March 19, 2007
Mr. Richard Fristik
Rural Development, Utilities Program
U.S. Department of Agriculture
1400 Independent Ave SW.
Washington, DC 20250-1571
REF: Comments on FEIS Southern Montana Electric & Transmission Cooperative, Inc. Highwood Generation Station.
Number: C29, Dolman, Aart (Appendix, L-68)
Dear Mr. Fristik:
As an ÒInvited ConsultantÓ to the Section106 Process of the 1966 Historic Preservation Act, 02/27/07, I find that the documentation in both the DEIS and the FEIS is seriously flawed. Therefore, I request that a Supplemental FEIS is forthcoming before the Record of Decision is completed.
I find that the entire EIS process submitted by Southern Montana Electric & Transmission Cooperative Inc. (SME) and the City of Great Falls as a partner consists of a series inexcusable errors and missing components. For instance, where are the listed contents under FEIS, Vol. II, Section 3.0 Results and Discussions, p. TOC-1? This section relates to the Salem Plant seize (a premier National Historic Landmark), transmission lines (the Renander family has filed litigation in the 8th Judicial Court in Great Falls, MT.), railroad spur (which now must according to BSN requirements accommodate a 150 car train rather than a 100 car as stated in the EIS), habitat (the corresponding figures are also missing) etc.
These serious omissions cannot be written off mere oversight or misidentification. In addition, the entire examination of the FIES is so cumbersome that the 30-day comment period seems to be an exercise in public torture. Thus, I can confine my comments and remarks to some of the issues dealing with the Great Falls Portage National Historic Landmark.
One unacceptable error is that the Section 106 process should have started in the early fall of 2004. This was the time that SME and the Urquhart family had concluded a Òpurchase option agreement.Ó[1] The whole EIS issue should have been centered around the impact of the HGS on this particular location. It is difficult to understand the reason for describing a lengthy process of site selection, such as the Great Falls Industrial Park, South of Salem site, and others in the DEIS and FEIS if there existed all ready a purchase agreement between the cooperative and the landowners.
When it became clear, in August 2006, that the HGS was to be located on the Great Falls Portage National Historic Landmark, the 106 Mitigation Process required under the 1966 National Historic Preservation Act had a consultation meeting early in the following October. The fact is that Ken Dickerson, Renewable Technologies Inc, writing the Cultural Analysis and Evaluations of the DEIS, knew that there was a Section106 Mitigation Process was necessary.[2]
From the first October 5, 2006 mitigation meeting to the present there seems to be negotiations between RUS and SME for the purpose of finding a solution to lessen the impact of the HGS location on the landmark. This was perhaps the reason that the next mitigation consultant meeting, March 7, 2007, Great Falls, the restrictions, or boundaries, for discussion were so narrow that the subject of errors, mistakes, and deletions of the FEIS could not be brought to the table. It seemed that RUS was under a timeline for the Record of Decision and SME was pressing for an early starting date whether or not the material for the ROD was completed. Certainly, the accumulative effects imposed by the HGS and its location were not discussed. However, during the discussions that a Section 213 is absolutely necessary and I support this.
Since the group of consultants agreed that the Great Falls Portage National Historic Landmark is a premier site, I tried to raise some of the issues missing in the FEIS. In any study of placing a heavy industrial project on and astride a premier national landmark needs to be examined with integrity. When I tried to raise the issue of newly established Cascade County Industrial Park (not to be confused with ÒIndustrial ParkÓ in the FEIS) is directly located on the NHL, I was ruled out of order.
However at the end of that consultation mitigation meeting, the group was introduced to the SME version of landscape architecture. Since the mitigation process has recognized that the NHL site is a premier national historic site, the Landscape proposal, March 2007, offered by SME is not acceptable. The fact is that the HGS is located astride of the NHL boundary on Sections 24 & 25, and its auxiliary services must be located on the landmark site. The reason is that the landowners, Louisiana Land and Livestock, Inc., surround the property from the north, east and south. In other words the HGS plant must be located on such a confined space that it cannot accommodate its auxiliary services, such as road and train accessibility, temporary and permanent housing, emergency services, etc.
Since space allocation is an issue in any landscaping design and plant operation, the architect has tried to minimize its violation of landscape integrity. So all of the sketches to landscape alterations to such an extent that has the similar effect of a Disneyland sort of vision. The rocks and trees are so out of character that even a child can see that its violates the landscape integrity of Lewis and Clark.
More seriously, when I asked the architect about the missing 200ft high diesel exhaust stack, I was told by Mr. Gregori that it was located behind the main building. He did not explain of what happens when one drives on Salem road. The stack is still visible when one goes either north or south. The strobe lights required by the FAA are not present on the stack either. The 120,000 ton coal pile is missing, but I was told that this was not much of an issue. I know that every coal-fired plant has a pile and they seem larger than Mr. Gregori explained for it can be an imposing view. There is no sketch of 150 car rail track and its unloading facility, etc. One each side of the drive way was a deposit of unnatural rock formations, and the few trees could not hide the plant structure.
Within a few weeks a required mitigation plan must be developed, and this is an insurmountable task. Both SME and the Urquhart family must have been aware that this is a premier national historic landmark site when they concluded Òa purchase option agreementÓ or they should be advised by an attorney of the complexity of this issue. Certainly, Ken Dickerson, Renewable Technologies Inc. hired by SME should have been aware of the intensive mitigation requirement under the 1966 Historic Preservation Act when they contracted for the cultural study of the NHL. Their materials published in the Cultural Resource Inventory and Evaluations, Appendix G, DEIS and FEIS, acknowledge that the HGS would make an impact upon the landscape integrity of the NHL. The issue is that the cultural research and inventory is incomplete for this did not examine the space confinement of Sections 24 & 25 astride of the NHL boundary. The land rezoning process from prime agriculture to heavy industrial has such an accumulative impact limited amount of space that it will lead to de-listing.[3]
Adding to the difficulty of space limitation for the HGS project is the confusion about the various map configurations proposed by SME. Realizing that the actual plant could not be located on the actual NHL site, a series of maps of configurations has placed the HGS astride of the NHL boundary. However it has become clear that space confinement of the main structures such as buildings, smoke stack, coal pile, and ash cells have absorbed the land east of the NHL boundary. It is necessary for the auxiliary services such as temporary and permanent housing, construction equipment, emergency services, etc. would have to be placed on the landmark. Thus it is necessary for the Tax Increment Finance (TIF) designed for creating a heavy industry infrastructure will overlap, located on and astride, of the landmark boundary.[4]
This zoning change in Cascade County will set precedence in two ways. First, it has set precedence for industrial expansion to other areas of land located on the landmark site. This can be done very easily by landowner request and the TIF can be extended to other land on the NHL. Second, two thirds of the landmark has housing structures south of Great Falls, and the center is absorbed by Malmstrom AFB; however, this happened before the 1966 Historic Preservation Act. The remaining portion or known as lower the lower portage route has been left relatively undisturbed. Its current agricultural practices have not diminished its landscape integrity. It is this remaining portion of the Great Falls Portage route that will be impacted because of industrial development. So far it has maintained its historic integrity and it is connected to other Lewis and Clark sites in the immediate area. It is this accumulative effect of the Cascade County Industrial Park that will lead to de-listing of a premier national historic site.
The long range accumulated effects on the premier landmark site on the preferred location by the HGS have not been addressed in the entire EIS process. The impacts created by the seasonal emissions on the landmark itself have not been analyzed by several Montana governmental agencies. This whole process has been narrow in its scope and a press conference held on February 2, 2007, Mr. Gregori and Governor Schweitzer in the Capitol Building, Helena, SME promised that it would include carbon dioxide sequestration equipment in the Highwood Generation Station. If such equipment would be installed it would greatly reduce the seasonal emissions impacting the historic landmark.
From the first ÒOpen HouseÓ, October 2004, that SME and City of Great Falls employees have continually made statements that the HGS is going to happen and that it was a Òdone deal.Ó An article published by the Great Falls Tribune, 03/11/07, is merely one of the many examples of how misinformation was disseminated by SME employees to the general public. The headline stated that ÒCity not pivotal to plantÓ with a supporting statement on the front page that ÒCoal-fired facility would be built here even if Great Falls didnÕt participate backers say,Ó and declared that
ÒThe RUS is ready to fund this project,Ó Holzer said. ÒWe want the city of Great Falls to be a partner. But if they canÕt, RUS has already talked to us about finding another partner, preferably one that qualifies as an RUS borrower.Ó[5] (Terri Holzer is the General Manager for Yellowstone Valley Electric Cooperative, an SME member).
So it is easy for the public to conjecture that RUS is not only paying for the destruction of the NHL, but that RUS is also actively seeking an acceptable partner for SME in case the City of Great Falls decides to quit. Needless to state that during the March 7, 2007, Mitigation Consultation meeting the opposite was discussed.
In none of the published literature, the Great Falls Tribune and other Montana newspapers, the Stanley Consultants Inc and SME publications identified the actual location of the HGS on the Great Falls Portage National Historic Landmark. It was the greatest secret in town. The published maps did not have the portage boundaries identified, and time upon time during public meetings the public was told that the EIS process was not completed. One would have to wait to ÒdiscoverÓ its real location and this was building up suspense in the local press.
Therefore a Supplemental FEIS must present a complete and true picture of the impacts such a plant creates in a historic sensitive area. The choices should be carefully analyzed and then the public can give meaningful comments for the ROD.
Now, I shall present my comments on the FEIS as listed under C29,
100-7: ÒThere is public concern in Great Falls that the decision for a partnership with SME and that type of electric Generation was made without public discussion.Ó C29
Response: In this case, neither RUS nor the DEQ has any control over the City of Great Falls efforts to provide information, conduct meetings, or allow a vote on the cityÕs bond issue. This item is outside the scope of review of the EIS.
This item is not outside of the scope review. There are public funds involved at the federal and local level. The City of Great Falls is a public institution and is a member of SME, and it is investing public funds into the Highwood Generation Station project. The public has the right to know according to the Montana Constitution, Article II, Section 9, to review all documents related to public interest. So far the city of Great Falls has an agreement with SME and has refused to disclose agreements when requested by citizens. Eventually, the burden will come at public expense and it has a right to know of the conditions of any contractual agreements. It would have been an entirely different demand if this project was funded by non-governmental guarantees.
The other public concern not addressed by SME and the City of Great Falls is the rising costs of the HGS project. In 2004, the amount to be guaranteed was between 300 and 400 million, but with the increasing costs outlined by the R.W. Beck Study these costs have raised to about 700 million. If the sequestration equipment, (See Gregori and Gov. Schweitzer News Conference, 02/02/07) the cost would rise by another 200 to 300 million. Since RUS is guaranteeing the loan amount, it is hard to believe that there is a lack of desire to deal with this issue. Although cost overruns usually happens, but the public is confronted with rapid costs associated with the use of outdated equipment.
100-14: ÒThe technology planned for this enterprise is outdated. It will contribute pollution on a serious scale. There are better and safer technologies available. In this day of global warming, such proposed methods of producing power should be out of the question.Ó C29
Response: The combustion technology proposed by HGS was selected after a thorough review and elimination of other possible means of generation. The technology was chosen as the most feasible based on its ability to address the purpose and need, be technically feasible, cost effective, and limit emissions to meet current federal and state standards.
This response is a contradiction. SME and Stanley Consultants Inc. should have known that the CFB technology is outdated and that this type of coal-burning process is the last of its generation technology. There are more efficient plants available and they were told about this by several individuals during the 2004 Open House and they were told that this was a Òdone deal.Ó Another example is that in the News Conference held by Governor Brian Schweitzer and Mr. Tim Gregory, February 2, 2007, where SME promised to use carbon dioxide sequestration because the emission standards of the original model as proposed by SME is not acceptable. Thus the DEQ must evaluate for different standards and this must be included into the Supplement FEIS.
100-30: ÒThe fact is that the Draft EIS presents the public with non-scientific and conflicting misinformation. The document reflects a close cooperation between the proponents of the coal industry and the DEQ.Ó C29
Response: Thank you for your comments.
This response is arbitrary and capricious. The fact is that SME has recognized that it has published confusing statements about the HGS project. Kenneth A. Reich, attorney for SME, admitted that the location of the plant was misidentified in the Draft EIS and he acknowledged that there was in existence an Òoption purchase agreementÓ between SME and the Urquhart family.[6] Yet in all of the articles published by SME and the Urquhart family, the existence of this contract was never admitted. More so the public understood that the Site Selection Process as part of the Draft EIS a credible examination of several sites before the Salem road site would be chosen.
Misinformation was continually distributed in public information sessions from the first ÒOpen House,Ó October 13, 2004, to the present. Usually the theme was that any comments for other alternatives was premature and that the forthcoming the DEIS and the permitting process would examine all options. The maps published in newspapers were postage seize and failed to place the plant on the exact location and landmark boundaries were not printed. The articles cited by Mr. Reich did not identify the boundaries of the NHL and its location was not identified except that it was somewhere in the general area.[7]
The first map published by SME identified the exact location and this was during the Cascade County Commissioners meeting in late October 2006. In all of the publications by Stanley Consultants, Inc. from the Site Selection Study, October 15, 2004, and the Site Screening Study, October 2004; the DRAFT EIS in the current DEQ website, entitled Highwood Station does not identify the HGS on the boundaries of the NHL. [8]The City of Great Falls Historic Preservation Office was notified by the National Park Service in the beginning of August, 2006, that the HGS was to be located on-site of the NHL. Even though the Great Falls Tribune noted that the land sits near (emphasis added) the Great Falls Portage National Historic Landmark it did not identify the actual location. In short, the public did not know where the site was going to be located for the 2006 DEIS had two sites and it was not aware that the site had been chosen in the summer of 2004. Later in the same month, the local paper in an editorial stated that Òblocking the plant because it would be visible or audible from part of a long-gone historic route shouldnÕt be on the listÓ not caring that this would lead eventually to the de-listing of a premier historic site.[9]
As recent as March 16, 2007, Great Falls City Employee Jordan Love testified before the Montana Senate Committee Natural Resources and Energy, that there had been more than 70 meetings held by SME and City of Great Falls pertaining to the HGS, numerous articles published, at least one Electric City Power (advisory Committee to the Great Falls City Commissioners), and City Commission meetings in which the public participated. He neglected to state that there never had been a public decision process. And Mr. Gregori commented that the public could always turn to the City Commissioners. The fact is that the public has protested to the City Commissioners for a long time and each time they refused to take public protest seriously.
100-31: ÒI have many objections to the awarding of a permit for the Highwood Generation Station. At minimum, there should have been wider collaboration between Montana governmental agencies such as the Fish, Wildlife and Parks, and especially Montana Historic Preservation Office before a Draft EIS can be complete. Since it is obvious that there has been a great deal of collaboration between SME and DEQ in the composition of the Draft EIS, there has been a failure to understand the unintended consequences in a wider range of subjects from air pollution to social impacts for this document falls short of its objectivesÓ C29
Response: Notice and coordination was completed with a large number of state and federal agencies as shown in Appendix D. The array of topics covered in the EIS reflects the breadth of concerns considered. The Table of Contents lists 14 resource areas, including air quality and the socioeconomic environment. Additional consultation is occurring to the Great Falls National Historic Landmark, and the FEIS documents this consultation process and any mitigations recommended as a result of consultations.
First, the Montana Fish, Wildlife, and Parks, MT. Departments of Natural Resources, and Livestock, are not on the list in Appendix D, Draft EIS. Surely, the emissions from the smoke stack must affect organic farming and cattle grazing in the neighboring areas. Local agencies operated by Cascade County and the City of Great Falls cited on the page are not sufficient in competency making judgments of the area. For instance, there is no inventory of wildlife including sensitive bird population assessment pertaining to the National Historic Landma. rk for this is part of the Landscape Integrity. Flora and Fauna are cultural resources necessary to understand the history of Lewis and Clark.
Certainly the Montana Department of Livestock could have provided an analysis of the impact created by the development of the Cascade County Industrial Park on cattle operations in the vicinity. There is no such analysis in the DEIS and FEIS. This is even more so important since the land can be rezoned from agriculture to heavy industry at the request by a land owner.
1000-7: ÒAnother shortcoming is the inadequate analysis, or non-existence, of the impact of emissions and contaminated groundwater upon the nearby the Lewis and Clark historic site and Portage Route. Since both city officials and SME employees maintain that much of the project is to be funded by federal funds and especially when a local governmental institution is a partner in this project, it would seem that a more thorough examination of the Highwood Generating StationÕs site and the site for the storage of ashes is needed.Ó C29.
Response: The FEIS concludes that there would be no groundwater contamination from ash disposal at the HGS. It also concludes that the air quality would not be a degraded in the vicinity of the NHL. The HGS would have to comply with both an air quality permit and a solid waste license.
First, the ash cells are to be located in a northerly direction from the plant structures and are placed astride of the NHL boundary surrounded by a rail road track. There is no information on the latest FEIS map to indicate the flow of moisture containment. Since these cells have a heavy liner, it must be assumed that accumulated snow or rain will flow from these ash cells. Sooner or later they will fill up and the question is where the water will direct itself. There is no narration on controlling this flow and it can have an accumulative impact not favorable to the NHL. Since the landscape is on a downward eventually flowing into Belt Creek, it must be considered that water, containing mercury in the ash, can have a negative impact.
Since Montana Governmental Agencies, such as Fish, Wildlife, and Parks, Livestock, Natural Resources, have not been consulted or have filed reports of the immediate impact of emission, it is necessary to study the impact of both air and water contamination. Therefore, on these issues alone there has to be an addition to the current FEIS.
In other words this answer is arbitrary and not acceptable.
1000-9: ÒWhere is the study of the historic integrity of its landscape? It is clear that the 1906 Antiquities Act and subsequent congressional legislation demand that such an analysis is part of the Draft EIS.Ó
Response: A Cultural Resources Inventory was conducted as part of the EIS analysis, and a summary of its findings is included in Section 3.7.
The inventory of the Cultural Resource Inventory DEIS and subsequent FEIS is inadequate and this was not changed in the FEIS except for an inadequate mitigation proposal by SME. The Cultural Resource Inventory does not take into consideration that the Great Falls Portage National Historic Landmark is a premier historic site.[10] (Emphasis added)
Although in both the DEIS and FEIS, Analysis and Evaluation, Appendix G, stated that the Òpurpose of this cultural resource inventory report is to provide baseline data regarding cultural resources that could potentially impacted by the proposed project.Ó It is very clear that this has not been done and it gives the reader the impression that every thing is being done to avoid placing the HGS project on the NHL. It is very obvious that in the map configurations of different locations by SME much of the impact has not been included in the inventory. The creation of the Cascade County Industrial Park to accommodate the coal-fired power plant will lead to the de-designation of the NHL the accumulative impact of heavy industry will destroy landscape. This destruction was ensured when the Cascade County Commissioners approved the Tax Increment Finance (TIF) applicable on and astride of the NHL.
The most recent Landscape, March, 2007, published by SME does not take into consideration that the NHL is a premier historic site. The endangerment caused by the HGS plant is more than just a Òfootprint.Ó This assessment is arbitrary and capricious.
1000-18: My comments under this section are not recorded even though I had sent related comments. I strongly protest the exclusion.
1100-2: Again my comments under this section are not recorded even though I had sent related comments. I strongly protest the exclusion. See my statement below on accumulative effects.C29
1100-3: Same as above. See my statement about accumulative effects. C29
The effects of lighting has been addressed in the FEIS as an adverse impact. One of the mitigations identified in the Memorandum of Agreement is to utilize directional lighting that will focus light downward to reduce glare to the night sky.
Note: Since this plant is in close proximity to Malmstrom AFB, it needs to have a continual strobe lighting system on its smoke stack and the two hundred feet diesel exhaust system according to FAA regulations. They must be operative for 24 hrs a day and this is also not in the artists description of landscape integrity.
1100-4
Response: In consultation with the various agencies, the use of trees has not been identified as an appropriate mitigation. SME would plant native grasses and shrubs in landscaping around the plant.
Excuse me, the March 7, 2007, consulting mitigation meeting about Section 106, the landscape artists hired by SME who proposes the planting of Rocky Mountain Juniper on the landscape. The plan is to hide the plant from as much view as possible from Salem road according to the artistÕs interpretation. Needless to state, I found this very much out of character with the surrounding landscape and it was mentioned that no trees were to be planted. The SME landscape plan clearly shows that trees are planted on the NHL as part of a road, or pathway, from Salem road to the plant. This violates the landscape integrity as seen by Lewis and Clark. Currently, the land consists of flowing grain fields. The arrangement of rock is an unnatural pattern along the same access road from Salem Road to the plant.
Accumulative Impact on the Great Falls Portage National Historic Landmark:
I. Accumulative socioeconomic impact on the Great Falls Portage National Historic Landmark in Cascade County and Central Montana:
Although the FEIS Executive Summary, p.ES-12, and p. 5-7, states that Òconstruction of the HGS would have a moderately beneficial effect on the socioeconomic environmentÉ,Ó there are three segments, tourism, housing, and agricultural livelihood, that have not been explored as an accumulative socioeconomic impact upon the area in northeast Cascade County.
A. Tourism: glancing at the map of the National Historic Landmark sites in Montana, there are two east-west, I-90 in the south and US 2 along the Canadian border from North Dakota to Glacier Park, and only one north-south, I-15, from Canada to Idaho. Along both east-west routes are Lewis and Clark NHL sites, and in central Montana there is only one located near Great Falls. This geographic area plays a key role in the economic tourist pattern of north central Montana and the Great Falls area.
The placement of the Highwood Generation Station in this northeast corner of Cascade County has an accumulative during its projected lifespan of thirty (30) years in north central Montana. The Official Montana Travel Information website advertises the Lewis and Clark experience, and it has the following statement:
ÒON THE LEWIS & CLARK TRAIL
Much of the Montana landscape that Lewis & Clark crossed remains unchanged. From river canyons to mountain meadows. Montana's rivers and highways flow past scores of landmarks related to the expedition.Ó Travel Montana, http://lewisandclark.state.mt.us/
Then it goes on to describe, ÒUnder the Montana Unspoiled Adventure,Ó that today, much of the Montana landscape that Lewis & Clark crossed remains unchanged. From solitary sandstone through river canyons to mountain meadows, Montana's rivers and highways flow past scores of landmarks related to the expedition. Tourist from all over the United States and the world are attracted to view the unspoiled beauty of Lewis and Clark sites and experience the travels of the Corps of Discovery in the nearby Missouri River Breaks National Monument.
Continually Montana and local advertisements stress the point that the area has not changed much from the time of Lewis and Clark. The Lewis and Clark National Historic Trail Interpretive Center states that Òone can re-live the 1804-06 Lewis and Clark Expedition's 8,000-mile journey across western North America in the comfort of its center.Ó This center attracts some 80,000 tourists a year. The Director reported the Òbiggest crowds since the first summer opening in 1998.Ó A total of 3,336 visitors came over the Fourth of July weekend in 2005 and on a regular basis the Center draws more than 80,000 visitors from all parts of the United States and the world. The Montana ChildrenÕs Museum, the CM Russell Museum, and the High Plains Heritage Center, all in Great Falls, featured educational exhibits related to the Lewis and Clark experience and all reported during that year increased attendance.
During the Lewis and Clark Bicentennial, a 2005 signature event, Montana was one of fifteen states in the United States to participate. In Great Falls it took years to plan and the project had a budget of more than $2 million, and it produced some 180 activities over a 34 day period. A ballet, ÒA Tremendous JourneyÓ drew high praise and a crowd of more than 1500. The opera, Poia, built around the Blackfeet legend of Scarface, likewise drew critical praise, but small crowds. A Native American Powwow attracted some 300 dancers and hundreds of participants took advantage of river floats and bus tours. The attraction is so strong that the area surrounding the City of Great Falls is in essence Lewis and Clark Òcountry.Ó It is part of the Lewis and Clark Interpretive Center, which has a yearly count of about 80,000 visitors, the Sulfur Springs Trail, the lower Portage route, White Bear Island, and the campsites along the Missouri River have been described in the Lewis and Clark Journals.
The numbers of tourists and visitors tell only part of the story for more than 60 grants were made to tribes and were used to promote and preserve native culture. A nationally unique program, ÒUndaunted StewartshipÓ may well ensure that when the tri-centennial rolls around, generations of the future will still be able Òto see the land as Lewis and Clark saw it.Ó The Bozeman Daily Chronicle, ÒWhy the Lewis and Clark Bicentennial was not a bust,Ó September 18, 2006, stated that to Òsay that the bicentennial was a bust because of low-budget sales of souvenir T-Shirts is like arguing that the Louisiana Land Purchase was a flop because sales of beaver pelts died down. It misunderstands both the purposes of the Lewis and Clark Bicentennial and the reality of what really happened.Ó The tourist industry is already the foundation for the celebration of the Lewis and Clark Tri-centennial.
For many years, since the late 1950s, a variety of local and national organizations, federal and state agencies have developed Lewis and Clark sites in north central Montana. Millions of dollars were invested to develop these sites and attract tourists to the area. Since the Great Falls Portage National Historic Landmark is in danger of de-listing, or de-designation, there is a socioeconomic accumulative impact which has not been taken in balance with the 30-year lifespan of the Highwood Generation Station. The FEIS does not compare the accumulative balance between the two industries. Therefore it is essential that an additional FEIS must compare and contrast the socioeconomic accumulative impact of both industries.
B. Required Structures and Housing: The maps of the FEIS do not find the location of an emergency station, temporary, or permanent housing described in this document but these structures will have an accumulative impact upon the Great Falls National Historic Landmark.
1. Emergency Station: As part of the socio-economic impact the idea Public and Plant Safety is not mentioned in the FEIS. In case of fire, panic, or other dangers related to employees and residents of the temporary and permanent housing units there are no plans. Emergencies are bound to happen during construction period and once the plant is in operation. Currently, there is limited access to emergency care in the agricultural community. The proposed coal-fired electric generating plant depends upon emergency care and this must come from many miles away.
Forgotten is that the available emergency crew is a volunteer force and the Volunteer Fire Department is not likely to have the resources necessary to address large scale emergency situations that could arise when the plant of this magnitude is constructed and later becomes operational.
No provisions have been made for this type of situation and this is irresponsible for RUS to ignore. A subsequent FEIS must place accessibility on a map for it is part of the accumulative impact.
2. The temporary housing site used for rapid changing construction crews will be located on the NHL. The Cascade County Commissioners have created a TIF for this purpose and this is for the duration of the HGS construction phase. This means that between Salem road and the plant location there will be the development of an infrastructure for this type of housing. Many of the construction workers will live in Recreational Vehicles, small trailers, and other type of temporary structures for they are highly mobile and stay on the job for short time durations.
3. Permanent housing will last for the thirty year life span of the Highwood Generation Station. This will have a different accumulative impact on the HHL. The TIF application reads as follows:
ÒInfrastructure including the acquisition, construction, and improvement of infrastructure and industrial infrastructure and technology infrastructure that includes streets, roads, curbs, gutters, sidewalks, alleys, parking lots and off-street parking facilities, sewers, sewer lines, sewage treatment facilities, storm sewers, waterlines, waterways, water treatment facilities, natural gas lines, electrical lines, telecommunications lines, rail lines, rail spurs, bridges, fuel manufacturing, and cargo holding facilities, public owned buildings, and any public improvements authorizedÉÉ.Ó Cascade County Minutes of Commissioner Meeting, 12/29/06.
Please note that none of these features are located on the map published by both the county and SME; they are supposed to be located in Sections 24 & 25, unless there is, of course, expansion to other areas of the NHL. The landowners, Louisiana Land & Livestock, Inc. have refused to sell any of the surrounding land. But the latter did donate land to the Lewis and Clark National Trail Heritage foundation for a historic marker site on Salem Rd.
In each case of the structures on and astride of the landmark there is no discussion of what happens when the plant is no longer operational. Whose responsibility is it to clean up?
C. Agricultural livelihood: The FEIS does not evaluate a comparison of the accumulative impact by use of agriculture and heavy industry. When the Cascade County Commissioners had adopted the Cascade County Growth Policy, September 19, 2006, a few days after the August 30, 2006, DEIS dead-line the implication was that traditional agricultural practices would remain on the landscape of the Great Falls National Historic Landmark site. From the latter part of the nineteenth century to the present a variety of agricultural practices have had a very low or non-existent accumulative impact upon the NHL landscape integrity. To this day, the land supports a variety of agricultural productions which ranges from growing the traditional wheat crop to contemporary organic wheat production.
Nowhere does the FEIS responds to the accumulative impact of the adjoining properties caused by its operations. The operation of HGS Òcould indirectly influence land uses on adjoining or nearby properties in the vicinity of the site.Ó The impacts associated with plant operations could potentially Òhave an accumulative affect one particular area and be perceived as adverse enough to residents that they would choose to relocate.Ó (See FEIS, p. 4-141, Farmland and Land Use). The families living in the immediate area who earn a living from this land and they face not only increased traffic by trucks carrying limestone, or the proposed railroad track separating landowners from their farming operations, to the automobile traffic generated because of the proposed housing development necessary for employees working in the plant. In short the agricultural heritage described so vividly in the Cascade County Growth Policy will be destroyed and farm families will have to move if they disagree with it development.
When in late October 2006, Cascade County Commissioners rezoned the land, Sections 24&25, Township 21N and 5East, from prime agriculture to heavy industry they created the Cascade County Industrial Park for the sole reason to accommodate SME which wanted to construct the Highwood Generating Station. Later, 12/29/06, a TIF (Tax Increment Finance) application was submitted to the Montana Department of Revenue. This meant that on and astride of the NHL an industrial infrastructure complete with streets, lights, sewer/water, etc. was to be created and, according to County Commissioner Briggs to be expanded.
The FEIS does not examine the accumulative impact of the transformation from agricultural practices to one of heavy industry. The fact is that it will have a tremendous short term impact upon the area and it will be changed forever. The reference to the Òimpacts associated with the operating the plant could potentially cumulatively affect one particular area and be perceived as adverse enough to residents to relocateÓ is arbitrary and capricious. (See p.4-112)
Therefore a supplemental FEIS is needed to examine seriously the accumulative effects of destruction of agricultural practices. Is this not a contradiction of the USDA mission?
4. Other accumulative impacts upon the NHL:
A. Fugitive Deposits:
1. Seasonable emissions are not taken into consideration. According to the DEIS, each year the stack from the HGS will produce and place more than 3 millions tons of carbon dioxide, 336 ton of particulate, 443 tons of sulfur dioxide, 944 tons of nitrogen oxides and 1,777 tons of carbon monoxide into the air. It will emit mercury, arsenic, beryllium, cadmium, manganese, lead, and acid gases. Will accumulate on the NHL and it has not been measured what its accumulative impact will be on the NHL.
2. Coal Pile: although the coal pile is marked on the map, the FEIS does not discuss the accumulative effect of coal particles being blown onto the NHL during its 30 year life-span.
This is particularly important because the amount of a monthÕs emergency supply and daily consumption of coal, some 120,000 tons of coal in a pile need to be Òwetted or dampenedÓ down because of frequent strong winds in the area.
3. Diesel Stack, 200 feet, is not mentioned in the FEIS including its accumulative fugitive emissions deposits on the NHL.
4. Expanded rail track missing for the system has to accommodate 150 cars and not 100 cars as listed in the 2006 DEIS and subsequent FEIS.
B. Visibility
1. Unacceptable landscape design as part of the mitigation process. The artist showed a serious of incomplete designs of a possible landscape design. Missing was the 200 feet Diesel Stack; in fact, Mr. Gregori explained that it would be hidden as one enters the complex. But it is not hidden from the L&C Historic Marker on Salem Road.
Also the FEIS states clearly that no trees are to be planted but the artist included a tremendous amount of trees which is totally against the landscape integrity of the NHL. This includes the entry road from Salem Road to the HGS structures.
2. The picture, F-4-13, presents a distorted view of the Windturbines. They are much larger and again the coal pile, the emission stack is not showing. A. Proposed Landscape alterations.
C. Wind Turbines cannot be allowed on the NHL. As Cascade County Industrial Park has no rules for additional wind turbines, there is no guarantee that there will not be an expansion of a wind farm on the NHL. This is an important accumulative effect.
Conclusion: A supplemental FEIS is needed before a Record of Decision can be made for the following reasons:
1. The Site Selection Process was compromised from the beginning. The existence of a Òpurchase option agreementÓ between SME and the Urquhart family challenged the public credibility of the entire EIS process.
2. Mitigation cannot be solved for continuing with the HGS project will destroy a premier national historic landmark. Even more so a local Lewis and Clark organization cannot negotiate to mitigate this endangerment.
3. The economic benefits have not been discussed in the EIS process. Certainly, agricultural and tourist industry will be impacted with the loss of the NHL, and this needs credible economic analysis.
4. The Great Falls Portage NHL is so important that federal, state, and local governments, private foundations, and numerous individuals have invested millions of dollars to protect, preserve, and restore important L&C sites in north central Montana.
5. The implementation of carbon dioxide sequestration equipment for the HGS plant must be taken into consideration because it will, eventually, destroy much of its native vegetation.
I appreciate it very much that RUS has requested my services as an ÒInvited ConsultantÓ in the Section 106 Mitigation Process. And if I can be of further assistance please do not hesitate to contact me. Again it was wonderful to meet with you in Great Falls.
Sincerely yours,
Aart Dolman
[1]
See Kenneth A. Reich to Mark Plank letter, 01/09/07, p. 4
In fact, Mr. Gregori
stated this during the Consultation meeting, March 7, 2007, that he had been
for a long time a Lewis & Clark enthusiast and that he served on a local
Lewis and Clark Board. Both Duane and Mary Urquhart also have served on local
L&C boards and are well known for their activity in a local historic group.
The parents, Charles and Stella Urquhart had made many contributions to local
historic groups and even donated land to the BSA monument. One of the
consultants pointed out during this meeting that Stella Urquhart had been in
communication about the landmark with Senator Mansfield sometime in the
nineteen sixties.
See also attached Great Falls Tribune articles,
02/17/05 and 02/03/06.