On January 21^st I was invited by Jeffrey Chaffee an environmental engineer that was (is) contracted by Southern Montana Electric (SME) to discuss all the scientific and common sense issues surrounding the purposed Highwood Generation Plant. In all scientific papers there are disclosures of possible bias, but none were provided in his January 21^st article. So Mr. Chaffee is paid by SME and his views should be taken as such.

Mr. Chaffee referenced to my original January 8^th article as not following “science”. My illustrations in that article are the “science” that the best scientists and public health professionals made starting 3-4 decades ago. So Mr. Chaffee, lead and mercury policies for the elimination from gas, paint and child vaccines were acted on by multiple studies showing substantial risk and politicians and professionals making policy to eliminate lead and mercury from products that children are exposed to in their use. I call that pretty good science and pretty good policy.

Your firm Bison Engineering has worked with gas, oil, coal and power companies that by your 1/21/07 article have the altruistic interests of the people and their health set by government you lobbied. And the threshold of substances that are know to be extremely toxic to the body and especially the developing brain that even the EPA, United Nations, European Union and Canada categorize as “extremely toxic with cumulative effects”. So your firm knows all about the cumulative effects of one of the most neurotoxic substances and that the threshold is acceptable? Are you ready to bring you family to Fort Benton and live down wind of the plant? It’s nice living in Helena and being paid by SME to make such statements.

Western Europe took out all lead from gas and paint twenty years before the USA did because US industry knew better and lobbied to use lead as long as they could. US tobacco firms did the same on any regulation of tobacco and took until 1964 to put any warning on a pack of cigarettes.

So scientist Mr. Chaffee, the problem is NOW even without adding the HGS to the total worldwide emissions of mercury, particulate CO2, CO, sulfur and nitrogen …. 1 out of 5 women of childbearing age RIGHT NOW have enough mercury in their blood stream to be defined as “at risk” for their fetus defined by the EPA. This was from University of North Carolina study of women in 2005 across the USA. Is it accurate to state that adding to a risk with more mercury emissions is not a good idea? From United Nation Environmental Programme the sources of world wide mercury emissions are mainly from man made sources (man-made mercury: natural mercury emissions): 3.3 to 1 at high estimate to 2 to 1 most recent study. So we can see that man-made mercury is contributing to the cumulative effects that are making lakes, rivers and the oceans unsafe fisheries for our consumption.

A study done by Mount Sinai gave an accounting that mercury emission from coal power plants cost the USA in lower IQ in children of 1.3 billion dollars in decreased productivity. In the USA we emit more mercury than any other country in the world per capita (380 mg per person per year). The University of Texas has a study showing a significant increase of autism and special education rates with increased released mercury in the environment.

Mr. Lee of Yale University has a study last year that through tracer analysis that spikes of as high as 75%, almost doubling of mercury in air came from coal power plants in the New England area.

The Fores islands out in the north Atlantic with a stable population that have fish as a main staple was extensively studied to find any relationship to mercury and child development. They found mercury in the blood even at very small levels would cause impact on a children’s IQ. This study was the basis for the EPA’s recommended threshold for mercury. Other studies show the placenta magnifies mom’s blood mercury by the factor of 1.7, almost doubling the amount of mercury to the fetus, which has led to further consideration to what is the “threshold”.

The scientific community knows a lot more about mercury and how it destroys brain cells and how it accumulates in a living organism. Anyone can google search “mercury” and see EPA and other health organizations reports on mercury and it’s dangers.

If the trends in asthma and autism were declining with Mr. Chaffee’s “below threshold” forecast but they are not! Asthma has doubled in past 20 years and Autism has also shown significant increase.

Mr. Chaffee stated the 2018 state regulation for the forecasted 20 pounds of mercury emission (0.9 lb/TBtu) at HGS. So yes as the law as written in 11 years from now and 7-8 years after the plant is built it should conform to lower emissions standard but if it is able to burning lignite coal (?) and if the billions gallons of water are available from the Missouri River in the future (? climate change, other river community needs, population growth). Maybe the plant will make that goal and maybe it will not. And if it doesn’t will a 500 million dollar plant be closed or will it still continue emitting at unacceptable levels. Lots of money and lots of liabilities are on the table, do we really need to gamble. Now from the day the HGS starts production to 2018 it will be allowed to emit 40 + pounds of mercury a year (1.5lbs of mercury/TBtu/year).

For Mr. Chaffee let us talk about common sense issues, alternatives for economic and energy development. All should be included because in Mr. Chaffee assumes that Coal Fired Power is the only alternative for the SME and the city. In all the environmental impact studies for HGS the “Best available control technology” will be used. BACT is what? Wind, Hydro, Geothermal, NO! In the “windiest city” SME did not consider “BACT” that is health risk free. If Great Falls has assets then use them, make jobs and economic growth without the liability. Investment in coal is not BACT nor is it our future! Investment in wind and hydroelectric are our future and the worlds future.

So Mr. Chaffee “the science” of Mercury is that risk is here and now with 1 in 5 woman having risk to their fetus, Mercury is classified as a toxic substance, that coal produces more mercury that any other source, that SME and the city are not proposing BACT and that the health of children are not fully addressed by your commentary “below a threshold” because children’s health is not worth risking. And for the public you express your opinions to should know who pays for your words and opinion, Southern Montana Electric SME. So for 1/21/07 article ‘Thank You SME for misleading the public'.