November 14, 2006

Mr. Mark Plank, Director

Engineering and Environmental Staff

Federal Preservation Officer- Water and Environmental Programs

Rural Development, Development Program

1400 Independence Ave, SW-Mail Stop 1571, Room 2240

Washington DC 22050-1571

Dear Mr. Plank:

I am writing a reply to the letter sent to you by Mr. Gregori, Southern Montana Electric, Generation & Transmission Cooperative, Inc., October 10, 2006. And in particular I am referring to the statement under IV. Degradation of the quality of life in North Central Montana: the last paragraph, p. 27, which states that:

“Southern Montana Electric G&T has been proactive in meeting with local groups concerned about the impact of HGS on the Lewis and Clark Trail National Historic Landmark.”

First, this has nothing to do with the “quality of life” in north central Montana but his organization is endangering a precious heritage site important to our nation’s history. In fact, I am very concerned about the disastrous impact as the result of the proposed Highwood Generating Station, near Salem. The National Historic Landmark site of the Great Falls Portage route is totally ignored by SME and city of Great Falls officials. In a few days, the Cascade County Commissioners are considering to rezone sections 24 and 25 from prime agriculture to heavy industry. They are making an exception to their recent adopted Cascade County Growth Policy Manual, September 16, 2006. Duane Urquhart who is the current property owner has applied to change this agricultural designation because it is allowed when his land received the “special” district status.

There is no question that the location of the HGS plant endangers the Great Falls Portage route to such an extent that it is beyond “reasonable mitigation.” The visual features of its historic landscape integrity so enjoyed by members of the Lewis and Clark expedition and others since will be destroyed. The location for the actual site is eight miles northeast on and astride of the Great Falls portage route. The zoning change will mean that the heavy industrial site designation is surrounded by agricultural lands. The construction plans for the proposed Highwood Generation Station calls for a series of buildings, a 400 feet smoke stack, a coal pile, a circular railroad track, a series of ash cells and, as the photographs displayed on the cover of the 2006 DEIS, a security fence/wall will be placed around the property. The features of the terrain along the Salem road will destroy the views east of the Highwood Mountains and towards the south the view of the Little Belt mountains. Both the 1966 and 1984 historic landmark application and designation state very clearly that the Great Falls Portage route is part of other Lewis & Clark sites in the immediate area. The additional proposed plans for the construction of an eight mile sewage/water line, a railroad spur from the abandoned Milwaukee railway circling the actual site, and a series of transmission lines will further destroy the visual experience enjoyed by members of the Lewis & Clark expedition.

Today, the visual experience from the Salem road, between the abandoned Milwaukee railroad and the newly created Lewis & Clark historic marker site just before Belt Creek, is very similar to the same experience by the members of the 1805 Corps of Discovery. Nearby to the east one can see readily the nearby Highwood Mountains and the more distant Little Belts to the south. The enjoyment of the wide panoramic view of the expansive prairie to the west and north has not really changed since the Ice Age. This particular spot is one of the most beautiful landscapes of the wide prairie and when one looks down from the Lewis & Clark historic marker site it is easy to visualize the hardship of the ascent from Belt Creek to the above plateau where there is this stunning view of its expansive landscape.

The last sentence that “Southern Montana has proposed and will agree to reasonable mitigation measures regarding the visibility impact of its project on the National Historic Landmark” is disturbing. SME and Great Falls city officials have ignored the fact that the proposed plant will destroy the integrity of this beautiful landscape. Mr. Gregori loves to show in his power point presentation a photograph apparently taken from the bottom of the lower portion of the portage route. It must be where the trail leaves Belt Creek. One sees a several transmission line poles giving the impression that the site has already been destroyed. But this picture was only taken, about three fourths of the way up, from the Belt Creek bottom and it does not show that if one continues the ascent the transmission line is located at the edge of the plateau where Lewis and Clark saw the expanse of the prairie.

Second, I am puzzled by the statement that the “federally mandated consultation process has been established to give ample opportunity for concerned groups to ‘weigh in’ on the issue.” Nothing can be further from the truth. I have attended most of the meetings held by the City of Great Falls and Southern Montana Electric officials, and I was always told that this was a “done deal” and not subject to change. For the first time, the public had the opportunity to meet with elected public officials who were serious of listening to a public discussion were the Cascade County Commissioners during their regular scheduled meeting on October 23, 2006. The public hearings for the 2006 DEIS cannot be claimed that this was a public decision or hearing; it was merely whether an air quality permit would be issued. The request for zoning change from agriculture to heavy industry exposed the Cascade County Commissioners to the reality of the actual location of the proposed site. In fact, one of the County Commissioners stated to me personally that they had learned of the location of the generating plant only during the previous October 17, 2006, when the Cascade County Planning Board had its meeting.

Then, the statement to “weigh in” is also very troublesome. I have lived in this area since 1968 and have been interested in the preservation and restoration of local historic sites. I was a faculty member at MSU-Northern, Havre, for twenty seven years and am currently adjunct Professor of International Law at the Malmstrom Campus, Troy University. I have done several research projects such as writing the impact statement for WPA pertaining to a new transmission line between Havre and Glasgow. Organized an Oral History project pertaining to homesteading along the Hi-Line in north central Montana, and I have actively participated in many local community preservation projects such as the restoration of Fort Assiniboine, the 10^th Street Bridge in Great Falls, local historical museum projects, etc. The Alberta Government requested that I write a cross border cultural study of comparison between Montana’s Golden and Alberta’s Paliser Triangles. In my academic field of International Law, I have presented papers and lectures pertaining to the American and Canadian comparisons of economic and political developments north and south of the border. In fact, until time-limited out, I had served six years on the Cascade County/City of Great Falls Historic Commission and many other boards dealing with historic preservation. Yet, I was surprised to discover afterwards that on October 5, 2006, a meeting when historic preservationists here in Great Falls for the purpose of solving a mitigation problem of the historic portage route. It was only last August that our community learned that the proposed plant would be located partially on and astride of the portage boundary.

Third, as I stated above I had attended many of the meetings, including the “Open Houses” and presented oral and written testimony pertaining to the 2006 DEIS. At each of the meetings, I had requested a map of the precise location of the proposed generating plant. My request was either ignored or I was promised one but it never received one except from our Cascade County Commissioners. Actually, the first time I saw a map of the precise location when it was on display during the October 23, 2006, Cascade County Commissioners meeting. It was a day later that one of the County Commissioners was so kind to give me a copy of four small maps which dealt with various configurations of the proposed plant position astride of the Great Falls Portage boundary. It was the following Monday that the Cascade County Planning Office gave me an actual copy of the large map which outlined not only the proposed placement of the generating building complex, the coal pile, and the ash cells. It showed also the railway spur and how it rounded the site, the water line crossing the portage route, and the transmission lines from the proposed plant to the other side of the Missouri river. It does not show where the security fence/wall is to be located as pictured on the cover of the 2006 DEIS.

Fourth, I am disturbed by the apparent negative tone of this letter and how it demonstrates clearly the attitude by SME officials towards those with whom they disagree. The sentence on the top of p. 27 that “the CCE group has very strong views regarding the use of the IGCC” is in reality an under estimation of the widespread opposition to the proposed generating station. I am not a member of that particular organization but I have attended several of their meetings to answer questions about the national importance of the Great Falls Portage route. Also the Cascade Democratic Party has asked me to mediate between that CCE and the labor unions in favor of this plant and I happily accepted this request. Other CCE members are interested in alternative energy, other generating plants, global warming, etc. I must point out that more than a 1000 citizens of all walks of life have signed a petition opposing this generating plant, and I was also pleased to put my name on the list because I am concerned about the possible destruction of the landscape integrity by the proposed plant of the lower Great Falls Portage route.

In any case, my final point is that I request and urge the USDA to examine the project very carefully before you make a decision. To allow this project to continue will mean that future generations will have lost a very valuable historic landmark in our national heritage.

I also want to thank you for your interest and cooperation. And if you have any questions please feel free to contact me by phone, letter, or email. Do you know that the Cascade County Commissioners have asked me to provide them with information and documentation about the history of the Great Falls Portage route before the November 27, 2006, meeting? No matter what the outcome about their decision of the zoning change, I feel that they are sincere in learning as much as possible about the value of the Great Falls Portage route landscape integrity for future generations.

Sincerely,

Aart Dolman, Ph.D.

3016 Central Avenue

Great Falls MT. 59401

Phone: 406-452-5554

Email: aart-dolman@bresnan.net