March 15, 2007

Mr. Richard Fristik

USDA Rural Development, Utilities Programs

1400 Independence Ave. SW, Mail Stop 1571, Room 2237

Washington, DC 20250-1571

re: Highwood Generating Station FEIS

Dear Mr. Fristik:

My name is Charles Bocock, & my Identifying Number in the FEIS is #C14.

100-16. When I stated in the Draft EIS that the document was “woefully inadequate”, it was a polite way of asking for the truth. I have been told that it is up to the public to point out the “false” statements in the DEIS. The public having done so, I am extremely disappointed that the FEIS still has many shortcomings and flaws. The FEIS “Response” to my comment (page L-90 ) indicates that the RUS will make an “informed decision”. I ASK “BASED ON WHAT?” It is for this reason that I am requesting a Supplemental EIS with accurate, complete, and correct information.

100-16 and 100-17. The FEIS offers two different contradictory responses to essentially the same question:

The Response to 100-16 on page L-90 indicates, “Financial concerns are not covered in detail as they were not brought up as an issue of concern and are outside the scope of this EIS.”

The Response to 100-17 on page L-91 indicates, “The financial viability of the proposal must be demonstrated as part of a prospective borrower’s loan application to RUS, and in turn forms a large part of the RUS review”. “Throughout the EIS preparation phase, the prospective borrower meets periodically with the RUS (both loan and environmental staffs) to update information as necessary. The RUS process assures that the information provided by any prospective borrower is accurate, current and in conformance with standard financial and environmental best practices”.

I ask, “Which Response is correct Number 100-16 or Number 100-17?” The FEIS can’t have it both ways.

Numerous Financial and Environmental concerns were brought up by myself and others in detailed comments on the DEIS. These will be addressed again, now in our FEIS replies. A RUS loan guarantee places federal taxpayers dollars at risk, based upon an inappropriate and incomplete investigation of the facts. The FEIS contains spurious data reported by “technical staff” and consultants hired by SME and Perseus that appear to come from SME itself, although the document’s cover purports it to be the product of the RUS and the Montana DEQ. The lack of the RUS’s own due diligence, shown above by two contradictory responses about financing, will be brought to the attention of our US Congressional Delegation.

500-4 In this section I proposed the water for the coal plant be taken from the discharge of the Great Falls City Waste Water Treatment plant just before it reenters the river. According to your Response on page L-190, PPL does not want the water removed upstream of its hydro-generation units. However, SME does intend to remove the water from the pool above rather than from below Morony Dam.

The litigation and negotiation presently involving this issue will likely cause SME to pay PPL upwards of one-half million dollars for loss of potential power generation for each year water is removed. This is not a part of the R.W. Beck financial projections (copy enclosed), and I doubt that RUS has taken it into consideration either.

In addition, I am appalled that the Secretary of the Department of Agriculture would allow such a large consumptive use of water in our State with a decade long history of drought. In your Response to this same question you also indicate that the entire wastewater stream from a City of 60,000 residents isn’t enough to run this coal plant, and that were it to be used as a water source additional make -up water would have to be added to achieve the full required amount. This coal plant appears to be a most unwise use of an increasingly precious resource.

602-1 & 602-2 Mercury pollution and toxic heavy metals fall out from the HGS onto the Missouri River and deposit downwind on the “Golden Triangle”, which is Montana’s most prized wheat country. The Steubenville study clearly points out the localized area of fallout of mercury from coal plants, and the location of the plant on the Salem site places the water and prime agricultural land of statewide importance at increased risk from the cumulative deposits of this toxic element.

Furthermore, the wind modeling study presented in this FEIS for the wind deposition of pollution is based upon wind studies obtained from the “GORE HILL” airport area. The Gore Hill site is many miles from the proposed actual coal plant site location, and is not subjected to the same air inversion patterns as the Salem site, which is adjacent to the Highwood Mountains. Furthermore, this wind pattern changes with the season. This is yet another example of inappropriate information found in the FEIS. Accredited meterologists queried by Citizens for Clean Energy have said that if seasonal wind row studies were performed at the exact plant site, there would be a very different pattern than the one presented in the FEIS.

Where is the full year wind row study from the actual coal plant site?

Where are the four different seasonal wind row studies from the plant site?

The City of Great Falls during certain times of the year will suffer various fallout patterns from the proposed coal plant, due to different prevailing wind directions. What are the types and amounts of pollutants ? During which seasons and which weather conditions would the City of Great Falls be most subject to HGS pollution?

According to my estimates, the surface volume of water in the Missouri River from below Morony Dam to Fort Benton Montana is over 2,560 surface acres. The town of Fort Benton uses the Missouri River as their primary source of “Drinking Water”. I am concerned that the volume of assorted toxic pollutants from the HGS will have a serious cumulative effect over time on persons, animals, birds, fish and aquatic life and soil.

Volume One Chapter 3 , Titled Affected Environment, page 3-11. erroneously states:

“The Missouri River is listed as not supporting the beneficial uses of aquatic life, cold water fishery, warm water fishery, and drinking water”.

The Missouri River starts its flow below the Town of Three Forks Montana. Towns downstream such as Great Falls, Fort Benton, Carter, get their drinking water from this River. What test were used to determine “Not supporting the beneficial uses of drinking water”?

How has the FEIS determined that a premier “Blue Ribbon Trout River” does “Not” support cold water or warm water fisheries ? I am certain that this question is of the utmost importance for the Montana Fish, Wild Life & Parks Department as well as to the tourism industry.

Soil contamination from the “Acid Rain” of various types and concentrations, falling from the water vapor plume of the HGS Stack over time will lower the soil pH. This constant degradation will impair soil fertility and reduce productivity of farm lands. This would over time compromise Montana’s most treasured wheat producing area known as “The Golden Triangle”.

I think the Secretary of the USDA should be made aware of this, considering the United State’s sells billion’s of bushels of wheat to Japan and other countries.

What type of compensation will be awarded to those farmers whose crops are jeopardized? Why doesn’t the FEIS call for baseline studies of water, air, and soil prior to the plant generating electricity? Is it because farmers who can show that they have suffered Crop Damage, loss of Production and loss of Revenue may have legal recourse against SME?

Will the Secretary of the United States Department of Agriculture be informed by the RUS, that the HGS coal fired electric generation plant will have deleterious effects on the surrounding farm land and “The Golden Triangle” prior to the Record of Decision?

Sincerely yours,

Charles Bocock, co-Vice Chair

Citizens for Clean Energy, Inc.