. Wind normally blows west to east in Great
Falls, but it can blow from any direction. As part of the air quality permit and the alternatives
under the DEIS, potential deposition of mercury in Great Falls City proper when
the wind blows from the North and/or East needs to be studied and then
addressed.
d. The
cumulative effects of the Great Falls' refinery's air discharges, the new
malting plant, 10th Avenue South vehicular traffic, the west bank linseed oil
plant, and Malmstrom coal plant (formerly they were burning oil) need to be
considered in this application and in the DEIS in a comprehensive way with
appropriate studies and actual test measurements so that we will know what is
actually happening here.
e. The
effects of particulate matter, acid rain, mercury deposition under a range of
alternatives as it affects area farmland needs to be considered and compared
under the various alternatives. This area is known as the Golden Triangle. The standard for measuring the effect
of soil contamination in the DEIS is not sufficient to measure the effects on
area farmland. The DEIS seems to
only refer to the acreage upon which the plant sits. Saying that the area farmland is not prime farmland is
clearly wrong. There are no tests
showing baseline levels on area farmland currently present for pollution from
the plant. It is not sufficient to
say that airborne contaminants will not have a significant impact on area
farmland without having a standard, a baseline study and a method of
monitoring.
f. The
effect of acid rain on area forests (the Highwoods, the Little Belts, the Rocky
Mountain Front) under the alternatives has not been analyzed. Furthermore, if the forests are
diminished due to acid rain, what will be the effect on the Madison aquifer,
which rises in the Little Belts.
g.
Areas in the little Belts (particularly Pilgrim Creek, middle fork of
the Judith) which may be considered for wilderness designation are not
considered in the DEIS.
Furthermore, the impact on the visual air as seen from the Rocky
Mountain Front (when viewed from the Bob Marshall Wilderness or the Scapegoat
Wilderness) at the top of the mountains looking towards Great Falls which are
more that 33 miles may still show the pollution of the plant visually. The DEIS
should consider the effect of the proposed plant on the view shed of the Rocky
Mountain Front.
h. The
USDA in making its decision cannot rely on decisions made by the MT DEQ as
being correct under Montana law for the reasons set forth in 2 below.
2. Even
though the DEQ may be meeting its MEPA requirements by this DEIS when applying
national air quality standards and then using MEPA to determine mitigation
measures, this does not mean that the state is meeting its requirement under MT
state constitution to provide its citizens with a clean and healthful
environment. In fact the opposite
is true for the following reasons:
a.
Granting an air quality permit before an EIS has been completed and the
public given the opportunity to comment thereon makes a mockery of the EIS
process and points up that recent changes in regulatory authority and MEPA will
not insure a "clean and healthful" environment as required by the
Montana Constitution. The DEQ
cannot make substantive determinations and the procedural ones being made are
not adequate to the task of protecting our "clean and healthful"
environment here in Great Falls. A
recent letter from the Governor's office to me to which a comment from the DEQ
was attached and a recent article in the Great Falls Tribune make it clear that
as far as the DEQ is concerned the matter has been decided and the only purpose
of the EIS is only to determine what mitigation measures are required.
b. The state
has said that it will only consider the alternatives that the proponents of the
plant propose as being economically viable, that they will not question the
proponents determination of economic viability of their proposal and that they
have no authority to use the MEPA process to prevent the plant being built.
Given that as a backdrop and the fact that the state is applying federal
standards, how could the DEQ possibly be doing an adequate job to protecting
Montana's pristine environment?
The people in the Midwest are a- coughing and a-wheezing from coal plant
emissions; why should we allow the same for the citizens of Great Falls?
c. The air
quality permit should only allow the best available technology to be
permitted. It does not do so. The
permit also allows the plant to operate for months before they use the
mercury-reducing technology they say they will install. Ostensibly this is to allow them to run
their plant and see whether they need it or not! This is unacceptable.
Mercury reduction by using best available technology must be required
from beginning of plant operations.
d. The coal
plant is not needed. Wind power
firmed up by hydro is a much better solution for Great Falls. Wind becomes more viable if regulations
related to the flow of electricity on the grid should not favor industry but
should allow for real pooling of wind power. If, in spite of better choices, a coal plant will be built, it
should use the state-of-the-art IGCC technology. Circulating Fluidized Bed technology is not new or best
available technology; it has been around for twenty years.
e. There is
more energy produced here in Great Falls by PPL hydro than we need. Coal development here makes no sense.
By granting this permit in this form, the DEQ becomes an agent (and
responsible) for bad economic development and environmental degradation this
type of coal plant would have on this region.
f. The
developers of the coal plant have not been honest and forthcoming with their
presentation to our city officials. Mr. Gregori of SME told city commissioners
that the plant would only produce 21 pounds of mercury a year while at the same
time the proposed permit allows 45 lbs per year.
g. Applicant
has referenced a plant with similar technology in Indiana or Kentucky. In talking with engineers who have
studied this sister plant in operation, I have learned that it has been very
difficult for the plant to maintain permitted levels of the various discharges
because chemical additives need constant adjustments for factors which change
constantly. It would seem that
this type of plant would be impossible to monitor adequately to insure that
standards you set are being achieved.
Has DEQ talked with regulators and plant officials for this sister plant
to determine problems they have had in meeting their permit in actual
operation?
h. I
am concerned that if standards DEQ sets in its air quality permit are not met,
the company, once the plant is built, will request modifications to the permit
to allow even greater pollution.
Bison Engineering, the firm designing this plant, have just undergone
the same process for a new plant in Western Montana. Even though this other plant was a small plant, it is
illustrative of a problem, which has surfaced with applications submitted by
Bison Engineering. The DEQ
must look carefully at the application to see whether claims are
supportable. The plant should not
be built and then the DEQ forced to consider closure or lowering
standards. In my opinion, at
the very outset applicants should not be allowed to submit proposals, which
they know, are risky or even impractical with the idea that they will get
modifications in the permit later.
Granting an air quality permit to such folks with such foreseeable
problems will only allow capital to be wasted if the plant can not be operated
adequately.
i. The permit should expire after eighteen months if
construction has not commenced. This was a condition in the Roundup permit and
should be here also, especially since technology is advancing so rapidly in
this field. We don't want Great Falls to be stuck with an old technology plant
just because the developer wants to sit on his permit for three years, as
allowed in this draft.
j. The DEQ's
responsibility to the citizens of this state makes up our first line of
defense. You are entrusted by the
citizens of this state to make wise decisions on our behalf. It is a difficult job, because politics
usually come into play. We in
Great Falls are relying on you so that our local city officials (who have political
interest in the coal plant project) will at least have clear standards before
them. Your Department sees to it
that those standards are in accord with our right to a clean and healthful
environment, as guaranteed in our Constitution. In the long term, an ill-conceived project can have
disastrous effects on the economic and environmental future of the people who
live here and those who live downstream and downwind from here.
3. Finally,
the City of Great Falls, Montana, has never permitted its Citizens to vote on
whether they want a coal plant business venture in Great Falls, even though it
is the taxpayers who may be forced to cover losses in the development and
possible operation of the plant.
The Cascade County Commissioners have never approved the plant, nor
consider its economic and environmental consequences to this region. Others living down wind from this plant
have never been involved in the decision-making. Questions put to the city concerning proof of those willing
to buy the power and the nature of the contract and the list of public meetings
they have submitted to you have never been provided me, although I have
requested them. How can citizens
be permitted to meaningfully participate in a process which has been determined
without such participation and then when participation is only granted if it
supports the city manager's view.
Sincerely yours,
Stuart Lewin
Richard Fristik, USDA RUD
Kathleen Johnson, MT DEQ
RE: DEIS
Highwood Station
August 29, 2006
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