Citizens for Clean Energy, Inc. <www.cce-mt.org>
615 Third Ave. North
March 16, 2007
Mr. Richard
Fristik
USDA Rural
Development, Utilities Program
1400
Independence Avenue, SW
Mail Stop 1571,
Rm 2237
Washington,
DC 20250-1571
re: FEIS, Coal-fired Highwood Generating
Station, Great Falls, MT
Dear Mr.
Fristik:
The Impact Analysis
for SMEÕs proposed action clearly states that if the coal plant were to be
constructed at the Salem site, there would be adverse impacts on soils, water
resources, air quality, biological resources, noise, recreation, cultural
resources, visual impacts, traffic patterns, farmland and land use, waste
management, and health and safety.
To conclude that these impacts would Ònot be significantÓ defies both
common sense and scientific reason.
When I queried the contractor Mangi Environmental as to where are the
cited references so that as an experienced scientist and a physician I could
independently evaluate the data upon which these pronouncements of
Òinsignificant to health and safetyÓ were based, I was told that Òsuch
references are not specifically cited and are not availableÓ and that the
determinations of significance are derived in a process that is Òan art as well
as a scienceÓ. I also asked if the Agency takes into consideration recently
published studies that have demonstrated the serious health effects of exposure
to very small particulates, such as those that will be emitted by the proposed
coal plant. I was informed that it was doubtful that the latest information
(such as the Feb. 2007 seminal study of the adverse effects of PM 2.5 pollution
published in the prestigious New England Journal of Medicine and cited below) would be factored into
the decision making process because Ògovernment doesnÕt work that fastÓ. I have yet to determine who formulated
these conclusions of ÒinsignificanceÓ, but as a concerned citizen and taxpayer
I believe I have a right to know.
I am not alone
in my concerns. Many healthcare workers in northcentral Montana have expressed
opposition to the proposed Highwood Generating Station (HGS). I have appended a
copy of a recent petition against the Highwood coal plant, signed by more than
150 physicians and healthcare workers and published in the Great Falls
Tribune on Sunday, March 4, 2007.
As citizens who
live and work adjacent to superfund sites that are the result of past
exploitation of MontanaÕs natural resources, we have learned hard lessons from
the past, when industrial projects were constructed at a time when longterm
adverse environmental consequences were unknown. To proceed with building such dated technology as a CFB coal
plant at this time in this century is the height of arrogance and folly.
Here are a few
selected quotes from area physicians in diverse specialties:
ÒAs a pulmonologist I treat many
patients with asthma and other respiratory diseases who would be adversely
affected by the particulate matter and sulfur dioxide pollution produced by
this proposed coal-fired generating plant.Ó Dave
Anderson, M.D., Great Falls Pulmonologist
ÒThe Final
Environmental Impact Statement indicates multiple ÔAdverseÕ
impacts on our health and air quality, with Moderate degradation and Regional
haze and acid deposition. These ÔAdverseÕ impacts would be Òlong-term
duration and medium extent with a probable likelihood of occurringÓ. With
emissions of 36.5 pounds of Mercury, 600 pounds of Lead (both neurotoxins), and
thousands of tons of sulfur/nitrogen/particulates, the Highwood Plant will put
children at significant unneeded risks with their health and
development.Ó
Charles
Christensen D.O. FAAP, Great Falls Pediatrician
"According
to a report from the Oak Ridge National Laboratory a 250 megawatt plant
such as the proposed Highwood unit would release approximately 1.3 tons of
uranium and 3.2 tons of thorium per year. There is no requirement to monitor
radiation released into the environment by coal plants so we will not know
how much of this enters our air, soil and water.Ó Jeffrey Stephenson, MD, Radiation
Oncologist
ÒThe
combustion of 2.6 billion pounds of coal each year will add smog to our Big
Blue Sky. The Highwood coal plant is permitted each day to release one ton
of breathable invisible particulate matter, laden with toxic heavy metals such
as mercury, arsenic, and lead. These inhaled particles not only endanger
peopleÕs lungs, but also contribute to heart attacks and strokes. This coal
plant will produce the greenhouse gas equivalent of more than 500,000 cars. Why
would we do this to our children, ourselves and our planet, when more modern,
cleaner alternatives exist?Ó Cheryl Reichert, M.D., Ph.D., Pathologist and
Biochemist
Important
health concerns- Mercury
Mercury is a
poisonous neurotoxin that is especially damaging to babies in the womb.
According to the EPA, coal-fired power plants are the largest source of mercury
pollution in the country. In recent years coal-fired power plants are
responsible for 92% of all manmade mercury air emissions in Montana.
.
Despite
repeated promises to our City Commissioners and the public that SME will
install specific mercury controls such as activated carbon injection when the
coal plant goes online, the plant as described in the FEIS (and as budgeted for
in the RW Beck financial feasibility study) requires no specific mercury
controls. There is only a stated intention of possibly adding this control
after 18 months of operation Òif itÕs needed to bring the plant into
complianceÓ with the 1.5 pounds/TBtu or 90% capture. In stark contrast,
according to John Thompson of the Clean Air Task Force, modern IGCC facilities
can capture up to 99% of the mercury and early enough in the chemical
processing of the coal that the mercury doesnÕt pose the added long term
ecological burden of possible contamination of groundwater.
Mercury enters
the food chain through consumption of fish tainted with mercury. Fish
bioaccumulate methyl mercury, which is mercury in its most dangerous form. The concentration of mercury in
predaceous fish can be 1 million to 10 million times more concentrated than the
surrounding water.
Fish are an important source of dietary protein and essential fatty acids, so
while at the same time patients are advised to increase consumption of heart
and brain healthy fish, they are warned to limit the amount of fish they eat,
depending upon the size and type of fish and mercury contamination where the
fish are caught. This conflicting advice is especially challenging for women of
child bearing age, since essential fatty acids are needed for normal brain
development in the unborn child, yet mercury is so slowly excreted from the
body that much of the damage could be done before the woman even realizes that
sheÕs pregnant. Many of MontanaÕs
lakes and streams already have fish advisories that limit consumption of fish
because of mercury contamination (see Montana Sport Fish Consumption
Guidelines, ÒIs my catch safe to eat?Ó ÒWhat you need to know about mercury and
PCBs in MontanaÕs sport fishÓ, Montana Fish, Wildlife, and Parks, Dec.
2004). At nearby Tiber Reservoir
it is recommended that a young woman not eat more than one 6 oz. serving of
18-22 inch walleye a month. The amount of mercury in a single teaspoon can make
the fish in a 1000 foot-acre lake unfit for consumption.
During the last
century mercury emissions worldwide increased 2 to 5 fold. According to the United Nations
Environmental Program, 70% of worldwide mercury emissions are now caused by
human activity. Coal plants are the largest single source of manmade mercury
contaminating our environment, accounting for approximately 48 tons of annual
mercury pollution in the United States. Coal plants are poisoning our planet
with mercury and need to be strictly regulated. The residents of Quaanagg, Greenland, located far above the
Arctic Circle, have mercury blood levels as high as 12 times the recommended US
guidelines for this toxic metal.
They do not create this mercury pollution themselves; this is a ÒgiftÓ
to them from the industrialized world as they subsist on a diet of whale, seal,
and fish contaminated by mercury (L. Greer et al, ÒCurtailing MercuryÕs Global
ReachÓ, Worldwatch Institute, State of the World 2006, p 96).
Mercury is
very dangerous to embryos and fetuses, where it is concentrated in the placenta
and enters the body of the unborn child, where its damaging effects are most
evident within the developing brain. One out of six American women of child
bearing age already have blood levels of mercury that exceed federal
guidelines. This puts approximately 600,000 babies at risk in the US alone (L.
Trasande et al,
ÒPublic Health and Economic Consequences of Methyl Mercury Toxicity to the Developing
Brain, Environmental Health Perspectives, vol 113 #5, May 2005, p. 590-596).
Mercury is particularly dangerous to unborn babies because it is concentrated
in the placenta and it crosses the blood brain barrier of the developing baby
and arrests dividing cells by affecting the microtubules of the spindle of
chromosomes, interferes with synaptic transmission, and alters apoptosis of
neurons. Babies are born with higher blood mercury levels than their mothers.
Babies so affected have fewer brain cells, and this is an effect that is
irreversible and lifelong. The
extent of damage is dependent upon the dose of mercury and host genetic
susceptibility factors. Since we
donÕt subject children to brain biopsies to count the number of neurons, this
is an effect that can only be measured indirectly and rather crudely, by loss
of IQ, learning disabilities, and behavioral problems. The National Academy of
Science has stated that neurologic damage to children exposed to mercury in
utero will result in
increased numbers of children requiring special education and remedial
classes. Mercury exposure may also
continue in infants by contamination of breast milk.
When the mercury
dose is very high the effects are dramatic, and have been proven in tragic
industrial accidents, such as occurred in Japan and Iraq. These are extreme
examples of exposures much greater than from eating Montana fish, but they
clearly demonstrate the serious toxic effects of mercury.
a. MinamataÕs disease-
The coastal waters of the cities of Minimata and Niigata, Japan
were contaminated with mercury
during the 1950Õs. There were 21,000 claims of injury and 600 fatalities. Among
those affected were 22 pregnant women who gave birth to children with severe
anomalies, mental retardation, cerebral palsy, and seizures.
b. Iraq grain-
During the 1970Õs mercury was used as a fungicide for stored grain and
was inadvertently consumed instead of planted. Of the 6,530 affected individuals, 439 died. There were 83 women who were pregnant
at the time of exposure. These women underwent tests for mercury in their hair,
and adverse effects in their offspring were seen in Hg levels as low as 10 ppm.
There is a
correlation of mercury emissions with rates of autism and special education
needs for young children in Texas.
Children more readily absorb metals than adults. In a preliminary study
performed at the the University of Texas Health Science Center in San Antonio,
Texas, there was an increase in the rate of autism and the need for special
education services autism that correlated with environmentally released
mercury. (R. Palmer S. Blanchard, Z. Stein, D. Mandell, and C. Miller
ÒEnvironmental mercury release, special education rates, and autism disorder:
an ecological study of Texas, 2005).
As if the cost
in human suffering isnÕt enough to justify the expense of mercury controls,
public health researchers at the Mount Sinai School of Medicine, Harvard
Medical School, and Albert Einstein College of Medicine have quantitated the
lost productivity to society from methyl mercury toxicity at approximately $8.7
billion, as referred to in the Feb. 2005 NESCAUM (Northeast States for
Coordinated Air Use Management) and the Harvard Center for Risk Analysis. See also: L. Trasande, P.
Lanrigan, and C. Schechter, ÒPublic Health and Economic Consequences of Methyl
Mercury Toxicity to the Developing BrainÓ, Environmental Health Perspectives, vol 113, #5 (2005) 590-596.
Mercury has
an adverse impact on the immune system in people of all ages.
Mercury replaces trace metals in some enzymes and binds to sulfhydryl
groups. Mercury inhibits
lymphocyte functions and is linked to increased allergies and autoimmune
reactions. M. Hansson et al,
Immunology 2005 Mar;114 (3):428-37.
Two
preliminary studies show that mercury conveys cardiovascular risk to middle
aged men (studies not
yet complete in women). Mercury
has no known beneficial physiologic effects. Mercury promotes formation of damaging free radicals. Mercury disables the bodyÕs most
powerful natural antioxidants (glutathione, superoxidase dismutase, catalase),
and it inactivates the beneficial effect of selenium. All of this has the net effect of damaging cell membranes
and making cholesterol more likely to deposit in plaques. In one European study of 400 men there
was a correlation of increased levels of mercury and risk of heart attacks and
coronary artery disease. In a
separate study there was a 50%-70% increased risk of heart attack and coronary
artery disease in patients with increased mercury levels. J. Virtanen et al. Arterioscler Thromb
Vasc Biol vol 25, (2005) 228-233.
At high
concentrations neurologic damage occurs in people of all ages.
1. The expression Òmad as a hatterÓ, which was popularized in Lewis CarrollÕs
Alice in Wonderland, comes from the occupational hazard of using mercury
compounds to make felt hats during the 1800Õs.
2. In the mercury mines in Spain the miners are asked to draw a
line in-between two narrow lines before they descend into the mines. When their
tremor becomes so bad they can no longer stay between the lines they lose their
job.
As recently
shown in the Steubenville Ohio study, mercury disproportionately settles
locally (G. J. Keeler,
ÒSources of Mercury Wet Deposition in Eastern Ohio, USAÓ, Environmental Science
& Technology, vol. 40 (2006) p. 5874-5881).
Biological
mercury hotspots have been identified in the northeastern United States and
southeastern Canada using a data set of biotic Hg concentrations (David C.
Evers et al., BioScience, January 2007, Vol. 57 No. 1, p. 29). More than 7300
observations were used to locate five biological Hg hotspots and nine areas of
concern. The yellow perch and common loon were chosen as indicator species for
the human and ecological effects of Hg, respectively. Biological Hg hotspots
receive elevated atmospheric Hg deposition, have high landscape sensitivity,
and/or experience large reservoir fluctuations. Time series data for this region suggest that reductions in
Hg emissions from local sources can lead to rapid reductions of Hg in biota.
Areas of
Northcentral Montana have the potential of becoming ÒhotspotsÓ if this coal
plant is ever built. Federal Agencies are required to examine possible
disproportionate impacts on children and on minority and low income populations
(Executive Orders 13045 and 12898 respectively). The Rocky Boy Indian
Reservation with a population of several thousand Native Americans is directly
downwind from the proposed coal plant.
Inhabitants of the Reservation have registered their unanimous opposition
to the coal plant, as evidenced by written and oral testimony.
Important
health concerns- Particulate
Matter 10 & PM 2.5
A 2006
television HBO documentary, ÒThe Air We BreatheÓ, graphically demonstrates the
problems with asthma in children living adjacent to coal plants. The
Highwood Generating Station is permitted each day to release approximately one
ton of dangerous, respirable PM 10 particulates, laden with toxic heavy metals
such as arsenic and lead. We now have evidence that very small particles
not only endanger peopleÕs lungs, but also hearts and arteries (Science News, August 2, 2003, p.72).
According to an
news article that appeared in the Great Falls Tribune on January 19, 2007,
Missoula, Libby, Hamilton and Butte will probably not meet new federal air
quality standards to safeguard human health. Helena and the Flathead and Gallatin valleys also appear
dangerously close to the limit, due to poor wintertime dispersion of air. The new standards, which took effect in
December 2006 address both PM 2.5 microns and particles between 2.5 and 10
microns. Under the revised
standards, the 24-hour fine particle standard was tightened from 65 per cubic
meter to 35 micrograms per cubic meter, while the national annual fine particle
standard remains at 15 micrograms per cubic meter. The FEIS indicates in a
table on p. 80 of the Supplemental PD 3423 that PM 10 pre-monitoring results on
the proposed site from Nov. 12, 2004 through Nov. 11, 2005 that 24-hr PM 10
background is already 19 to 23 ug; it is not possible to determine from the
data provided how much of this is from the most dangerous particles of 2.5
microns and smaller. Because the
provisional air quality permit that appears in the FEIS was released on June
30, 2006, the new limits for PM are not addressed and the permitted limits of
PM 2.5 particulates from the Highwood coal plant are not given. Furthermore, the data given in in table
2-7 in volume 2 on page 2-27
appears to indicate that for PM10 and for other Hazardous Air Pollutants that
the Highwood plant is more dangerous than any of the listed alternative
technologies. The table contains
obvious inaccuracies with respect to IGCC; these factual errors were pointed
out in comments for the corresponding table in the DEIS (2-25), but were not
corrected in the FEIS. This raises the question in my mind of which numbers are
accurate and which numbers are bogus and how am I to tell the difference?
An important
recent study on the adverse effects of PM 2.5 air pollution was published on Feb.
1, 2007 (K. A. Miller & J. D. Kaufman et. al.
ÒLong-Term Exposure to Air Pollution and Incidence of Cardiovascular
Events in WomenÓ, New England Journal of Medicine, Vol. 356, Number 5, 447-458). A total
of 1816 women had one or more fatal or nonfatal cardiovascular events, as
confirmed by a review of medical records, including death from coronary heart
disease or cerebrovascular disease, coronary revascularization, myocardial
infarction, and stroke. In 2000, levels of PM 2.5 exposure varied from 3.4 to
28.3 £gg per cubic
meter (mean, 13.5). Each increase of 10 £gg per cubic meter was associated with a 24% increase in the
risk of a cardiovascular event and a 76% increase in the risk of death from
cardiovascular disease. The risk of cerebrovascular events was also associated
with increased levels of PM 2.5.
The FEIS does
not specifically address PM 2.5, and this is a serious deficiency. This health and safety concern is
further compounded by the incomplete air modeling studies that fail to take
into account air inversions that accompany Arctic fronts. During these intervals an atmospheric
ÒcapÓ will concentrate deposition of particulates laden with toxic heavy metals
on the local populace.
Important
health concerns- other
air pollutants
According to a
2004 policy statement by the AMERICAN ACADEMY OF PEDIATRICS and published in
Pediatrics 2004;114:1699Ð1707 ambient (outdoor) air pollution is recognized as
an important problem, both nationally and worldwide. According to this study,
scientific understanding of the spectrum of health effects of air pollution has
increased, and numerous studies are finding important health effects from air
pollution at levels once considered safe. Children and infants are among the
most susceptible to many of the air pollutants. In addition to associations
between air pollution and respiratory symptoms, asthma exacerbations, and
asthma hospitalizations, recent studies have found links between air pollution
and preterm birth, infant mortality, deficits in lung growth, and possibly,
development of asthma. This policy statement summarizes the recent literature
linking ambient air pollution to adverse health outcomes in children. Criteria
air pollutants include ozone, particulate matter, sulfur dioxide, nitrogen
dioxide, carbon monoxide, and lead. Children are more vulnerable to the adverse
effects of air pollution than are adults. Eighty percent of alveoli are formed
postnatally, and changes in the lung continue through adolescence. During the
early postneonatal period, the developing lung is highly susceptible to damage
after exposure to environmental toxicants. Children have increased exposure to
many air pollutants compared with adults because of higher minute ventilation
and higher levels of physical activity. Because children spend more time
outdoors than do adults, they have increased exposure to outdoor air pollution.
Infants, children, the elderly, and those with cardiopulmonary disease are
among the most susceptible to adverse health effects from criteria pollutants.
Lead is neurotoxic, especially during early childhood. Carbon monoxide
interferes with oxygen transport through the formation of carboxyhemoglobin.
Other criteria pollutants (ozone, sulfur dioxide, particulate matter, nitrogen
dioxide) have respiratory effects in children and adults, including increased
respiratory tract illness, asthma exacerbations, and decreased lung function.
Children in communities with higher levels of urban air pollution (acid vapor,
nitrogen dioxide, particulate matter with a median diameter less than 2.5 m [PM 2.5] had decreased lung function
growth, and children who spent more time outdoors had larger deficits in the
growth rate of lung function. Ambient
ozone is formed by the action of sunlight on nitrogen oxides and reactive
hydrocarbons, and is a powerful oxidant and respiratory tract irritant in
adults and children, causing shortness of breath, chest pain when inhaling
deeply, wheezing, and cough.
Other
Hazardous Air Pollutants (HAPS)
The HAPs, often
referred to as Òtoxic air contaminantsÓ refer to 188 pollutants and chemical
groups known or suspected to cause serious health effects including cancer,
birth defects, and respiratory tract and neurologic illness. The health risks
may also be underestimated, because there is limited information on toxicity
values for many of the HAPs, and the risk models do not consider the potential
for increased risk in children. These findings underscore the need for better
ways to decrease toxic air emissions and assess exposures and risks.
According to the
Table 2-7 on page 2-27 in the FEIS, the CFB coal plant proposed by HGS is
permitted to emit far more hazardous air pollutants (43.7 tons/year) than any
of the other types of combustion coal technology.
Compounding
Effects of Exposure to Air Pollution
Dr. C. de Burbure and her colleagues
recently warned that Òheavy metals polluting the environment can cause subtle
effects on childrenÕs renal and dopaminergic systems without clear evidence of
a threshold, which reinforces the need to control and regulate potential
sources of contamination by heavy metals (Environmental Health Perspectives,
April 2006, vol. 114, #4, p. 584-590).
Current air
permitting regulations by the Montana DEQ do not require specific measurements
of any of the heavy metals that will come from the coal plant, despite
projected release of 540 pounds of Arsenic, 560 pounds of Lead, as well as
Cadmium. (These substances are only measured indirectly, using the surrogate
marker of the amount of the total PM 10 particulate matter that is released,
and based upon a measurement that is required to be performed by SME and
self-reported only once a year).
Exposure
to Radiation
According to W.
Alex Gabbard (leader of the High Temperature Fuel Behavior Group in the Nuclear
Fuel Materials Section of ORNL's Metals and Ceramics Division and principal
investigator for the Laboratory's Nuclear Energy Program), releases from coal
combustion contain naturally occurring radioactive materials--mainly, uranium
and thorium. Former ORNL researchers J. P. McBride, R. E. Moore, J. P.
Witherspoon, and R. E. Blanco made this point in their article
"Radiological Impact of Airborne Effluents of Coal and Nuclear
Plants" in the December 8, 1978, issue of Science magazine. They concluded
that Americans living near coal-fired power plants are exposed to higher
radiation doses than those living near nuclear power plants that meet
government regulations. This ironic situation remains true today. The
population effective dose equivalent from coal plants is 100 times that from
nuclear plants. The fact that coal-fired power plants throughout the world are
the major sources of radioactive materials released to the environment is not
well known.
Coal is one of
the most impure of fuels. Its impurities range from trace quantities of many
metals, including uranium and thorium. Trace quantities of uranium in coal
range from less than 1 part per million (ppm) in some samples to around 10 ppm
in others. The main sources of radiation released from coal combustion include
not only uranium and thorium but also daughter products produced by the decay
of these isotopes, such as radium, radon, polonium, bismuth, and lead. Although
not a decay product, naturally occurring radioactive potassium-40 is also a
significant contributor. Because the half-lives of radioactive potassium-40,
uranium, and thorium are practically infinite in terms of human lifetimes, the
accumulation of these species in the biosphere is directly proportional to the
length of time that a quantity of coal is burned.
Although trace
quantities of radioactive heavy metals are not nearly as likely to produce
adverse health effects as the vast array of chemical byproducts from coal
combustion, the accumulated quantities of these isotopes over 150 or 250 years
could pose a significant future ecological burden and potentially produce
adverse health effects, especially if they are locally accumulated.
Large quantities
of uranium and thorium and other radioactive species in coal ash are not being
treated as radioactive waste. These products emit low-level radiation, but
because of regulatory differences, coal-fired power plants are allowed to
release quantities of radioactive material that would provoke enormous public
outcry if such amounts were released from nuclear facilities. Nuclear waste
products from coal combustion are allowed to be dispersed throughout the
biosphere in an unregulated manner.
Health
Effects on Fisheries & Wildlife
It has been
known for years that mercury threatens wildlife in aquatic ecosystems (from
fish and waterbirds, to fish-eating mammals such as mink and otter). However, a
recent study (Rimmer, C., et al. ÒMercury Concentrations in BicknellÕs Thrush
and Other Insectivorous Passerines in Montane Forests of Northeastern North
American.Ó Ecotoxicology,
14, 223-240, 2005) found that forest songbirds in northeastern North America
have high levels of methyl mercury as well. The scientists theorize that the emissions from upwind
coal-fired power plants deposit mercury on leaves, which in turn are consumed
by the food source for the songbirds. Science has not yet focused on other
species that may be equally impaired.
The proposed
coal-fired power plant is located only a few air miles from the Benton Lake
Wild Bird Refuge. To date,
officials at the Refuge and other US Forest Service officials have not been
forthcoming with public comments about the HGS proposal, probably because they
are reluctant to criticize the RUS, another agency which like the Forest
Service is under the USDA umbrella.
This does not serve the public interest.
This past year
10 bald eagles in Montana have been diagnosed with mercury toxicity from eating
fish tainted with mercury; it was reported that 4 of these eagles have died. These
dying eagles are the modern day equivalent of canaries in the coal mine.
In
conclusion, the coal plant proposal as offered by SME is the wrong technology
in the wrong place in the wrong century. There are too many unanswered questions and too much
inadequate, incomplete, and incorrect information in the FEIS document. This coal plant, if it were ever to be
built, would violate the constitutional rights of Montanans to a Òclean and
healthful environmentÓ. Furthermore, the SME proposal completely fails to
address global climate change and ignores the current political climate in
Washington D.C. US Senate Bill 309
that is being introduced by Senator Barbara Boxer next month will address
global climate change head-on. As
I write this letter HB 753 addressing global climate change is being considered
by Montana Legislature. The U.S. is facing a looming fiscal crisis; our government cannot afford to
guarantee taxpayer dollars to fund such boondoggles. SMEÕs premise of an unmet
need for electricity is without basis in fact. To add insult to injury the proposed
project destroys the integrity of a National Historic Landmark that has been
nurtured by the US Park Service with federal tax dollars. The FEIS document fails to address the
legitimate concerns of Native Americans, and it disproportionately exerts an
adverse impact on children. Ironically (because the U.S. Department of
Agriculture oversees the RUS), HGS jeopardizes prime farmland of statewide
agricultural importance. The SME promise of economic opportunity with a few
jobs is false; this coal plant will chase away far more prospective employers
and job opportunities than it will attract.
This project
is without merit, and this process should be brought to a close now before
facing additional expensive challenges in the courts. The Record of Decision should reflect a resounding No! Should the Rural Utility Service
proceed with a loan guarantee in the face of such widespread and well organized
public opposition, it will reflect poorly on the judgment of officials with in
the Agency and on the integrity of the Agency itself.
Sincerely yours,
Cheryl M.
Reichert, M.D., Ph.D.
Healthcare Team
for Citizens for Clean Energy, Inc.
encl: Published
petition from area doctors and healthcare workers.