3/17/2007

Dear Mr. Fristik:

These are my comments on the SME FEIS for the proposed coal plant in Great Falls, Montana.  Please include them in the record and respond to them before the ROD is made.

The FEIS contained no discussion of local deposition of mercury and other pollutants, and in fact, it claimed that there were no such local deposition.  This is clearly not the truth.  The mercury hearings that were held by DEQ/BER received research reports proving local depostion.  This is a very critical subject as regards the people living in the Great Falls area.  The mercury does not just go up to the sky, a large part of it is deposited locally causing increased health risks for the local people.  The purpose of the FEIS is to inform the public and the decision maker as to what will be the environmental effects of the decision.  There is no way the decision make can make an informed decision on this plant proposal as regards local pollution since the FEIS does not include a truthful and accurate discussion about "local deposition of  pollutants".

The FEIS does not describe and give the details of the final air quality permit that will be issued by DEQ.  It does appear from the FEIS that the permit that will be issued by DEA for mercury will not require removing mercury down to .9 lb Hg/TBtu., the current standard.  It appears likely that DEQ will only require removal down to 1.5 lb HG/TBtu based on an old BACT study.  There is likewise no information in the FEIS about this old BACT study.  We have no way to know if the old BACT study is relevant, up to date, or even accurate.  So, as a result, when the decider considers this matter, he or she will have no way to know what will be the mercury standard required for the plant.  This is not the way the process is supposed to work.  The decider must have this information before he or she makes the decision on whether or not to proceed with the project.

It seems quite clear that there must be a supplemental EIS prepared to consider the above issues and such other issues as may be presented in other comments.  Please refuse to approve the project and order a SEIS be prepared that will properly consider local depostion, the mercury standard that will be required if the plant is built, and such other matters that need more consideration.

Thank you in advance for your consideration,and,

Sincerely,

Harriet Marble