Citizens For Clean Energy, Inc.

Wind, Water, Solar, Hydo...Future is ecat



Two heroes today.  Mary Jolley and a neighbor of the proposed Highwood Plant.  Thanks.  Both are heroes. 

Please take time to write a comment opposing the zone change.  We have 30 days to comment.  Either fax it at 454-6903 or email to or mail to Cascade County Commissioners/ Courthouse Annex/325 2nd Ave. N. / Great Falls, MT 59401.  Please use Paul’s letter below as a basis for writing.   Any neighbors who are known to oppose this, please tell them to get a hold of Lisa Hardiman at 455-6412 or Richard Liebert at 736-5791.  All neighbors who come forth, your names will not be shared.  Thanks  lisa

To:  Cascade County Commissioners and Planners
Re:  Urquhart family request to rezone agricultural land to Heavy Industrial use
for the construction of a coal-fired power generation facility
A portion of the legal zoning regulation for heavy industrial is listed below. It can also be found on the county's website under planning and zoning regulations (on electronic page 77, actual page 73):
_______________ Site Plan Review and Approval
In each case where an I-2 industrial building or use is proposed, the Zoning Administrator shall review the site plan of the proposal in accordance with Section 9.7 and shall approve, or approve with modifications, or disapprove such site plan. In modifying or disapproving such site plan, the Zoning Administrator shall enter his reasons for such action in Office of Zoning Administrator's records. The Zoning Administrator shall also review the plan considering the noxious or injurious effects of the industrial operation for the purpose of protecting the health, safety and general welfare of the community. Affidavit Required
Any applicant applying for a permit in an I-2 Heavy Industrial District shall file with the Zoning Administrator, on forms provided, an affidavit together with description of industrial occupancy and operation relative to the following:
(a) Noise (b) Smoke (c) Odor (d) Dust and Dirt (e) Noxious Gases (f) Glare and Heat
(g) Fire Hazards (h) Industrial Wastes (j) Aesthetics (i) Transportation & Traffic
(k) Psychological Effects
Apparently, the Environmental Impact Statement (still in Draft form, and not approved or modified to include numerous corrections and objections to the conclusions reached therein) is being provided to serve as the "Affidavit Required" under County zoning rules. It is precisely the issues enumerated here which cause us to object to the zoning change.  Every category above, a-k, will be impacted by the Highwood Generating Station.  More importantly, these effects will extend far beyond the boundaries of the Urquhart property, which has arbitrarily been defined as its own "District" for zoning purposes, thus excluding neighbors and people downwind from having any say in this zoning change.  At least that was the "ruling" made by the County Attorney present at the Planning Board hearing last week. 
We insist that everyone impacted by this proposed Generating Station be allowed to protest, and their property rights, health, and welfare be seriously taken into account in this zoning change.  It is obvious to us that a corrected Environmental Impact Statement will show that the harm and costs to the people of Cascade and adjoining counties will absolutely preclude the construction of such a facility in this location, and that the Commissioners should refuse the request for a zoning change.  At the least, this request should be tabled until such time as the final Environmental Impact Statement has been approved, financing has been obtained for the plant, and other uncertainties answered. 
This is not simply a request for a zoning change:  it is a request by specific parties to site a specific facility at this location.  Since this is a major industrial facility which will forever change the character of the immediate environment, and the lives, health, and property values of everyone in the vicinity, as well as those downwind and downstream in the Missouri River Basin, it is imperative that the Commission not grant this application without a great deal of further study and testimony from those concerned. 
(s) Paul Stephens

Canaries in the Coal Mine

Canaries in the Coal Mine:  Climate Change, Windmills and Birds
Russell Doty, CEO New World Wind Power, Executive Director of Green Electricity Buying Coop and Great Falls born and raised, will be our guest October 9th.  Mr.. Doty will present a program that covers global warming, bird kills as a result of global warming (it isn't just wind power that kills birds), and the cost to personally commit to reducing global warming.Mr. Doty has served in the Montana legislature, worked for the Public Service Commission, wrote environmental law in Minnesota, practiced private law and has also worked for the Untied States Postal Service in his varied career.  Come with questions, come with friends and family. 
The public is welcome to attend all Upper Missouri Breaks Audubon meetings.  We meet on the second Monday of the month at the Rainbow Retirement Center, #20 3rd Street North, across from the US Post Office.  The meeting is held in the lower level meeting room.  The meeting starts at 7 PM with bird identification and social time, the program starts about 7:30 PM.

Paul Stephens Article

Posted: Wed Oct 04, 2006 8:36 pm Post subject: Schweitzer's
billion IGCC plant
There are several important points which should be noted
this event. First, it is exactly the sort of plant which we've been
the city and SME they should build near Great Falls -- if they want or
to build more coal-based energy systems (and we insist they don't need
to do
this). Basin Electric, a North Dakota co-op, is building a similar
and has offered to sell SME power at long-term, cost-effective rates.
Second, it will only add to Montana's generating capacity,
is already more than double what we use, here. Thus, this plant (and
all new proposed plants) are really "merchant plants", whose power will
exported to other states, leaving us with depleted resources, huge
streams, and superfund cleanup sites down the road. This is a very bad
for "economic development" and "cheap power."
Third, we advocated IGCC technology over CFB (straight
coal-burners) for the Highwood Station because it is relatively
pollution-free; and the huge amount of CO2 it emits (the equivalent of
560,000 cars and trucks for the Highwood plant) can potentially be
"sequestered", or pumped back into the ground so it doesn't add to
warming. These are all pluses for the Bull Mountain plant.
SME and Mr Lawton have been lying to us all along, that IGCC
isn't financeable and is "unproven" technology. About 1/4 of currently
proposed coal plants are IGCC (some 30 of them nationwide). We must do
for the local Highwood station, or no coal at all. Carbon taxes will
increase the cost of coal-fired power by a factor of 2-3, or even more,
wind is widely established. The Highwood Station as proposed will never
cover its costs, and will be a great liability both to city and local
finances and to our health, the tourist industry, the arts, and other
growth sectors in central Montana. Those who want to build the Highwood
station are out to harm us. The "benefits" they offer in turn are merely
taxes and a few jobs. Think about it. Should it take an investment of
million dollars to create 65 jobs? This is absurd. The Highwood Station
never produce any power for the people of Great Falls.
Paul Stephens Member of Citizens for Clean Energy

Papers To wrte Letters to Editors

Helena Independent Record
Mailing Address:
The Independent Record
P.O. Box 4249
Helena, MT 59604

Billings Gazette
PO Box 36300
Billings, MT 59197-6300

Bozeman Daily Chronicle
Use this online form, or send letters to:
Editor, Bozeman Daily Chronicle, P.O. Box 1188, Bozeman, MT 59771. Or

Letters must contain the writer's name, address and telephone number
(phone numbers are for verification, not publication).
Mail to: Missoulian Letters, P.O. Box 8029, Missoula, MT 59807.
Fax: 406-523-5294.

Daily Interlake
727 East Idaho Street / Kalispell, Montana 59901 / 406-755-7000
PO Box 7610
Kalispell, MT 59904

Havre Daily News
PO Box 431
Havre, Montana 59501

Montana Standard (Butte, Dillon)
25 W. Granite St.
Butte, MT 59701

Lewistown News-Argus
P.0. Box 900 . 521 W. Main St. . Lewistown, MT 59457
406-535-3401 . 800-879-5627 . Fax: 406-535-3405

Mercury Rule Summary

The mercury rule components that were voted on last week are as follows. I will tell you what the rule says, what it means and why it is a problem. The board seems enamored with the term “soft landing” so I will point out to you the myriad of soft landings being provided by the rule. I count at least 7 soft landings in the following rule. There are a few more, but I won’t bore you with those details.    In short, the current problems with the rule are:  
  1. Gives agency almost unfettered discretion to establish emission limits
  2. Does not require honest mercury controls until 2018 (or beyond if a company uses banking).
  3. Sets a emission standard in 2018 that facilities could meet today.
  4. Gives weaker limits to lignite coal, the dirtiest type of coal in Montana.
  5. Encourages companies to burn lignite coal by giving them a weaker standard, despite the fact that Montana is loaded with higher quality coals.
  6. Allows cap and trade in Montana in perpetuity. Companies can buy and sell their way out of complying with emission limits.
  7. Establishes future limits based upon the weaker best available control technology standard and not the normal standard for hazardous air pollutants which is the stricter maximum achievable control technology standard. BACT is driven by economic factors. MACT is driven by what the best facilities in the country achieve.
How is my recollection of how the board voted and issues still open before the board: • The Board voted against requiring stronger standards for lignite. Robin Shropshire made the motion, but instead of voting the board directed DEQ to provide it with the basis for the weak standards on lignite. The Board was not satisfied with the industry lignite experts testimony showing these facilities can reach 90% control. • Robin Shropshire made the motion to give lignite the same trading credits as cleaner coals. The board rule gives them nearly double of cleaner coals. That motion failed. Robin Shropshire was the only vote in favor. • Robin Shropshire made a motion to prohibit banking. That motion failed unanimously with Don Marble abstaining and Joe Russell not finishing the vote since it was clearly going down. • Bill Rossbach made a motion to direct DEQ to establish some criteria by which the agency will make permitting decisions. That motion passed unanimously. Unfortunately, the rule still allows for little to no oversight by the board or courts for the decisions DEQ makes. • Joe Russell made a motion to establish a maximum emission limit after 2018 of no more than 1.1 lbs/Tbtu. Motion passed with only Kim Lacey dissenting. She was concerned it might hurt Great Northern’s proposal to build a 500 MW lignite plant near Circle. Summary of current rule: 1. All facilities have to submit an application to DEQ on Jan. 1. 2009 that demonstrates the ability to meet a 0.9 lbs/Tbtu emission limit. This provision is good. If facilities were indeed required to meet this limit it would be acceptable. 2. All facilities can violate the 0.9 standard at any time. As long as over the course of the year, their average annual emissions are not higher, they will not be penalized. SOFT LANDING. 3. If a facility fails to achieve 0.9 lbs/Tbtu over the course of the year they must submit a permit modification 18 months after they start operating. As currently written DEQ has no discretion in issuing that new permit for a higher limit (this new limit is known as an alternative emission limit). No enforcement action can be taken against them if they fail to meet their initial emission limit provided that DEQ determines they tried to meet the 0.9 lbs/Tbtu emission limit. SOFT LANDING. The Board asked DEQ to amend the rule to come up with criteria by which DEQ will decide whether and how an alternative emission limit will be issued. 4. DEQ has complete discretion as to whether a facility gets an alternative emission limit and they have almost complete discretion on what that new limit should be. DEQ cannot set the limits above a certain level though. But these levels are arbitrary, extremely weak and differ by coal type. For example, new facilities like the Highwood Generating Station near Great Falls would have an upper limit of 1.5 lbs/Tbtu  (which happens to be the same level as DEQ put in its draft permit) which is only only 26% control of mercury. Existing lignite has a limit of 4.8 lbs/Tbtu. The Great Northern lignite plant in eastern Montana which hasn’t even applied for a permit yet, will have an upper limit of 3.6 lbs/Tbtu. New lignite after 1/1/2009 will have an upper limit of 2.16 lbs/Tbtu.  The board or courts have have no ability, or at best and extremely limited ability, to review any agency decision on emission limits. SOFT LANDING. The numbers are completely arbitrary. The industries lignite expert who testified in Billings showed test results on lignite in which most results showed 90% reductions. These upper limits are more in the range of 30-50% reduction. DEQ argues that these are maximum limits they can set, but DEQ has gone along with industry on every power plant permitting decision to date. And with no oversight, there will be tremendous pressure on the agency, and incentive for the companies to convince the agency, that the weakest limit is the best they can do. 5. Facilities are not required to ever install mercury control equipment. If a facility can convince DEQ that its boiler can reduce mercury to the limit, it will not be required to install mercury controls. It can then get an alternative limit (weaker limit) even though it has NEVER installed mercury controls. This is troublesome because despite the fact that two facilities have already agreed to install mercury controls, DEQ is still saying those controls are not best available control technology and is therefore not requiring the Great Falls power plant to install mercury controls. If a company can convince DEQ that it doesn’t need to install mercury controls in the initial permit, it won’t have to install those controls until 2018, if ever. 6. Alternative limits (weaker limits) are good from the time DEQ establishes them (probably late 2011) until 2018 – approximately 7 years. SOFT LANDING. This provides an incentive for companies to convince DEQ that a cheap technology can meet 0.9 lbs/Tbtu and then for them to fail to meet that limit and therefore delay investment in mercury control technology. 7. If a company has an alternative limit (weaker limit) it will have to submit a permit application to DEQ in 2014 showing what “best available control technology” is for that facility. Hazardous air pollutants are supposed to be regulated under a maximum achievable control technology standard. A BACT standard is MUCH weaker than a MACT standard. The BACT standard is driven by economic factors. A MACT standard is driven by what the best facilities in the country are able to achieve. This is why EPA is being sued by 15 states and numerous public health organizations. MACT standards are required for hazardous air pollutants like mercury. 8. A facility that is operating under an alternative limit has to comply with a  BACT limit by Jan 1, 2018. The limit set by DEQ must be no worse than 1.1 lbs/Tbtu.  SOFT LANDING. The 1.1 lbs/Tbtu limit is 20% higher than the limit they are supposedly required to meet in 2010. 9. Trading of mercury credits is allowed. From 2010 until 2018 all nonlignite facilities will receive credits up to 0.9 lbs/Tbtu. Lignite facilities will get more credits, or credits up to 1.5 lbs/TBtu. If the plant can do better than those limits it can sell credits. If it cannot achieve those limits it has to buy credits down to that amount. So if Great Northern has an emission standard in its permit of 3.6 lbs/Tbtu but is actually able to achieve 1.1 lbs/Tbtu, it can sell those credits it received between 1.1 lbs/Tbtu and 1.5 lbs/Tbtu.  It will profit off of failing to meet its supposed required emission rate of 0.9 lbs/Tbtu. SOFT LANDING. 10. Banking of mercury credits is allowed. That means that if a company does better than its limit, it can save those credits until after 2018 and instead of meeting its emission limit after 2018, it can apply those unused credits it accumulated before that date to its emissions to show that on paper (although no in practice) it is meeting its emission limit. SOFT LANDING 11. All facilities must go through BACT review every 10 years. Again, BACT is an analysis that is driven by how economical it is to control pollution. The standard should be MACT. ********************** Anne Hedges Program Director Montana Environmental Information Center P.O. Box 1184 Helena, MT 59624 (406) 443-2520 fax: (406) 443-2507