March 19, 2007

Richard Fristik

USDA Rural Development Utilities Programs

1400 Independence Ave SW

Mail Stop 1571, Room 2237

Washington, D. C. 20250-1571

RE: Southern Montana Electric Highwood Generating Station

Dear Mr. Fristik:

I submitted comments on the Draft Environmental Impact Statement (DEIS) last fall. In general, I was not pleased with the response I received in the Final Environmental Impact Statement (FEIS) to my previous DEIS comments. I evaluated the FEIS responses and have the following comments.

Vol. II, page L89, 100-15 refers to Montanans’ Constitutional right to a clean and healthful environment. The response did not address the Constitutional rights of the people of Montana. The current environmental permitting regulations do not necessarily protect the people of Montana. The Constitution states in Article IX, Section 1 “(1) The state and each person shall maintain and improve a clean and healthful environment in Montana for present and future generations.” When a plant plans to emit carcinogens, radiation, and harmful chemicals in a place where these pollutants are not presently being emitted, it most definitely impinges on my right as someone who is in treatment for cancer to have a clean and healthful environment.

Vol. II, page L-123, 200-4 discusses the need for a reliable source of base load power for SME’s customers. USDA Rural Development Electric Programs can only finance facilities that will serve rural customers. SME cooperatives’ share of the proposed 250 MW HGS would be 187.5 MW [(0.75)(250) = 187.5]. This amount is more than the share listed in Volume I of the FEIS, Chapter 1: Introduction page 1-19 where it states, “SME would secure an equity position in a new 250-MW facility commensurate with 175 MW of the unit’s total 250 MW. SME would utilize 135 MW of its entitlement to meet load, sell 40 MW of its capacity under the terms of a contract…” I am curious about what happened to the extra 12.5 MW. Does 250 MW refer to the net or the gross power produced by this proposed power plant? SME should have 52.5 MW [187.5-135 = 52.5] to sell to customers outside of its customer base or will need to raise the rates to its customers to break even on power production costs. In Vol. II, page L-123 of the Response section, one finds, “SME is forbidden by law as an electrical cooperative from entering the competitive supply market.” So where else will they dispose of this 52.5 MW of power? The 2-28-07 R. W. Beck, Inc. report, which states its purpose in the heading–Subject: Independent Review of the City of Great Falls Proposed Investment in the Highwood Generating Station, contains the following information: “Additionally, SME has requested point-to-point transmission service for 65 MW over NWE from the Great Falls Substation to the Burke substation in Idaho. This request was made to secure a transmission path, starting in 2011, that would facilitate the sale of excess power from the Project.” By exporting power from the service area of its investor group, SME has made the proposed HGS into a merchant plant, and, as such, the proposed HGS should not be eligible for financial assistance from the Rural Utility Service under its charter.

Vol. II, pages L-145-6, 301-1 addresses Alternatives – Efficiency and Conservation. The response to alternative energy did not seriously consider any of the many very viable and commercially proven non-polluting energy alternatives such as wind, solar, and a definite conservation program. On page 4-55, SME states “that it has and would continue to promote energy efficiency for residential, industrial, and agricultural energy consumers. SME states that it would further develop and implement energy conservation ideas and projects as they are identified and shown to be economically feasible.” The facts do not support this assertion by SME and further illustrate SME’s tendency to promise more than they are currently delivering or have previously delivered. In Table 2-1 on page 2-7, the energy conservation expenditures by SME member system co-ops are documented for 2004. With the exception of the repayments for legacy programs undertaken–in the 1980s and early 1990s–by MPC, the BPA, and others, no expenditures are listed for the Beartooth and Fergus Co-ops and the Tongue River Co-op expended only $26 in 2004. Overall, 88% of the 2004 SME investments for “energy conservation” are for legacy program repayments. It is readily apparent from the expenditure data that several of SME coop members do not have any substantial, active, ongoing energy conservation programs and that SME as an organization is not stressing energy conservation. No mention is made of any net metering or potential payment to co-op members for extra energy production from wind generators, solar panels, etc.

In my comments on the DEIS, I discussed the high level of emissions from the proposed HGS. The answer response I received was that the plant emission levels would meet the standards imposed under Montana’s Clean Air Act. Just because these standards are met does not mean the plant is clean, i.e., relaxed standards result in high levels of emissions. In the article “Healing the Planet”, Guideposts, Jan. 2007, Dr. Matthew Sleeth’s research shows a single power plant in Massachusetts caused approximately 1,200 ER visits, 3,000 asthma attacks and 110 deaths annually. Presumably this power plant also met state emission standards. Assuming the proposed HGS is only a quarter of the size of that power plant in Massachusetts, how can SME and the DEQ and the RUS justify 1 to 27 deaths per year from this merchant power plant? The electricity required by the SME group (250 MW) could easily be provided by about 460 1.5 MW wind generators or three wind farms the size of the existing one at Judith Gap – assuming a 36 percent output level. The three farms could be spread across SME’s generating territory to ensure best operating efficiency. Based on the cost of the wind generators on Airport Hill in Great Falls, the wind farms would cost about a million dollars a MW or $700 million dollars, which just happens to be the cost of the proposed HGS plant. There would be no future fuel costs, and no one need die!

The movement of the physical presence of the proposed HGS plant a few hundred yards so most of the plant facilities are not actually within the boundaries of the National Historic Landmark (NHL) cannot possibly reduce the visual pollution created by the plant. In Appendix G, page 17, the phrase “A primary factor used to determine the landmark’s eligibility for National Register Listing is the undeveloped nature of the viewshed within the defined corridor. Witherell (1984; 8-9) states that the landmark retains historical integrity because, other than scattered modern developments, the ‘portage [route] can be seen largely as Lewis and Clark observed it’” is presented. Placement of a 400 ft stack, a 220 ft auxiliary stack, the 225 ft boiler building, and numerous other structures plus a large coal pile cannot help but detract from the viewshed that Witherell said was an integral part of the NHL. After 30-50 years of polluting the breadbasket of central Montana, locally known as the “golden triangle”, the proposed HGS plans to leave a very visible reminder of its presence. Nine to twelve monofill cells would remain on site as described in Chapter 4 page 4-116 “Once filled and covered, the monofill grid would have a height of roughly 22 feet (7 m) above grade and would have an overall footprint, at the perimeter, of roughly 1,700 ft by 2,600 feet (100 acres).” There is no way to mitigate the proposed destruction of the integrity of our treasured Lewis & Clark National Historic Landmark.

The comment on page 1-26 under Air Quality that this proposed HGS would “be considered a state-of-the-art ‘clean coal’ facility” is inaccurate. If this were a clean plant, the proposed HGS would likely have been eligible to participate in the Federal Clean Coal Technology program as authorized under Section 1307 of the Energy Policy Act of 2005. Since SME is not bragging about being one of the participants in this program, obviously, they are not one of the recipients of money to support “advanced coal electricity generation projects that utilize innovated technologies other than IGCC.”

Another problem I have noticed in the FEIS is missing sections and garbled information. If you check Appendix E of Volume Two closely, you will find that the Table of Contents for Appendix E lists a 12 plus page section 3.0 (Results and Discussion) [of basically the Bison Report]. If you page through Appendix E in the paper volume, the pages go directly from 2-3 to 4-1. Section 3 of Appendix E is also missing from the download version of the FEIS. A typical example of garbled information is in Appendix C of Volume 2. On pages 8 -10 of Appendix C in Volume Two, there are serious problems with formatting, making it difficult to figure out what "government law" corresponds to which "summary." This problem may extend all the way to the end of the section on page C-13.

I remain opposed to the construction of the proposed HGS. Electricity can be generated or conserved in countless ways that have less of an irreversible impact than the proposed SME HGS will have on central Montana and its people. Our neighbors to the north, the Canadians, consider their CFB electrical generation plants to be dinosaurs. I respectfully request that the RUS not loan any funds for the construction of this outdated, ill-considered project, the proposed HGS.

Please consider issuing a revised FEIS or a supplemental EIS to address the questions, concerns, and comments I have listed above. Thank you for the time you have expended on the EIS process.

Sincerely,

Kathleen Z. Gessaman