January 10, 2008

N36

xH34(LECL)

Cascade County Board of Commissioners

Courthouse Annex
325 2nd Avenue, North
Room 111
Great Falls, Montana 59401

Commissioners:

The National Park Service has learned your board is again considering a zoning change for Township 21 N, Range 5 E, Section 24 and 25. It is understood that this designation change, from agricultural to heavy industrial, is being considered to accommodate construction of Highwood Generating Station (HGS) proposed by Southern Montana Electric and Transmission Cooperative, Incorporated (SME). We are also aware the majority of this project’s funding would come as a loan from U.S. Department of Agriculture’s Rural Utilities Service (RUS).

The National Park Service and Lewis and Clark National Historic Trail oppose the proposed re-zoning action. The Secretary of Interior’s Section 213 report, Evaluation of the Impact of the Proposed Highwood Generating Station on the Great Falls Portage National Historic Landmark, issued to the National Advisory Council on Historic Preservation (ACHP) concluded:

The integrity of the NHL is based mainly on its current condition of large, open, historic and natural landscapes relatively free of intrusions. The proposed HGS and its ancillary features would constitute a broad and wide-scale impact on the surrounding landscape. In such an open landscape, the HGS cannot avoid, minimize, or mitigate adverse impacts sufficiently to maintain the integrity of the NHL.

In June, 2008, shortly after the aforementioned Section 213 submission, the ACHP sent a letter to the RUS in which they requested:

…careful review of the information and recommendations of the [Section 213] report and re-evaluate the preferred alternative. When this is done, please advise us of your conclusions and we will determine how to complete the Section 106 review in this case.

It should be noted that Section 106 consultation has not yet concluded.

Despite the claim “significant mitigation measures are planned to offset the impacts of the HGS,” (on page 24 of the Application for Rezoning), it is our belief that HGS cannot be mitigated at the Salem site and such construction would result in delisting of a most, if not all of the NHL. It is our position that RUS and SME should investigate other sites which lie outside of the NHL and its viewshed. Until the Section 106 consultation process has definitively determined an acceptable construction site, we believe it is inappropriate for Cascade County to rezone land in preparation for the Highwood Generating Station project.

Respectfully submitted,

Stephen E. Adams

Superintendent

DWiley:rsw:1/10/08