Richard Fristik

USDA Rural Development, Utilities Program

1400 Independence Avenue SW, Mail Stop 1571, Room 2237

Washington, DC 20250-1571

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COMMENTS  ON  FEIS

Highwood Generating Station

 

I am opposed to the Highwood generating plant because it is an unneeded facility that will pollute our air, water and soil, seriously impair visibility of a national historic site as well as nearby mountains, and bring us higher priced electric power.  Detailed comments concerning things in the FEIS and things not in that document that should be there and were omitted are given in what follows.

 

1.     The need for this new plant has been highly exaggerated.  The projected use for 2005 in the EIS in Table 1-2 in the FEIS is well above the actual use of megawatts of electric power by SME as reported by DOE.  The other projected figures also seem very inflated, especially the huge jump from 2004 to 2005 when DOE reports an increase of about  40,500 MWH while SME estimate more than double that in the cited table.  Indeed, given that the area served by SME is not a high population growth area and given that both residential and commercial customers will be looking at efficiency measures, those numbers of projected use seem highly inflated.  Owners and management of houses, businesses, and factories are likely to use generation facilities such as in-house co-generation and energy saving actions in factories, and residential customers, too, will likely use many methods to increase efficiency and hence decrease cost and therefore also usage of electric power.  Without these things modeled in the projection, the numbers seem more like a wild guess based on history that does not apply than they do on scientific projections.

 

 

2.     The need for more electric power is also partly based on having the residential customers from the city of Great Falls as customers of SME though the Electric City Power Board of Great Falls.  But it now looks like that is unlikely to happen, so the number of customers is much less than predicted.  Indeed, it looks like the capacity of the plant is likely to be two to three times the need even when it is scheduled to come on line in 2011.  Hence the load capacity to customer ratio is high, making this plant very risky to finance.  That risk is not a burden that RUS should place on taxpayers.

 

 

3.     Given the likelihood of reduced need from projections as cited in item 2., the only way for SME to handle 250 MW is to become a merchant plant marketing the excess power to other customers who would want this power.  And given that this is not clean power, even that marketing is not likely in the area served by SME.  The RUS should not be in the business of financing a merchant plant with taxpayer money.

 

4.     The plan to build the HGS is counter to prevailing wisdom these days.  Having essentially one source of power to serve customers makes the customers vulnerable to outages.  Having several sources to provide power for times of  unplanned outages or down-time for maintenance is essential to satisfy and maintain the customer base.

 

5.     The proposed site of the HGS is on or contiguous to the Lewis and Clark National Historic Monument Portage Trail Site.  One cannot mitigate by bribes the damage this would do to the monument resulting in the likely delisting of the site and causing economic loss to the area by decreased tourism.  The RUS should not be financing projects that are counter to the wishes and policies of the National Park Service and national historic preservation projects.

 

6.     In the power mix and too quickly dismissed in the FEIS is wind power.  NorthWestern Energy currently buys power from the new Judith Gap wind farm for an average of $31.16 per megawatt hour or 3.116 cents per kilowatt hour.  Adding in firming power, the average price rises to between 3.6 and 4.0 cents per kWh. This still undersells new coal power by a considerable amount.  These fact are part of the study "Repowering Montana: A Blueprint for Homegrown Energy Self-Reliance" by the Alternative Energy Resources Organization, Helena, Montana.

 

7.     The proposed site for the HGS is in prime agricultural land in the southern tip of the Golden Triangle, one of the best wheat producing areas in the nation.  Some of the emissions will be driven northeast from the plant onto this farmland at the very least contaminating the soil with mercury and heavy metals that are listed in the table of fallout.  Some of the emissions material will fall locally.  One of the pieces of farmland adjacent to the proposed HGS site is in organic production.  The ability for that farmer to continue to produce organic crops is marginal at best.  Other farms and homes located near the site will also experience considerable localized fallout from the emissions.

 

8.     About 80 miles downwind from the plant is the Rocky Boy Indian Reservation.  People there are opposed to this plant since they feel it would be a serious long-term health hazard for their community.  They have a special concern for Mother Earth, and see this as destructive of the environment that is their and our heritage.  Some residents of Rocky Boy have complained that their testimony against the HGS was not included in the FIES.  Our original Americans deserve better treatment than placing a dirty, coal-fired generating plant southwest of the plant in the direction of the prevailing wind and then not including their comments in the FEIS.

 

9.     The proposed HGS will consume as much water as over 40 percent of the residents of Great Falls in days it is producing, according to the figures provided by SME.  Given that we are in a dry cycle and water users all along the Missouri River are asking for more water to serve irrigation, recreation, transportation, wildlife management, and steam bank management, adding a  plant using that much water would be a very bad use of this valuable resource.

 

10.  The problem of carbon emission and the consequent huge addition to greenhouse gases present a major problem.   This is a real financial risk given the likelihood of a carbon tax of some kind.  Even a small tax of $10 per ton of carbon emissions would add over $25 million annually to the cost of production.  Given that wind, solar and hydro power will be unaffected by a carbon tax, that places the plant in even more potential financial risk.  SME has said it would install some kind of carbon capture technology to the HGS, but no such technology exists for this style of CFB plants.  The cost of development and installation would add considerable to the cost of the plant.  The cost of the plant has already risen from $520 million to over $700 million since the first cost estimate was given.  In addition to the cost, SME has at this time no developed plans for sequestering the carbon even if the capturing mechanism can be developed.  This whole area adds to the cost and investment risk of this plant.   Coal-fired plants are already at risk for financing due to the current AdministrationÕs directive not to finance coal-fired plants in the era of the global warming crises.

 

11.  The SME officials in new making announcements claimed they would be able to sequester the carbon, but this has never been done in a CFB plant and no one was working on this project at the time of the announcement.  This touting of undeveloped technology at the same time criticizing the IGCC technology because it was unproven, a false claim, was at best disingenuous of SME officials.    If one must burn coal, and thatÕs not at all clear as many companies and communities have found, letÕs at least use the best available technology.  That technology is IGCC which is inherently cleaner and more efficient in nearly every way than is CFB. 

 

12.  Given the importance of the carbon emission issue on the financial and technical implications of adding an entirely new, unproven carbon control technology, it would seem reasonable for RUS to require a supplemental study on this matter for the EIS.

 

13.  The placement of a coal-fired plant near Great Falls has not only the health related problems associated with it, there is also the economic problem of people choosing not to move here because of the negative affect it would have on the quality of life in Great Falls.  To be ÒgreenÓ and live in communities that values ÒgreenÓ products will be a strong consideration in the near future for many people.  That is not a risk that should be placed on Great Falls and the surrounding area with the HGS preferred site. 

 

14.  An associated press story dated March 14, 2007, discussed a recent report from MIT concerning the bleak future for coal in energy production unless fundamental changes can be made in the process so emission are not longer a huge problem for the environment and for the human race, especially children.  Again, this is not the kind of risk that RUS should assign to taxpayers by guaranteeing a loan.  There are much wiser investments in much better technologies.

 

15.  The activated carbon mercury capture equipment, while promised by SME to be part of the plants emission controls, is not given in the FEIS.  After the first claims that this equipment would be part of the initial installation, the proposers back off that promise to say that the plant would be run for a period, perhaps 18 months, to see what the amount of mercury emissions really were.  But this is using the citizens of the area affected as well as the environment as an experiment that should be carefully conducted prior to construction of the plant.

 

 

16.  The Highwood power plant, if it is built, would not be the clean plant that SME officials claim it would be. The FEIS indicates that every year it would emit

                  40 pounds of mercury,

                  443 tons of sulfur dioxide,

                  1,177 tons of carbon monoxide,

                  366 tons of particulate matter,

                  62 tons of sulfuric acid mist,

                  24 tons of hydrochloric acid gas,

                  38 tons of volatile organic carbon,

                  3,052,081 tons of carbon dioxide,

and, in additional, there will be some radioactive emissions as well as contaminated dust particles from ground sources blown about by the strong winds experienced routinely at the proposed site of the HGS.  This is hardly the kind of neighbor those living in the vicinity of the site would want to have.

 

In summary, this is a dirty and fiscally unsound plant which should not be built, here or anywhere else.

 

 

Ronald M. Mathsen, PhD