March 18, 2007

MEMORANDUM FOR

Richard Fristik, USDA Rural Development, Utilities Programs

1400 Independence Ave. SW, Mail Stop 157, Room 2237

Washington, DC 20250-1571

Prepared by: Great Falls citizen members of Socioeconomic Environment Team

Citizens for Clean Energy, Inc.: Pamela Morris, Kathy Fisher, and Sandra DiMauro

“Citizens for Clean Energy, Inc. (CCE), recently incorporated under Montana law as a non-profit corporation, is a fast growing network of Montana citizens whose objective is to convince our decision makers that clean, efficient, and cost effective energy is available for our communities and must be the preferred alternative to coal fired plants in Montana. What unites us is a very deep concern about the harm these coal fired plants causes to our local and world environments.” { http://cce-mt.org}

SUBJECT:

Socioeconomic Environmental Impact Analysis of Environmental Impact Statement (EIS)

of Southern Montana Electric (SME) proposal for Highwood Generating Station (HGS), Great Falls, MT

OUR FINDINGS Regarding the FEIS Address:

• lack of proper socioeconomic assessment: the standards the EPA has been using have not been adequate to the purpose;

• existing socioeconomic environment of the Cascade County/Great Falls community;
• likely adverse socioeconomic environmental impact to the Cascade County/Great Falls community;
• inadequate consideration of citizen comments;
• omitted impacts on tourism, fishing, recreation;
• weakness, neglect, omissions, and possible bias in the EIS;

___________

-Unless otherwise noted, all citations are from the FEIS.

-Abbreviations and terms used correspond to the FEIS, Appendixes A and B

________________________________________________________________________________________

A. Issue: Lack of proper socioeconomic assessment: {1-29, Issue 13: Socioeconomics}

• the character of the existing socioeconomic environment of the Great Falls/Cascade County area has not been accurately assessed;

• the impact of direct and indirect employment associated with construction and operation of the power plant has not been adequately projected and quantified.

1. A reasonable study has not been conducted.

The EIS states, “Construction and operation of the proposed power plant would entail impacts on employment, income, taxes, property values, and population in the Great Falls area”; yet, “no social surveys have been conducted for the EIS.” (4-130)

2. The EIS incorporates weak references out of context.

The credentials of the person/source of the following EIS statement is questionable, as is the accuracy of his(?) opinion as to the character of the Great Falls community.

The following opinion is cited as, quote: (BSF, no date) Big Sky Fishing.com No date.

Great Falls, Montana: History.

“Accessed 12/8/05 online at http://www.bigskyfishing.com/Montana-Info/great-falls-history.shtm.” (6-5: References Cited)

“The changing nature of Montana’s economy, from one based on raw materials extraction, manufacturing and agriculture to one based on tourism and services,

has largely bypassed Great Falls. (BSF, no date).” (3-108) [underline is inserted]

By accessing “bigskyfishing.com” website, one reads following, quoted here exactly as written:

“This travel guide section is really less a true "travel guide" than my own personal opinions and experiences about each city, Great Falls is an interesting city… a very scenic town, sitting as it does right along the Missouri River in Montana.” {http://www.bigskyfishing.com/Montana-Info/great-falls-history.shtm.}

However, one does not learn the identity or credentials of the author, “bigskyfishing.com.”

Nonetheless, most of the EIS’ description of the Great Falls community is taken directly from this

same anonymous source. [See “http:bigskyfishing.com”.]

3. An Accurate “Brief History of Cascade County and Great Falls,” using data supplied in the EIS, shows that the nature of community has indeed evolvedfrom an industrial to a service based economy.

During the industrial “boom” decade of 1950-1960, the population of Great Falls mushroomed from 53,000 to over 73,000. This growth occurred largely due to an active copper/zinc processing smelter, an expansion of the Malmstrom military base, and a vigorous agricultural economy. But after 1960, this boom fizzled with the closing of the smelter, a reduction in the size of the military base, and a depression in the agricultural industry.

But although these industries declined, the community did not. Instead, Great Falls experienced a community-wide transition to a professional service-based center with a county

population of 80,000, a 44% population growth from 1950. The city of Great Falls is now an urban service center with a stable population of over 55,000 that principally supports small

business, professional enterprises, medical and educational institutions, recreational activities, and tourism opportunities. [See EIS Table 3-28.]

While the city population has remained fairly constant even though the size of families has decreased, a growing number of people are opting to settle on a few county acres, thereby increasing land values, or in small communities within commuting distance to the city,.

A productive, stable society, the community’s employment rate has remained over 95% since 1995 and is currently increasing to +98% , according to the Great Falls Tribune, February, 2007,. [See FEIS Tables 3-30,1,2,3.

“Some 1,400 retired military people live in the Great Falls area.”(3-107) This is a community which provides a safe, stable, productive, and affordable lifestyle to a relatively large percentage of military and professional families, business personnel, students, tourists, and retirees. [See 3-110, Table 30.]

4. An excellent, up-to-date, comprehensive description of the areas’ socioeconomic environment in given in the Great Falls Tribune publication Guide to Great Falls and North Central Montana, March 18, 2007, “Everything you need to know about living, working and playing in the Great Falls area.”

5. According to the Great Falls Development Authority, Great Falls is thriving

Welcome to Northcentral Montana. Our region saw a lot of growth over the past year and it’s really no wonder why. This is an area that’s ripe for business opportunities of any type. Our beauty and natural resources alone have proven to be reasons enough to consider relocation or starting a new venture here.

Recent boosts to the Great Falls economy include Calgary based AvMax’s new aircraft maintenance facility (first outside of Canada), Cable Technology Inc.’s new cable and wire harness design and production facility, and St. Louis headquartered Centene Corporation’s brand new 250-employee medical-claims processing center.

These companies all found that the business friendly climate in Great Falls was perfect for their ventures. Chances are you’ll find the same for your project. Whether your major concerns are finding affordable commercial real estate and utilities, technological infrastructure or a strong available workforce, you'll find it here. And it all comes with the peaceful quality of life that's made Montana one of the most desired states in which to live.

Please check out our website, and feel free to call or write for more information.

Sincerely,

Brett Doney, President bdoney@gfdevelopment.org

http://www.gfdevelopment.org/ March 13, 2007

6. The following picture and comment accurately depict the open prairie, clear blue sky, and appealing nature of the city of Great Falls.

Looking Down on the Missouri River and Downtown Great Falls

This photograph shows the Missouri River as it cuts through Great Falls, Montana. Also visible in this photo is the historic Milwaukee Road railroad station tower - now nicely restored and visible from pretty much anyplace in Great Falls. Also note how quickly the town ends and the prairie begins on the hills above town. {bigsky fishing.com}

B. Issue: Probable De-Stabilizing Impacts of the SME Proposal:

An Adverse Environmental Effect/Affect

1. The Proposed Action, construction and operation of a CFB coal facility (HGS), would have a probable, significant, medium and long term adverse impact on local and regional socioeconomic resources. The likelihood of an adverse impact on the potential of localized (regional county) population growth is possible, if not probable to a major extent in the medium-to-long term. [ Underlined terms are defined in J-22, 23.]

2. The FEIS assertions that the No Action Alternative “is not an adverse impact” is true; however, a significantly erroneous conclusion follows: “but rather a lost opportunity to realize economic benefits to the local community from the Proposed Action.” (4-125)

The Cascade County and its neighbors would experience increased costs of many social programs, such as law enforcement, emergency services, fire, medical, counseling, and legal services which would be a far greater burden than “the direct and indirect economic benefits from investment in the local economy and short-term (construction) and long-term (operation) job creation” alluded to in the EIS.

EIS facts: From 300 to 550 workers would be employed for four years to construct HGS. “Based on a rough estimate that 75 percent of the power plant construction workers required would come from outside the region (SME, 2005j; Warren, 2004), the Great Falls area would see an increased demand on rental housing.” (4-127) An additional 200 jobs would evolve to support the construction and workers: thus, a total of 600 temporary workers. “However, these jobs would be temporary and would last only for the duration of the construction phase of the project.” (4-128.)

3. Fallacy of EIS Assertions: The Boom Town Affect

Boom towns are actually impacted negatively with the influx of the temporary workers. The cost of everyday living goes up because the temporary construction workers would make more money than the regular Great Falls area population earns. Local businesses would have problems hiring because they could not compete with the higher wages being offered to the construction people.

Also, typically, temporary workers do not have a vested interest in the community, but do require community services, such as emergency , fire, medical, counseling, and legal services, and law enforcement. Importantly, not addressed in the FEIS is the fact that the inevitable increase in social service requirements due to the influx of temporary workers would probably cost the community more during the project’s construction period than the FEIS’ touted positive revenue assessment would produce.

As to medium and long term assessments of the proposed project, although a HGS would create an additional sixty-five permanent jobs, a sudden departure of 300-550 construction workers would be even more costly, especially since significantly more people, largely professional people, would not choose to live here once a coal plant is sited in this area.

Therefore, the EIS assertion that “workers and jobs would be an economic boon to the community” (4-127, 128) is not accurate.

C. Issue: Public Perception: Another “Dirty Coal Town”

Perhaps an even greater danger in implementing the Proposed Project is the possibility that the community might revert to its 50’s (dirty) industrial based community, for who would want to live or even visit here? -not the doctors, not the teachers, not the artists, not the retirees, not the students, and not the tourists!

Great Falls would be perceived as another “dirty coal town,” the kind of community that many current residents chose to leave in order to locate here where the quality of life is superior! A thorough look at the citizen comments to the Proposal would confirm that a significant number of local citizens do not want to live in the area of a coal plant. The quality of life and environment this community now has to offer would be inexorably altered. In other words, folk like the majority of those who have chosen to locate here in the past few years would not choose to locate here (near a coal plant) Thus, growth in this community would suffer.

That HGS would be a strong disincentive for growth is further supported by the still increasing volume of such public comments that are continuing to be generated about this proposed coal plant.

D. Issue: Inadequate Consideration in the EIS of Citizen Comments

1. A significant number of timely submitted oral and written comments are either not addressed in the FEIS or overly edited.

2. A great many of the Responses do not sufficiently address the stated concerns.

The following is one, of many instances, of arbitrary and capricious consideration of citizen comments: the EIS response, below, obviously does not address the comment of concern: only part of the ten comments from fourteen different citizen ID’s are offered below, but most of the EIS response is included here. [See EIS, SOC-1600, #1.]

[As per the FEIS, comments are given in italics and responses are bold faced. Our concerns are offered in regular font.]

[Comment] The DEIS is too limited in scope and does not talk about the huge issue of perception. … Many Great Falls residents live in this area by choice…. They value the quality of life our clean environment offers. A significant number of them would not choose to live and work in a community affected by a CFB coal plant.

[Response] “The DEIS did not include the type of social impact analysis that might have gauged resident’s perceptions about or attitudes toward the proposed plant.”

[Our opinion] Since the reputation of a community has significant influence on its potential for growth, the issue of perception must be addressed, for the SME proposes a course of action that would affect the potential growth of the community. The EIS fails to address the several comments of concern about perception, but instead merely continues its response with an explanation of technological aspects of the RUS process. In fact, most of the Responses in the EIS ignore important socioeconomic environmental considerations.

[Response #1 continues] Many comments have been received that express some opinion toward the plant in terms of its ‘cleanliness’, the efficiency of the proposed combustion technology, and its potential effects on health and safety. These opinions, as expected, cover a wide spectrum, from total opposition to total support. In considering SME’s loan application, RUS must consider the proposed design and combustion technology in light of the current industry standard. Although CFB combustion has been in use for some time, it remains among the cleanest current methodologies in terms of emissions and combustion efficiency, and also one of the most reliable. Other technologies such as IGCC are on the verge of full commercial viability, but at this time, or in the near future, do not present the level of certainty required on the part of SME and RUS.

[Response concludes] In various public … comments received, the possibility of large numbers of residents re-locating due to the HGS has not been raised as an issue of concern.

[Our opinion] “Relocation” is but a minor part of a change in the demographics of a community, as alluded to in numerous citizen comments. Yet, even “relocation” is given short shrift in this EIS comment. The EIS is charged to describe potential growth-inducing or growth-inhibiting impacts. No where does the FEIS accurately address this very real concern. In truth, Cascade County has transitioned from an “industrial-base” to a professional service-based community. Growth is accelerating, fueled by the arrival of increasing numbers of people who value the uniquely safe, clean life-style offered here: professionals particularly in the fields of medicine, education, the arts, and small business; retirees; and tourists. Therefore, the likelihood of a major adverse impact on the potential of localized population growth is highly possible.

5. None of these likely occurrences are addressed in the EIS, which, therefore, determines erroneously: “Overall, the construction of the HGS at the Salem site would have a primarily positive or moderately beneficial effect on the socioeconomic environment of the local and regional area”; rather than an adverse medium to long term effect (cause) and affect (result) on the socioeconomic environment of the local and regional area.

E. Issue: Tourism, Fishing, and Recreation Impact Concerns: HGS will have an adverse impact on our tourism and fishing attractions. Many tourists come for the fishing and beauty of the open landscape and visible mountain ranges.

1. Rivers, Streams, Parks, Lakes, and Springs: According to the EIS there are not any bodies of water that will be adversely impacted by the plant. How about Belt Creek, the Missouri River, Benton Lake Refuge, Wadsworth Park, and Giant Springs?

• Almost every year Wardworth Park has a Fishing Derby. The Lake is stocked so the kids can catch fish. After the plant is built and there are high mercury warnings, that will have a negative impact on such community activities.
• To claim that there are no meaningful fishing opportunities on the Missouri River and in Belt Creek are absurd. Both Belt’s Sluice Box State Park and the Missouri River are popular “blue ribbon” trout areas.
• The aquifer drains nine miles south of the Salem site and 1 mile ESE of Industrial Park toward the Missouri River and Giant Springs, so the fish hatchery there would very possibly be jeopardized by mercury and other toxic waste dispersals from HGS.
• Nesting sites for birds and family recreation would be threatened by contamination to the Benton Lake Refuge.

2. Endangered Species: Certainly, the EPA and Fish Wildlife and Parks should be concerned about the possible impact of HGS:

· The EIS mentions the bald eagle, but does not address the fact that the entire range of some pairs encompasses the most heavily HGS impacted fallout area.

· No consideration is given to cutthroat trout. FWP are working hard to develop cutthroat populations in the Highwood and Little Belt Mountain.

· No mention is made in the EIS to the danger to the pallid sturgeon due to the further depletion of water to the Missouri River downstream.

3. Air Quality and Viewshed pollution will discourage use and development.

· A state-of-the-art soccer field is being built less than eight open miles from the Salem site.

· On the River’s Edge Trail eastern pathways are being further expanded on both sides of the river to provide even more wholesome outdoor recreation for all ages.

· The River’s Edge Trail will lead to Soda Springs, where Sacagawea was healed, and which features a view south to the Lewis and Clark Portage Route, now rated as the most endangered of the seventy-some National Historic Landmark sites. Here, a rare open vista which will be sorely and permanently destroyed by the 20 story HGS and 30 foot tall artificial coal and waste mounds at the Salem site.

· Of course, the Lewis and Clark National Historic Landmark, this historic national treasure, will be permanently scarred; its natural character inexorably altered, a travesty that responsible federal agencies must not permit.

F. Issue: Economic Socio-environmental Concerns: The economic feasibility of the HGS is a gamble that society cannot afford to take, for the possible consequences of an unsuccessful outcome are far more adverse than the possible (unlikely) gain.

1. SME has expressed great concern about its purported shortage of estimated energy supplies. Similar concerns of energy shortages spawned Colstrip 3 & 4, along with huge cost over-runs. These two plants came on line just in time to contribute to a surplus in the regional power markets. The customers ended up paying higher prices, and Montana Power sold Colstrip 4 to the city of LA at a discounted price. Highwood Generating Station’s 250 MW plant will prove again that history repeats itself.

2. HGS would cost $168 million to operate per year. HGS would need about half as much water as is consumed by the entire City of Great Falls: enough for about 26,000 people. Such commitment of these reserve water rights, along with HGS’ sewer and rail system commitments, will forestall the ability of the City of Great Falls to capture and serve other growth opportunities.

3. With the alarming information on global warming, HGS sets the course to be part of the problem, rather than part of the solution. Current promises by SME to implement carbon capture technology are merely meaningless diversions, as are SME’s other promises, unless these promises are legally guaranteed and enforced.

4. Given the nature of “boom-and-bust” economics and the socioeconomic character of the greater Great Falls community, only a few people might profit from the HGS proposal, while the majority of citizens would assume considerable risk!

G. CONCLUSION AND RECOMMENDATIONS:

The FEIS for the HGS fails adequately

1. to comply with a number of relevant laws and regulations
2. to apply EPA standards to the environmental impact.

3. to list and describe the responsibilities of federal, state and local agencies that have jurisdiction over several aspects of the Proposed Action

4. to describe potential growth-inducing or growth-inhibiting impacts

5. to describe the economic and environmental costs of the Proposed Action

6. to describe the relationship between local short-term uses of man’s environment and the affect on maintenance and enhancement of the long-term productivity of the environment

7. to evaluate the impacts on private property

8. to address major questions, such as

· What is the need to be met?

· In what ways could the need be addressed?

· How would these courses of action affect the environment?

· What could be done about those effects?

· What do others think about these alternatives and their impacts?

[See FEIS 1.2 NEPA and MEPA Processes]

Also, the 3 studies required by RUS and prepared and submitted by SME are not sufficiently complete for RUS to make a truly informed determination as to the feasibility of the proposed project. {See FEIS 1.2 –“Key Agency Roles, Responsibilities and Decisions}

Therefore, Citizens for Clean Energy, Inc. (CCE) requests that either the “No Action Alternative be assigned in the ROD or a Supplemental EIS be ordered before an ROD is issued. It is also understood that the RD’s decision whether to finance the Proposal is subject to the completion of all environmental review and loan requirements.

Most respectfully,

Socioeconomic Environment Team Coordinator, Citizens for Clean Energy, Inc.

Pamela June Morris

2201 8^th Avenue North, Great Falls, Montana 59401

(406)453-2336 E-mail can be sent to: pml@imt.net

Background includes:

Morris family business in Great Falls: 1913-1976

BA Humanities - University of Great Falls; MA Guidance and Counseling – MSU-Billings Retired from teaching English, 30 years, public schools and university, Billings, MT