March 19, 2007

Richard Fristik

USDA Rural Development

1400 Independence Avenue SW

Room 2237

Washington, DC 20250-1571

RE: Highwood Generating Station FEIS

Dear Mr. Fristik:

Once again citizens are asked to peruse in detail a very large document,

this time over a thousand pages. Most people, I am sure, are simply

willing to throw up their hands in defeat rather than try to comment on

it. The feeling of hopelessness is exacerbated by the distinct feeling

that the RUS is poised and ready to issue its ROD in favor of this

project, notwithstanding the input of the public. I will, however, take

this opportunity to thank you for granting us an extra WEEK in which to

peruse this tome, because of the repeated error of an incorrect address to

which to send our remarks.

This FEIS is a sterling example of government waste. Not only is it

prepared with skewed data, it doesn’t contain many analyses I would deem

essential to a fair assessment of this project. (such as weather patterns

at the actual site, not from the top of Gore Hill) This document assumes

that as long as the extant regulations are met, then by definition there

can be no deleterious effect. The future health of our community and the

true viability of this coal-fired plant need to have a true assessment,

not just a circular referral to the regulations. Our city tells us they

don’t need to do any due diligence; the county tells us that environmental

protection is not their job; and the people proposing this plant are busy

successfully lobbying the state government to make sure the regulations

are as lax as possible. Federal environmental regulations have already

been gutted. Therefore the whole process is about politics and

expediency, not truth.

There have been no studies done on soils in the area of this plant. Are

you aware that this plant is sitting in the middle of prime agricultural

land, and actually abuts an organic farm? Have any studies been done on

acid rain and other poisonous pollutants, and how it will reduce yields

and quality of the wheat grown here? Our wheat is some of the most

sought-after in international markets. The organic farmer has already

been told his products will not be suitable for his customers should the

plant be built. Is it the job of the Department of Agriculture to destroy

farmers’ livelihoods? I brought this matter up in my comments on the

DEIS, and I was “reassured” that this plant met regulations. Can you be

sure that simply because the plant’s effluent will meet regs, there will

be no ill effect?

Are you aware that this plant is massively oversized for the need, and

will therefore be required to sell its excess power on the open market?

This is by definition a merchant plant, and it is my understanding the RUS

is not supposed to be supporting such plants.

The FEIS says that most of the impacts of the HGS on its surroundings will

be adverse and “non-significant.” I realize there is an official

definition of “non-significant” somewhere, but I am not convinced that the

effect will, in fact, be “non-significant.” And by the way, the

discussion on the effects of this project on fauna is totally missing.

The adverse socioeconomic effects I spoke of in my DEIS comments were

admittedly not addressed. Am I supposed to be comforted that because

Great Falls has a history of heavy industry, it’s okay to re-introduce it

with all its accompanying problems? We are just barely recovering from

having that smelter here, and the refinery is repulsive but what can we do

about it, it’s here. Choosing at this late date to make another of these

things, in this time of very negative public opinion, is ridiculous. Our

history of heavy industry was from a time when such industry was tolerated

and even embraced as a sign, or a price, of “progress.” Nowadays we know

better. Great Falls would be much more appealing if it were seen as

progressive in the area of energy production, rather than regressive.

Coal plants are being fought all over the country; people don’t want them!

The historical industry in this city has left us with five Superfund

sites. That is the legacy of heavy industry. The future of Montana is

better served by preservation of what we still have: clean air and water,

abundant wildlife, unique history, and breathtaking views. This plant

does not fit in with our vision for our city. Further, studies show that

“green,” renewable industries generate more prosperity and jobs, and

foster a higher quality of life, than fossil-fuel industries. Yes, Great

Falls can and should have industries, but burning coal is just foolish.

Putting this coal plant here just destroys the true treasures we have.

And speaking of treasures, this thing is destroying a National Historic

Landmark, the Lewis & Clark Portage site. The FEIS does in fact admit

that this project has a significant negative impact on the historic site.

SME’s proposal to bribe the Lewis & Clark Interpretive Center hardly

amounts to mitigation, and attempts to make the plant “blend in” by

painting it “earth tones” and planting a few trees would be laughable if

they were not so insulting.

I believe a Supplemental Environmental Impact Statement is required in

this case. The socioeconomic impacts have not been properly assessed; the

effect on local soils and agriculture has not been properly assessed; the

customer base is exaggerated, as the citizens of Great Falls cannot by law

be customers (not that I would want to be; and it is a very bad idea to

have only one source of power); the advisability of building a CO2-spewing

behemoth has not been addressed. And speaking of CO2, Gregori has

promised the Governor that he will consider new technology to address this

issue. There are NO specifics on how this might be done in the FEIS. In

light of SME’s very publicized promises to “capture” carbon in this

project, a Supplemental EIS needs to be done to assess this.

Thank you for this opportunity to comment. I am sure you will thank me

for my comments, as you did before.

Hilary Ransdell Lewin