Pm 2.5 Facts

An article by Doctor Cheryl Reichert

Montana’s Priceless Blue Sky trumps the Highwood Coal Plant

Great Falls currently boasts the fourth cleanest air of any metropolitan area in the country. Growing up under the Big Sky, I assumed that clean air and blue skies were a birthright. It wasn’t until I left Montana to pursue my professional education that I appreciated the clean air that I had taken for granted.

As a pathologist and biochemist, I’m an advocate for public health. I’ve examined lung tissue from more than a thousand individuals. It’s easy to distinguish the pink healthy lung tissue of a newborn from the blackened lung of heavy smokers. More surprising is the gray lung tissue of non-smokers who simply breathe dirty air.

I returned to live in Great Falls two decades ago. I am reminded of the blessing of our clean air whenever I travel to other cities that are encased in haze of brown-tinged smog. Airborne contamination finds its way deep into the air sacs of our lungs, where it contributes to asthma and respiratory distress. Some of the particles are so small (particulate matter less than 2.5 microns) that they find their way into our circulatory system. These particles are a fraction of the diameter of a strand of hair and are so small several could fit inside a single red blood cell.

I’m sensitive to the practical concerns of those who would profit from jobs at the Highwood coal plant, and I certainly understand the growing electrical needs of our neighbors in southeastern Montana. However, I believe it’s reasonable to expect energy developers to give a hard look at non-polluting alternatives to coal, and if they must use coal to employ the latest technology to protect our air quality.

To its credit, Southern Montana Electric (SME) has listened to the community’s concerns about mercury emissions and promised to install activated carbon injection to improve the capture of this potent neurotoxin. However, SME has not given serious consideration to “clean coal” technology that is based upon coal gasification, which has greater potential to capture harmful pollutants and greenhouse gases like carbon dioxide. Highwood Generating Station (HGS) clearly doesn’t fall within the accepted definition of “clean coal technology”. It’s true HGS’s “circulating fluidized bed” is cleaner than Colstrip, but it’s still an old technology that burns rather than gasifies coal.

The annual combustion of 2.6 billion pounds of coal by HGS will add smog and acid rain to our Big Sky. The Highwood coal plant is permitted each day to release approximately one TON of breathable invisible particulate matter. This coal plant will also produce the greenhouse gas equivalent of more than 500,000 cars.

Due to the limited 400’ height of the proposed stack, variable local wind patterns, an upper air inversion cap that periodically prevents adequate dispersion of pollutants, and the baffle effect of the Highwood Mountains, a local meteorologist expects the air in our area will be degraded about 25% of the time. Why would we do this to our children, our planet, and ourselves when there are more modern, cleaner energy alternatives?

Are you and your family ready to be part of the “collateral damage” of Southern Montana Electric’s ambitions? If HGS is built, north-central Montana will experience an increased incidence of chronic respiratory and cardiovascular diseases. Infants, children, the elderly, and those with cardiopulmonary disease are among the most susceptible to adverse health effects from air pollutants. Children have increased exposure to air pollutants compared to adults because of higher ventilation rates, higher levels of physical activity, and because they spend more time outdoors. Children in communities with higher levels of air pollution (acid vapor, nitrogen dioxide, PM 2.5) have decreased lung function.

In 2006 area volunteers formed a grassroots organization, Citizens for Clean Energy Inc. (CCE). One of its missions was to partner with the Montana Environmental Information Center (MEIC) to legally challenge the Air Permit for HGS that was issued by the Montana Department of Environmental Quality (DEQ). The Air Permit did not specifically address PM 2.5, and this was a serious deficiency. By using a much larger and less dangerous particle (PM10) as a surrogate marker for PM2.5, DEQ didn’t ensure the maximum achievable reduction in PM2.5 emissions from a major polluting facility. By analogy, if SME’s proposed baghouse filter were a large kitchen strainer into which I poured a cup of flour (PM2.5) and a cup of marbles (PM 10), the strainer would very effectively retain the marbles, but not the particles of flour that are of much greater concern.

PM2.5 is a “pollutant subject to regulation” under the Federal Clean Air Act. Therefore “best available control technology” (“BACT”) requirements under state and federal law apply. SME and Montana DEQ should have undertaken a BACT analysis for PM2.5 and identified control technologies that have a greater potential for reducing PM2.5 emissions. On April 21, 2008, the Montana Board of Environmental Review acknowledged this deficiency in a landmark ruling. Additional studies will now be required before the Highwood coal plant can go forward.

Recent medical research expanded the list of health effects associated with fine particulate matter and identified health effects at lower exposure levels than previously reported. As a result, new federal air quality standards to safeguard human health took effect in December 2006. Under the revised standards, the 24-hour fine particle standard was nearly halved, from 65 micrograms per cubic meter to 35 micrograms.

An important recent study on the adverse effects of PM 2.5 air pollution was published last year in the New England Journal of Medicine. Among a large group of middle age women, each increase of 10 micrograms per cubic meter of PM 2.5 was associated with a 76% increase in the risk of death from cardiovascular disease. The risk of stroke was also associated with increased levels of PM 2.5.

Unfortunately, current air permitting regulations by the Montana DEQ do not require specific measurements of some of the heavy metals that will come from the coal plant, (including 540 pounds of arsenic and 560 pounds of lead).

Our Montana Constitution not only guarantees its citizens a right to a “clean and healthful environment” (Art. II, Section 3) but also creates an obligation to “maintain and improve a clean and healthful environment ...for present and future generations” (Art. IX, Section 1). The proposed coal plant violates these tenets. Interference with the fundamental right to a clean and healthful environment receives the highest level of judicial scrutiny: state action may impede the right only if the state demonstrates a compelling interest.

In addition to important public health concerns, there is an economic risk that is more significant than the temporary construction boom and 65 permanent jobs that the coal plant will bring. By using up available transmission capacity for our area, HGS will impede future development of cleaner, sustainable energy alternatives and will discourage those who value clean air from locating or remaining in Great Falls.

A moratorium on construction of all new coal-fired power plants is currently working its way through Congress. How sad it would be for America’s last old-technology coal plant to be built in the middle of “the Last Best Place”.

Cheryl Reichert, M.D., Ph.D. is a Great Falls native. Contact her through Citizen for Clean Energy’s website, www.cce.mt.org.

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