Critical Points

• Don’t disadvantage Montana in its efforts to compete successfully with neighboring coal states like WY and ND where CAMR is or has been adopted.
• Rule should provide for interstate cap & trade to allow for new development.  Montana has 20% of the nation's coal reserves but only 1% of the mercury allowances (as allocated by EPA). (We need the ability to trade or a whole lot of Montana coal is stranded.)
• Rule should provide for “soft landing” regarding meeting specific mercury emission limits.
• More stringent emission limits, if necessary, should be phased in over time as Hg emission control advances. 

• Montana’s economy depends on affordable energy sources
• Creation of excessive rules that apply only to Montana drives energy development to other states.
• Lack of new energy development leads to higher energy prices for all Montanans.
• High energy costs make it difficult to attract industry to our state.

• Montana, the Saudi Arabia of coal, has more reserves than any other state - more than 120 billion tons.
  • With high energy prices causing everyone to look to domestic and local sources for our energy needs, Montana is poised for an expansion of energy development. State regulations that exceed those of EPA and our neighboring states will negatively affect this opportunity.
• Coal fired power plants provide an opportunity to add value (and associated jobs and tax revenue) to a Montana natural resource.
• Montana’s coal is located in the regions of our state that are struggling.  This is an economic opportunity that we cannot afford to destroy.
• Decreasing Montana coal-fired power plant mercury emissions will have virtually no effect on the amount of mercury consumed by Montana citizens.

• We should not pass any rule that would disadvantage lignite.
• Rule should acknowledge that mercury control is more difficult with lignite and set lignite-specific limits accordingly.
• 75% of Montana coal reserves are lignite. The lignite is located in some of the most economically distressed areas of Montana.

Conclusion

Adopting standards for Montana that are more burdensome than other states when there is no science indicating a health benefit for those standards simply puts Montana at a competitive disadvantage for electric production.  It creates a situation that may force companies to either litigate standards that they cannot meet or leave the state.  Montana needs the economic benefits of affordable electricity.  Any rule adopted must NOT create an unnecessary roadblock for the development and production of that electricity.

Please encourage the Board of Environmental to adopt reasonable and competitive mercury rules.