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IJt-C 1 2003 






3 0864 1002 3597 


30' 3/03.' II 

Montana Energy Advisory Council 
Project Director: Sharon Solomon Project Investigator: Gail Kuntz 

January 1977 



1. Introduction 1 

IT. Montana Energy Facility Siting 3 

A. Major Facility Siting Act 3 

B. Administration 5 

C. Discussion 8 

III. Survey of State Siting Processes 12 

A. Oregon 13 

B. Washington 16 

C. North Dakota 18 

D. Minnesota 21 

E. Maryland 26 

F. California 31 

G. Analysis 37 

IV. Criteria 44 

V. Resource Data Assessment 50 

VI. Data Systems 55 

A. System Components 55 

B. Discussion of Computer Systems and Programs 63 

C. Summary Discussion 72 

Recommendations 7f, 

References gQ 

Background Information 84 


The following report has been prepared for the Montana Energy Advisory 
Council in partial response to the directive of the 1975 Legislature that "the 
siting of certain energy conversion facilities shall be suspended . . . until 
a long-term, comprehensive state energy conversion policy and plan" has been 
prepared. Recognizing the need for a sound framework of policy and information 
to guide future siting activities in the state, the Legislature specifically 
called for "a statewide siting inventory and a proposed siting policy for the 
coordinated siting of energy conversion facilities to meet Montana's energy 

The responsibility for these tasks was assigned to the Montana Energy 
Advisory Council with a further directive from the Governor to conduct a broad 
assessment of the energy- related data situation in Montana. 

Montana's existing involvement in energy facility siting is defined through 
the provisions of the Montana Major Facility Siting Act. The following section 
of this report presents a discussion of significant sections of the act and the 
administrative activities employed by the Energy Planning Division of the Depart- 
ment of Natural Resources and Conservation in interpreting the act and process- 
ing specific energy facility applications. This discussion is followed by an 
analysis and comments on the strengths and weaknesses of the Montana siting 
process which have emerged during its three and one-half year existence. 

At present, the state is not directly involved in energy facility siting 
until an application is filed under the siting act for a specific facility at a 
specific location. A major objective of this report has been the investigation 
of alternative options open to the state in developing a statewide siting policy 
and inventory to guide the activities of the state and future energy facility 
applicants in the earliest possible stages of planning to meet energy needs. A 
statewide siting inventory can be expected to supply a classification system 
defining the relative compatibility or incompatibility of geographic areas of 
the state with future siting activities. The third section of the report is a 
survey of the siting processes employed in six other states which, in varying ways, 
have taken steps to develop comprehensive policies and statewide studies to fill 
the needs outlined above. The States of Oregon, Washington, North Dakota, 
Minnesota, Maryland and California are included in this survey. 

A siting inventory and future site selection activities must be guided by 
the state's policies concerning economic growth, environmental protection, and 
the types of development activities deemed most appropriate to meet the state's 
future needs and societal goals. These policies must be reflected by specific 
siting criteria which define the relative importance of various types of land 

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uses and natural and cultural environmental characteristics in terras of future 
energy facility siting. The fourth section of the report discusses some of the 
policy decisions and organizational activities which will be required In develop- 
ing siting criteria. 

The next two sections of the report discuss the availability of resource data 
to meet the needs of a siting inventory and the availability of automated systems 
to facilitate the storage and analysis of data in meeting a variety of resource 
planning needs. The identification of data needs and subsequent coordination of 
management efforts to meet those needs is a central topic of the discussion. 

Siting decisions have been, and will continue to be, made amid conflicting 
political pressures and concerns. The State of Montana is presently faced with 
an important opportunity and a challenge to create a strong policy to guide the 
future development of its resources and the siting of energy facilities within 
its borders. National energy concerns and the increased activities of industrial 
and energy-related interests in the western states have created a critical and 
immediate need for a state siting policy. Although development of siting criteria 
and a statewide siting inventory will not eliminate future political pressures, 
these decision-making tools will help provide a definitive process and framework 
of information to guide the planning activities and future Interactions of all 
concerned parties in siting-related matters. The concluding section of this 
report contains recommendations which outline specific proposals designed to meet 
the policy and planning needs identified in the preceding sections. 

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The State of Montana has been involved in energy facility siting since pas- 
sage of the Montana Utility Siting Act in March of 1973 (Section 70-801, et seq. , 
R.C.M. 1947). At that time, the Legislature found that the construction of addi- 
tional energy conversion facilities might be necessary to meet the increasing need 
for electricity and other forms of energy, but that these facilities "have an 
effect on the environment, an impact on population concentration and an effect 
on the welfare of the citizens of this state" (Section 70-802, R.C.M. 1947). The 
act was passed to ensure that the location, construction and operation of these 
facilities will produce minimal adverse effects. Responsibility for administra- 
tion of the act was given to the Department of Natural Resources and Conservation 
(Department) which subsequently created the Energy Planning Division (EPD) to carry 
out the assignment. In the past three and one-half years, the siting act has been 
applied to the Colstrip Units 3 and 4 application and to applications for a number 
of transmission lines of varying voltages and lengths. EPD is also presently con- 
ducting baseline environmental studies relating to the proposed Burlington Northern 
coal-based industrial facility involving the possible production of fertilizer, 
methanol fuel and diesel fuel near Circle, Montana. The following discussion of 
the Montana siting situation will be presented in three subsections, including: 
(1) a discussion of several significant provisions of the siting act; (2) a dis- 
cussion of the administration of the act; and (3) an analysis of the siting 
process thus far utilized in the state. The latter subsection will be partially 
comprised of comments and observations collected from participants to the Colstrip 
Units 3 and 4 application and hearings. 

A. Major Facility Siting Act 

The siting act was amended and retitled the Major Facility Siting Act in 1975. 
It states that no energy facility (as defined by the act) may be constructed in 
this state without a certificate of environmental compatibility and public need. 
The act established the informational requirements which the state shall use in 
evaluating and subsequently approving, denying or approving and modifying a 
facility application. However, the specific process to be used in analyzing the 
information and applying it to decision-making requirements is not clearly speci- 
fied in the act. Therefore, this process has been developed through administrative 
interpretation. Full responsibility for certification of a facility is given to 
the Board of Natural Resources and Conservation, excepting air and water quality 
related matters, which reside with the Board of Health and Environmental Sciences. 
All other siting- related permits or approvals required by other regional, state 
and local governmental agencies are superceded. The Board of Natural Resources 
and Conservation is required to determine the basis of need for a proposed facility 
as well as determine that the facility represents the minimum adverse environmental 

- 4 - 

impact. Additionally, the benefits to the applicant and the state, the effects 
of economic activity resulting from the facility, the effects on public health, 
welfare and safety, and "any other factors" considered relevant must be evaluated 
(Section 70-810, R.C.M. 1947). 

Among other requirements, an applicant must identify alternative facility 
design technologies and sites and explain the reasons the preferred design and 
site is considered superior to any reasonable alternative. This explanation must 
include social, economic, engineering and environmental factors. 

As amended in 1975, the siting act provides a maximum period of two years 
after a major facility or transmission line application is filed for the Depart- 
ment to complete all necessary studies and submit formal recommendations to the Board 
(some types of transmission line applications must be evaluated within one year) , 
The Department and the Board are guided by an extensive list of environmental, 
social and economic concerns which must be considered in the evaluation of an 
application. The Board is required to hold a public hearing on an application 
under the Montana Administrative Procedure Act not more than 120 days after 
receiving the Department's final recommendations and issue a decision within 90 
days after the close of the hearing. (It should be noted that there is no time 
limitation on the length of the hearing.) During this proceeding, the applicant 
must carry the burden of proving that the application should be granted and that 
all requirements have been met. 

The siting act requires annual submission of long-range plans by utilities 
and any person contemplating construction of a facility within the ensuing ten 
years. These plans must include the general location and design of all facili- 
ties planned for the ten-year period as well as a complete explanation of the 
demand projections used to determine the need for future facilities. This infor- 
mation is made available to the public and all affected state agencies as well as 
citizen environmental protection and resource planning groups. For any facilities 
planned within five years of the submission of the long-range plan, the Department 
is required to evaluate the proposed site to determine whether construction of 
the facility would unduly impair the various environmental values cited in the 
act (Section 70-815, R.C.M. 1947). At this time, no future facility sites have 
been evaluated under this provision, but the process presumably would provide the 
opportunity for negotiation and discussion between the state and a potential 
applicant. The process also would reveal major areas of agreement and disagree- 
ment regarding a proposed site, and thus would allow time for constructive modifi- 
cations of the proposal before the application is filed. 

The siting act also features an enforcement provision which states that any- 
one who violates any portion of the act in the construction or operation of a 
facility or knowingly submits false information in any report or application 
required by the act is liable to a civil penalty of not more than $10,000 per 
violation. Each day of continuing offense constitutes a separate violation. 
Authorization is also provided for the Department to seek injunctive or other 
appropriate relief against a violation (Section 70-821, R.C.M. 1947). 

- 5 - 

Additionally, a certificate may be revoked or an application voided if false 
information has been submitted by the applicant (Section 70-818, R.C.M. 19A7), 

B, Administration 

The Energy Planning Division was created within the Department in 1973 to 
administer the siting act. Over the past three and one-half years, EPD has 
primarily concentrated its efforts in the extensive studies required to evaluate 
facility applications. However, the division also has undertaken planning acti- 
vities and has developed tools to aid in the siting process. 

One of the most important problems confronting a siting agency is the organi- 
zation of large volumes of information into a format or process which will permit 
orderly consideration of all necessary facts as well as comparison of conflicting 
elements for decision-making purposes. A team of experts can use basic resource 
data, and through a combination of professional judgment, familiarity with a given 
study area, and manual comparison of maps, can evaluate various alternatives 
and ultimately recommend a relatively optimal area or corridor for a proposed 
facility. The division has generally employed all of these steps in considering 
transmission facility applications. However, many facility applications are con- 
tested at some point in the certification process and since the state must be 
able to demonstrate exactly how each specific environmental factor has been 
evaluated, documentation of the process is essential. Also, duplication or 
reproduction of study results may become necessary. Therefore, the division has 
been developing a methodology to meet these needs. A methodology ideally should 
provide a logical breakdown of analytic steps which include all of the evaluation 
requirements listed in the siting act. The need for a facility should be established 
before comparative analyses of alternative energy sources, site locations and 
design technologies are performed. When choices have been made among these 
various alternatives, the natural and cultural environmental impacts of the 
proposed facility can be identified and studied. Environmental, economic, social 
and engineering factors must all be taken into account in evaluating these impacts. 
This process represents an ideal study model which has not yet been applied in 
the specified sequence. The reasons for this will be discussed in the following 

The division has made progress in developing a process for evaluating and 
comparing the various resource elements included within the geographic study areas 
associated with various transmission facility applications. It is virtually impos- 
sible for a single site or corridor to minimize all types of adverse impacts on 
all resource elements. Therefore, values or measures of "importance" must be 
assigned to these elements in order to make trade-offs or comparisons between 
them. The elements are locationally plotted on maps. Figure II-l on the fol- 
lowing page presents an example of the maps and the analysis process used in the 
division's study of the Anaconda-Hamilton transmission line application. Each 
item in the legends of the maps shown in Figure II-l is assigned a weight or number 
value which conveys its relative compatibility or incompatibility with a trans- 
mission line. Each complete map is subsequently assigned an overall weighting 
which establishes its importance relative to the other maps. After the weightings 
have been assigned, the maps may be overlayed, combined and compared through a 
computer process to reveal the areas or corridors where least impact could be 
expected to occur. 

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Figure II-l 

- 7 - 

Tlie computerized aspects of the process provide important flexibility in 
allowing EPD to make many types of comparisons between areas, using different 
combinations of weights for the various environmental elements. This reveals 
how different emphasis on the concerns can alter the desirability of a given 
corridor and helps insure that all options are considered. The computer process 
is discussed more fully in Section VI of this report. 

The principal fact which must be understood is that the above process is only 
as useful or as accurate as the information and professional thinking put into 
it. The process will accommodate an almost infinite amount of data analyses, 
but an individual or team of individuals must define the relative importance 
of the elements used in the analyses. These types of judgments are unavoidable, 
but to the greatest extent possible, they should reflect existing state policies. 

The Department has been responsible for negotiating several planning agreements 
between the State of Montana, the U.S. Forest Service (USFS) and the Bureau of 
Land Management (BLM) . These federal agencies are responsible for administration 
and management of significant units of land in the state, as well as the forest 
and mineral resources within those areas. Since both agencies are responsible 
for conducting studies related to siting activities within tbeir respective 
areas of jurisdiction, and since the future siting of energy facilities in Montana, 
particularly transmission lines, is likely to involve federal lands, the planning 
agreements are beneficial to all parties. A cooperative agreement with the USFS 
was signed in December 1973. It provides for joint development of an acceptable 
process for energy transmission planning. The agreement provides a basis for 
exchange of resource and land use data needed by both agencies in making siting 
decisions. The two agencies also expect to collaborate in developing the computer 
programs and procedures required to store, analyze and display the data. A mem- 
orandum of understanding between the state and the BLM was executed in June 1975 
and is primarily oriented toward the coordination of land use studies and data 
collection activities and development of complementary land use planning systems. 
There is also provision for exchange of land use information and mutual review 
of related environmental impact studies. A more recent memorandum of understanding 
between the state, USFS and BLM was executed in June 1976. It complements the 
earlier agreements and is specifically intended "to provide guidelines for the 
three agencies to effectively work together on planning, programming and manage- 
ment issues related to major facilities" set forth in the Major Facility Siting 
Act. Major objectives include establishment of siting decision criteria, defini- 
tion of unsuitable areas for siting and definition of a public involvement process. 
Also, guidelines for joint administrative efforts on individual facility applica- 
tions are to be developed to meet short-term planning needs. It is hoped that 
these planning agreements will provide a strong basis for coordination of federal- 
state activities in the future, especially as mutual responsibilities are con- 
centrated in siting-related issues. 

- 8 - 

C. Discussion 

The Montana Major Facility Siting Act has two weaknesses which have hindered 
the attempts of both applicants and the state to effectively comply with the require- 
ments and intent of the law. These weaknesses are best described as (1) an inad- 
equate planning and informational framework to guide the siting of energy facil- 
ities, and (2) inadequate scheduling of the various procedures required by the act. 

The siting act provides an extensive list of factors which must be included 
and evaluated in a facility application (Section 70-816, R.C.M. 1947). A potential 
applicant has this list to guide preparation of an application; however, nearly all 
of the elements are oriented toward determining the total impact the facility 
would represent, while very few elements provide specific guidance for selecting 
an optimal site or corridor. Therefore, in the planning stages, the applicant 
selects a site based upon the criteria he considers most important and at the 
point that an actual application is filed, considerable amounts of time and funds 
have been invested in studying that specific location. 

As indicated in the siting act, the state must evaluate the facility and the 
site which have been proposed in an application. Although the applicant is required 
to submit information concerning alternative sites which have been considered, the 
state is in an extremely unfavorable position to determine whether the proposed 
site is the optimal choice. The applicant's criteria may be in conflict with the 
state's responsibility for minimizing adverse impacts, but unless the state 
initiates extensive siting studies at alternative locations, the possibility of 
relocating a proposed facility appears slight. This Is especially true for major 
facilities other than transmission lines. Also, there is no mechanism for select- 
ing alternative sites for study. 

The most essential problem facing both applicants and the state is the lack 
of a geographically oriented framework of criteria to guide the actual siting of 
facilities. The environmental elements listed in the siting act could be adapted 
to this purpose, but thus far, this type of planning has not taken place, primarily 
due to lack of funds and lack of specific authorization to include the results of 
such planning in the state's siting regulations. 

One siting inventory has been undertaken in Montana by the Montana Energy and MHD 
Research and Development Institute (MERDI) located at Butte. This organization 
is federally funded, primarily through the Energy Research and Development Admin- 
istration, and is principally charged with furthering the development of magnetohydro- 
dynamics (MHD) technology (a coal-fired process of energy production) and ultimately 
siting and operating a 500 megawatt MHD plant somewhere in Montana. MERDI has con- 
ducted a statewide study to identify candidate areas within Montana which will 
potentially yield a suitable site for the MHD facility. The statewide study used 
1:1,000,000 scale maps and considered the following criteria: 

(1) Meteorology (air dispersion characteristics). 

(2) Hydrology (volume of stream flow). 

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(3) Seismiclty (distance from geologic faults). 

(4) Land use (legally proLected areas). 

(5) Socio-economics (proximity to community of 
at least 6,000 persons). 

This study effort should be evaluated by the state. A state-sponsored siting 
study might be organized under entirely different criteria, but the MERDl experience 
can provide valuable insight into potential problems which may be encountered. For 
example, lack of reliable statewide data prohibited use of some criteria categories 
which MERDI had hoped to incorporate in its study. These included land productivity 
and wildlife population density categories. Also, meteorology was used as a study 
criterion, but the data were not detailed enough to allow more than an extremely 
broad evaluation which generalized the available information over large geographic 
areas. MERDI has taken its initial study, which identified candidate areas, through 
a second, more detailed screening level. The large candidate areas have thus been 
reduced to reveal smaller, suitable siting areas which are presently being studied 
to identify potential sites for the future MHD facility. Although a state siting 
study and criteria development process would be an independent effort with different 
goals, interaction and exchange of information between the state and related efforts 
such as the MERDI study should be encouraged. 

Development of siting criteria and completion of a statewide siting inventory 
constitute a medium long-range planning goal which will partially correct the state's 
present reactive position in evaluating siting applications. However, other adjust- 
ments may be required to correct problems in the scheduling and general organiza- 
tion of the application evaluation procedures outlined in the act. 

As noted in the methodology model described previously, the need for a facility 
should be established before engineering design and environmental evaluations 
proceed. However, the siting act requires that the entire evaluation of a major 
facility must be completed within a maximum time period of two years. This 
effectively prohibits the initiation of a separate study to determine "need" 
and essentially requires that all phases of the evaluation proceed concurrently. 
Policy determinations which go beyond the siting act are involved in interpreting 
the definition of "need" for new facilities. If these policy determinations are 
ultimately established, it may be possible to divide the siting evaluation period 
into a "need" study and a subsequent environmental study, especially if earlier 
state involvement in facility planning somewhat reduces the time required for some 
types of evaluations. 

The long-range plans and five-year site evaluation requirements presently 
included in the siting act (Sections 70-814 and 70-815, R.C.M. 1947, respectively) 
are intended to address the need for earlier state involvement in site planning, 
but these provisions may not be functioning as intended. No funding source has 
been provided to the Department to carry out the five-year site evaluations and 
no studies of this type have been conducted thus far. Also, there is considerable 
debate concerning the time that energy demand projections decisively show that a 
new energy facility or facilities will be needed. Further, there is uncertainty 
regarding the time the potential need for a new facility becomes an integral part 
of a utility's long-range plans and begins to require plant design and site- 
related decisions. The relative newness of the Montana siting process has not 

- 10 

allowed time for extensive state Involvement in the initial design and siting 
plans for facilities proposed thus far under the siting act. The quality of the 
state's involvement in these plans in the future will partially depend upon the 
accuracy of the long-range plans and the openness of state-utility interaction 
prior to the filing of specific applications. The siting act's long-range 
reporting provisions may require further refinement to insure that their purpose 
is adequately served. Several types of provisions which could help meet this 
objective are featured in other state siting processes discussed in Section 

The recently completed certification process for the Colstrip Units 3 and 4 
application has revealed many opportunities for improving the siting act's hear- 
ing procedure as well as improving the interaction of federal, state and local 
government agencies, and the public both prior to and during the hearing process. 
The Colstrip hearing participants who submitted comments for this study agree 
that the length of the hearing and the volume of material in the hearing record 
could have been significantly reduced by clarification of contested issues and 
other types of planning prior to commencement of the hearing. This matter should 
be studied in detail before specific changes in the procedure are proposed, but 
it appears that the hearing examiner should be appointed to an early stage in 
the application process and given the responsibility for organizing pre-hearing 
conferences to clarify areas of agreement and disagreement between the potential 
hearing participants. More effective use of time could also be achieved by 
requiring that all testimony to be included in the hearing be submitted in advance. 
Additionally, the hearing examiner could streamline and clarify the entire pro- 
ceeding for the Board if given the responsibility for summarizing the hearing 
record in a form suitable for decision-making. Another related matter requiring 
further study concerns the adaptability of the Montana Administrative Procedure 
Act to the requirements of a siting proceeding. If procedural adjustments 
improve the process, they should be considered. 

The Colstrip application and hearing revealed a number of areas where coor- 
dination between government agencies could be improved. Numerous state, federal, 
regional and local government agencies have either statutory responsibilities or 
geographic areas of jurisdiction which are directly affected by siting issues 
and decisions. The Department is given lead responsibility for siting, but there 
is no clearly defined mechanism to insure that proper communication, interaction 
and coordination of interagency efforts is taking place. The siting act provides 
a basis for coordination between state agencies in requiring that agencies with 
expertise in areas affected by energy facility siting must make appropriate 
reports to the Department. However, the absence of well-defined siting objectives 
creates problems in achieving a comprehensive approach with these reports. 

The Colstrip application is presently being evaluated by several federal 
agencies. Although these evaluations may potentially be aided by the state's 
hearing record and environmental studies, improved federal-state coordination at 
an earlier time could have avoided much of the confusion and complex legal 
entanglements presently surrounding the application. 



- 11 

The existing cooperative agreement and memorandums of understanding between 
the state, U.S. Forest Service and Bureau of Land Management provide for mutual 
exchange of land use and resource information applicable to siting and joint 
development of an acceptable siting process. The latter objective will provide 
a specific means for achieving sustained interaction and cooperation between the 
agencies, but it has not yet been fully implemented. 

A separate, but related, matter concerns public input and the involvement 
of local government and community leaders in the siting process. As with the 
other topics discussed herein, earlier and more clearly defined forms of involve- 
ment would be a significant improvement. Public input in the siting process has 
thus far been characterized by testimony at public hearings and submission of 
written comments on specific applications and evaluations. Various forms of organ- 
ized political activity have supplemented this input. The ultimate effectiveness 
of the former types of involvement is, perhaps, questionable. More innovative 
and effective forms of public input would include participation in the site plan- 
ning process through the development of siting criteria and the siting inventory. 
Public input in this type of planning would help insure that future site selections 
are made within a policy-oriented, informational framework which the public has 
helped construct. Alternative mechanisms for insuring public input in criteria 
development are discussed in Section III. 

Public involvement in the application evaluation process also requires 
attention. If the certification and hearing procedures are eventually amended 
in specific ways, the form and content of public input should also be analyzed 
for possible improvement. 

Further discussion of the various topics and problem areas outlined above will be 
presented in the following sections of the report. 



Nearly all state siting legislation has come into existence in the past six 
or seven years with the objective of involving states in the energy facility 
planning and siting process. All 38 state siting laws (Council on Environmental 
Quality, 1976) have been oriented toward minimization of the various adverse 
impacts associated with energy generation and conversion. This objective has 
principally been served by requiring new energy facilities to apply for and 
receive state evaluation and approval before construction may begin. 

A principal objective of this report has been the identification and investi- 
gation of siting activities in other states which have begun to move toward com- 
prehensive involvement in the planning and siting of energy facilities prior to 
the evaluation of individual facility applications. This investigation may provide 
Important guidance to development of the Montana siting process. Therefore, this 
section presents a review of siting activities in the States of Oregon, Washington, 
North Dakota, Minnesota, Maryland and California. It must be noted that other 
states not included in this study have also engaged in comprehensive site planning 
activities, but time constraints and the results of initial study research and 
communications have limited this review to the above listed states. It also must 
be noted that these states vary considerably in the extent of their involvement 
in site planning and in the approaches which have been applied to statewide siting 

The following list includes key questions which have emerged during the course 
of this study in evaluating state siting processes in terms of comprehensive, long- 
range planning: 

(1) Does the siting legislation provide a direct mechanism for development 

of a state siting plan, development of siting criteria and state involve- 
ment in the facility planning and site selection process prior to eval- 
uation of a specific application? 

(2) Are long-range plans required from any person intending to construct 
an energy facility in the state? Is there an enforcement clause or 
similar mechanism to insure serious compliance with the intent of 
these plans? 

(3) Is the state authorized (required) to generate its own energy demand 
data and perform subsequent forecasting tasks relating to an independent 
assessment of the need for any proposed facility? 

(4) Is there an adequate provision for staffing and funding to carry out 
comprehensive site inventory studies, energy demand analyses, and 
application evaluations? 

(5) Is a mechanism provided for joint planning and interaction between the 
state and the utilities in serving the public interest? 

(6) Is there provision for one stop approval of applications and authoriza- 
tion for the siting agency to coordinate activities of the various 


- 13 - 

federal, state, local and regional agencies with responsibilities 
or jurisdictions related to siting? 

(7) Is there provision for public involvement in designation of siting 
priorities, development of siting criteria, and other types of site 
planning? Is the public informed or provided the opportunity to 
become involved in plans for new energy facilities at an early stage 
in the process, before major decisions have been made? 

The States of Oregon, Washington, North Dakota, Minnesota, Maryland and 
California will be analyzed in the following subsections in terms of these 

A. Oregon 

In 1975, the Oregon legislature created a Department of Energy which absorbed 
the former siting authority (the Oregon Nuclear and Thermal Energy Council) created 
in 1971. The legislature declared that "a need exists for comprehensive state 
leadership in energy production, distribution and utilization" (Section 469.300 
et seq. , ORS 1975). The department was specifically authorized to obtain all 
necessary information from producers, suppliers, and consumers of energy resources 
in the state to predict the timing of construction of future energy facilities. g 
The department presently includes about 30 staff members and has a budget of " 
approximately $2 million over the next biennium (Woods 1976). 

The siting council, retitled the Energy Facility Siting Council, is a part 
of the energy department. The council was directed by the original siting 
law (1971) to conduct studies, investigations, research and programs relating 
to all aspects of site selection, and after public hearings, to designate areas 
within the state that are suitable or unsuitable for use as sites for nuclear, 
fossil-fueled and geothermal power plants. 

A statewide siting task force was appointed by the Chairman of the Nuclear 
and Thermal Energy Council in June 1972 to undertake the site designation study 
and make recommendations to the council. The state was divided into three 
sections — Eastern Oregon, Oregon Coast, and Western Interior Oregon (Oregon 
Nuclear and Thermal Energy Council (ONTEC) 1974) and evaluated for the following 
five parameters: (1) natural resource areas; (2) meteorology; (3) population; 
(4) water restrictions; and (5) geology. Each parameter was considered individ- 
ually in terms of each of the three types of energy facilities. Natural resource 
areas and water restrictions were considered important in siting all types of 
power plants. Meteorology was most strongly considered in fossil fuel plant 
siting, while population and geology were more closely related to nuclear plants 
(ONTEC 1974, p. 0-2). Natural resource areas Included national parks, wilderness 
areas, wildlife management areas and refuges, and other types of special or 
legally designated resource areas. The meteorological evaluation was based upon 
"elements which affect the fate of appreciable quantities of air contaminant ^ 
emission to the atmosphere or emissions which may produce other significant ^ 

- 14 - 

meteorological effects" (ONTEC 1974, p. 2-1). Broadly defined areas such as 
confined valley floors were considered unsuitable for siting. The population 
parameter applied a population proximity concept as a measure to suggest whether 
or not the population in a region is sufficiently dispersed so that there would 
be a high probability of finding suitable nuclear sites. The water restriction 
parameter was determined by existing legal and policy constraints affecting water 
withdrawals from each drainage basin. These restrictions were compared with 
the water requirements of a 1,000 >fW plant, and the various tributaries sub- 
sequently were rated unsuitable, less suitable or suitable for siting. Geology con- 
siderations were described in terms of geomorphic provinces and included earthquake 
potential, active faulting and volcanism. All five of the parameters were designed to 
identify broad geographic areas. Extensive evaluations using specific plant 
designs would be required to determine the true suitability or unsuitability of any 
specific site. 

The siting council was specifically directed to encourage the voluntary cooper- 
ation of the people, municipalities, counties. Industries, agriculture, and other 
pursuits, in establishing standards for site selection. The parameters used in 
the siting study were developed by the task force and then presented to the public 
for comment and modification. 

The siting council amended the task force's study before adopting the results 
into the siting rules and regulations. The entire water restriction parameter 
was omitted. The council decided that applicants should deal with the problem 
of water availability in terms of specific plant design proposals. The council 
also omitted the "less suitable" designation which the task force had assigned 
to some areas because there was no legal provision to support it. The "less 
suitable" areas were redistributed between suitable and unsuitable designations. 
The council also added a new study parameter, prime agricultural land. This para- 
meter was based upon U.S. Soil Conservation Service classifications and was 
defined in terms of a specific number of acres in each of the three sections of 
Oregon which can be considered for future siting. 

The areas designated suitable and unsuitable in the rules and regulations are 
subject to re-evaluation and may be amended either by the council or through peti- 
tions filed under Oregon law. By rule of the council, construction of thermal 
power plants will not be permitted in areas designated unsuitable. However, the 
council is presently concerned that lawsuits may result if an application is made 
for a site in an unsuitable area and subsequently denied because of location. It 
is hoped that negotiation can resolve such problems if they arise. 

Oregon law requires that an applicant must file a notice of intent to file 
an application for a site certificate at least twelve months prior to actually 
filing for the certificate. The notice of intent must identify the proposed site 
for the facility and a fee of $5,000 must be submitted for each site so indicated. 
Copies of the notice are then sent to a specified list of agencies and the cities 
and counties affected by the application for comments and recommendations. This 
section is intended to provide greater opportunity for the public to become aware 
of utility plans before the site certification process begins (even though these 

- 15 

plans should be reflected In long-range plans) and to allow for expression of 
opinions, which, if opposed to the application, could lead to public hearings. 
The council is also required to designate the governing body of a city or county 
where a proposed site is located as a special advisory group when an application 
is filed. 


Oregon's siting process contains many significant features which could provide 
guidance to future siting efforts in Montana. The statewide siting study was 
broadly based and was generally designed to reveal areas of outstanding unsuit- 
ability for power plant sites. The parameters initially defined by the siting 
task force are based upon eziisting federal and state environmental protection 
and public health and safety statutes. Prime agricultural land was defined as a 
resource of importance and included as an additional siting parameter through a 
direct policy determination of the siting council. The unsuitable areas designated 
by the study were formally included in the siting rules and regulations and the 
state considers them closed to future siting. Montana could conduct a statewide 
study of this type. Further discussion of this topic will be presented in the 
analysis at the end of this section. 

One aspect of Oregon's energy research activities has presented a problem 
which directly affects the state's long-range site planning efforts. As mentioned 
previously, the Oregon Department of Energy was established in 1975 and was directed 
to prepare independent long-range energy forecasts which could be used to predict 
the timing of construction of future energy facilities. The department's prelimin- 
ary efforts to meet this responsibility were challenged from several standpoints, 
including accuracy of data input, application of econometric analysis processes, 
and general conclusions. This type of problem is best understood when con- 
sidered in terms of the complexities involved in making reliable energy demand 
forecasts. Additionally, the Oregon energy agency was making its first effort 
in this area. If Montana eventually assumes a similar energy forecasting respon- 
sibility, initial planning and evaluation of the implementation processes and 
problems encountered elsewhere will be essential. The following discussions 
of Maryland's and California's siting situations present different perspectives 
on this topic. 

Oregon's siting law contains two public involvement provisions which the 
State of Montana should consider. These are, respectively, the notice of intent 
requirement and the directive which requires the siting council to encourage 
voluntary cooperation from various sectors of society in establishing standards 
for site selection. The notice of Intent clause provides the opportunity for the 
public to become aware of potential site proposals and to express opinions at a 
preliminary point in the siting process. The state and the applicant are given 

- 16 - 

strong indications of public attitude before Iprge amounts of time, funds and 
study efforts have been committed to a particular site. The state and the 
applicant also are given additional time to clarify major issues or points of 
disagreement concerning a particular application before official state studies 
begin. The 12-month "notice" period provided by Oregon law would not be adequate 
for evaluating the potential impacts of a site on a quantitative basis, but 
qualitative impact determinations could be made. However, some source of funding 
must be provided to support this activity. 

B. Washington 

The energy facility siting situation in the State of Washington is substantially 
different from the other states discussed in this section because approximately 
80 percent of Washington's energy is supplied by publicly-owned and operated 
utilities which collectively comprise the Washington Public Power Supply System. 
The long-range plans of these utilities, as well as all other utilities serving 
the general Pacific Northwest Region, are published annually in a document entitled 
the "West Group Forecast". The availability of this information essentially 
explain the absence of a clause in the Washington siting law requiring submission 
of long-range utility plans. Additionally, the siting law does not require a state- 
wide siting inventory. 

Washington's energy office was established by the 1975-76 Legislature and was 
given responsibility for collection of all types of energy-related data and prep- 
aration of analyses "necessary for development of recommendations with respect to 
the timing of construction of additional facilities and other energy programs 
(Section 80-50 et seq. , R.C.W. 1976). Additionally, this office is responsible 
for development of conservation plans, preparation of contingency plans for dealing 
with energy shortages or emergencies, and generally advising and supporting other 
state agencies in energy-related matters. 

The Washington siting agency is the Energy Facility Site Evaluation Council, 
This council was established through 1976 amendments to the original Washington 
siting legislation of 1970 and is comprised of the directors of 14 state execu- 
tive departments, as well as temporary representatives from each county affected 
by individual site applications. The director of the energy office serves as the 
council's non-voting chairman. The council's primary responsibility is the 
evaluation of energy facility site applications. Since both the council and the 
energy office function with very limited staffs, consultants are contracted to 
conduct the site evaluation studies. These studies and the recommendations of 
the council are forwarded to the Governor, who makes the final decision to approve 
or disapprove an application. 

The law presently requires the director of the Department of Commerce to work 
with the energy office in expending funds appropriated by the Legislature to acquire, 
develop and operate land and facilities which will foster development of the state's 
nuclear economic potential. This provision has existed since 1961 and was utilized 
to lease land for burial of radioactive wastes. It may be repealed or transferred 

- 17 - 

to the energy office in the near future (Adair 1976). 

Although the siting council was not given authority to undertake a statewide 
siting study, the siting law does provide for preliminary review of potential sites 
if an applicant chooses to request such a review prior to actually filing an appli- 
cation and furnishes a $10,000 fee to finance the study. It appears that the 
state has no authority to modify utility plans at this stage, but the process is 
designed to reveal problems with potential sites which could result in many types 
of modifications in the facility application (up to and including relocation of 
the proposed site). Additionally, the process provides a means of informing the 
public of facility siting plans, although there is no specific provision for public 
input. The first site review conducted under this provision is presently being 
completed. The siting act also contains a "notice of intent to file" provision 
similar to that required hy che Oregon law, except that no fee is required and 
the notice period is 90 days. The notice must indicate the general location for 
the proposed facility. 

In the absence of a state-initiated site screening study, the public utilities 
of the Washington Public Power Supply System commissioned their own statewide siting 
study. The initial phase of the study, published in December 1975, considered seven 
parameters in identifying suitable site candidate areas (WPPSS 1975; Adair 197fS). 
The study has since progressed toward identification of nine potential specific sites, 
with emphasis on nuclear facilities. No actual site applications have been based 
upon this study to date, but the state considers it a useful planning tool contain- 
ing information which will be considered in reviewing future site applications 
(Adair 1976)- It should be noted that Washington does not have a statewide land 
use plan. If such a plan is ultimately required, the state would have to initiate 
its own statewide site screening study (Adair 1976). 

The analysis and ultimate determination of need for a proposed facility has 
not been a well defined process in Washington. The siting council's role in assess- 
ing need is particularly ambiguous because, on one hand, the council is required 
by the state environmental policy act to analyze alternatives to a proposed 
facility (and must, therefore, indirectly deal with the need to be filled by the 
facility). On the other hand, a need analysis is not mandated in the siting act 
and apparently may not be considered in the council's consideration of a facility 
application. Therefore, the siting council's role is rather strictly confined 
to site evaluation. 


Washington's siting agency has the most narrowly defined area of jurisdiction 
and analysis responsibilities of any of the states considered in this study. The 
authorization to acquire all pertinent energy-related information from energy 
producers, suppliers, and consumers is granted to the state's energy office, and 
the data analyses and forecasts subsequently developed by this agency are used 

- 18 - 

by the Governor in approving or denying energy facility applications. 

Washington's siting situation Is comparable to Montana's in some respects, 
although Montana's siting agency is responsible for determining the need for 
proposed facilities. Since the Washington siting act does not call for a state- 
wide siting study and also does not require an applicant to submit to a preliminary 
site review process or to reveal the location of a future facility except as pro- 
vided in the 90-day notice of Intent period, the state must evaluate site appli- 
cations solely on a case-by-case basis. The public nature of most utility plan- 
ning activities in Washington may offset this situation. Also, long-range site 
planning advantages of a statewide site screening study have been provided by 
the Washington utilities. However, if this type of study tool is to provide the 
widest possible basis for use in state siting decisions, it should most properly 
be undertaken by the state with input from all concerned parties, including 
utility interests and the public at large. 

C. North Dakota 

The North Dakota Energy Conversion and Transmission Facility Siting Act was 
passed in the closing days of the 1975 legislative session, but for purposes of 
actual siting, the effective date of the act was December 1975, when the siting 
rules and regulations were adopted. The siting act and the rules and regulations 
must be considered together in order to obtain a complete understanding of North 
Dakota's siting process. 

The North Dakota Public Service Commission (PSC) was assigned the responsibility 
of administering the siting legislation. The first task of the commission was 
to "initiate a public planning process where all interested persons can partici- 
pate in developing the criteria and standards to be used ... in preparing an 
inventory of potential energy conversion facility sites and transmission facility 
corridors and to guide the site suitability evaluation and selection process" 
(Section 49-22-OA, N.D.C.C. 1975). All future applications for sites will be 
evaluated in terms of this inventory; however, all applications filed thus far 
have been emergency cases which have been processed on an expedited time schedule 
specified in the act (Englerth 1976). 

Two citizen advisory committees were formed in May 1975 to propose the 
criteria for locating energy conversion facility sites and transmission corridors, 
respectively. Several public meetings were held by the committees during the 
summer of 1975 to gather public input for criteria development. 

The committee was guided by a list of evaluation factors included in the 
siting act and also by North Dakota's policy of siting facilities so as to pro- 
duce minimal adverse effects on the environment and the welfare of the state's 
citizens. It was decided that certain areas of the state would be designated 

19 - 



"exclusion" or "avoidance" areas because of their uniqueness or susceptibility 
to adverse environmental effects. Exclusion areas are completely removed from 
siting consideration and avoidance areas are considered "last choices" which 
would be utilized only on clear demonstration that no reasonable alternatives 

The criteria developed for the siting inventory were based upon the exclusion 
and avoidance categories and included legally designated parks, wildlife reserves 
and historic sites as well as other types of scenic, recreational and natural 
areas at the national, state and county administration levels. Additionally, 
critical habitat areas for endangered or rare animal and plant species were 
included as were areas of prime farm land and irrigated land and areas within 
city limits or the boundaries of military installations. It was also recognized 
that "buffer zones" would be required to preserve the quality or nature of some 
criteria types. The width of the buffer zones were determined on a case-by-case 
basis. The exclusion-avoidance criteria were mapped for each county in the 
state and published in July 1976 as the site inventory. 

At present, the siting act calls for criteria and an inventory to designate 
specific potential energy conversion sites and transmission facility corridors. 
It appears, however, that this provision may be amended in the near future, thus 
leaving the task of specific site identification to applicants, who can then make 
site applications based upon specific facility design criteria as well as the i 
information provided in the inventory (Englerth 1976). 

The criteria selection committees developed a number of site-specific criteria 
which were not actually mapped in the inventory but which are intended to provide 
guidance to future site selection efforts. These criteria fall within the 
avoidance categorization and include: (a) areas where surface water drainage or 
groundwater flow patterns would be adversely affected; (b) zones surrounding rural 
residences, businesses or communication facilities; and (c) areas of unspecified 
scenic, recreational or paleontological significance. Other socio-economic- 
related criteria are also included. 

Additionally, a separate listing (partially presented below) delineates 
criteria which would cause the PSC to give preference to a proposed site: 

(1) Recycling of conversion by-products and energy conservation 
through location, process and design. 

(2) Utilization of available labor in the state. 

(3) Economic benefit to residents of the area and state 
in general. 

(4) Non-relocation of residents. 

(5) Economies of construction and operation. 

(6) Commitment of a portion of the energy for use in the state. 

(7) Use of a primary energy source or raw material located in 
the state. 

- 20 - 

It is unclear how some of these positive site selection criteria may actually be 
dependent upon specific sites; nevertheless, they are specific factors for appli- 
cants to consider in order to receive the most favorable evaluation of their site 
proposals. All of the criteria discussed above are officially included in North 
Dakota's siting rules and regulations. 

North Dakota's siting process requires two types of long-range plans from 
potential applicants. The ten-year plans must include information regarding 
demand projections and future facility needs, as well as a description of on- 
going efforts by the utility to coordinate its plans with other utilities to 
meet regional needs. A second long-range plan requirement concerns "facility 
development plans" which must be submitted by "every utility which owns, operates 
or plans within the next five years to start construction, own, or operate" an 
energy facility (Section 49-22-06, N.D.C.C. 1975). The plans must be submitted 
annually, following publication of the site inventory and criteria described above. 
The plans must identify the tentative preferred site (or corridor) and at least 
one alternative and give preliminary indication of the potential environmental 
impact of the proposed facility. The act presently states that sites or corridors 
may be selected from the inventory of potential sites and corridors published by 
the commission or they may be selected and proposed solely by the utility. This 
provision presumably will be amended if the provision requiring state identification 
of sites is revised. 

An additional provision included in the rules and regulations requires an appli- 
cant to file a letter of intent to file an application at least one year prior to 
beginning construction of a facility. This enables the commission to determine if 
it has jurisdiction over the facility and to plan for processing the applica- 
tion. The applicant must obtain a certificate of site compatibility before 
beginning construction, but it should be noted that after July 1977, the processing 
time for a major facility application will be only six months and for a transmission 
facility, three months. This expedited process will depend upon the pre-application 
planning and evaluation capability provided by the criteria, the siting inventory 
and the various long-range plans. However, the shortened evaluation period will 
require careful review in the future to ensure that enough time is provided to 
make adequate studies. 


North Dakota's siting legislation has not existed long enough to be analyzed 
in terms of its complete operational capability. The potential for systematic 
state involvement in applicants' site selection activities and for examination 
of the need for facilities through a ten-year period are evident. North Dakota 
has not specifically addressed the problem of insuring compliance with the intent 
of the long-range plan requirements nor has it chosen to pursue detailed involve- 
ment in energy demand forecasting through its siting act. 


- 21 - 

Public Involvement In North Dakota's siting process is partially defined by 
a provision which directs the siting commission to appoint citizen advisory 
committees to assist in criteria development. Additionally, there is provision 
for appointment of "evaluation and selection committees" for each facility appli- 
cation received. These citizen committees serve in an advisory capacity and are 
composed of three utility representatives, one representative from the Montana 
Department of Agriculture, and representatives from each county and city where 
a facility would be located. This type of committee has not yet been organized 
for a specific application (Englerth 1976). 

One serious problem in North Dakota's siting process has been the lack of 
provision for adequate staffing or funding to meet the mandates of the siting act. 
A minimal staff from the state's land reclamation division was assigned to perform 
staff responsibilities for the siting act. This group's activities have been 
basically limited to evaluating the information supplied with the transmission 
facility applications thus far received under the siting act. The siting inventory 
was conducted by a private consulting firm. A recommendation to the legislature 
for increased staff and funding is expected in the immediate future. 

The general structure of North Dakota's site planning activities could be 
applied to Montana in terms of scope and the types of criteria which have been 
developed. This consideration will be discussed further in the analysis at the 
end of this section. 

D. Minnesota 

The Minnesota siting act was passed in 1973, and was used as a pattern for 
several of the provisions included in the North Dakota siting law. These two 
laws and their accompanying rules and regulations feature similar requirements 
for a siting inventory to identify suitable sites and corridors and include similar 
sets of criteria to guide the selection and evaluation of preferred sites. The 
two laws also feature somewhat similar long-range plan requirements and both laws 
include provisions for citizen advisory committees to assist in criteria develop- 
ment and to provide public input into the overall siting process. The description 
of these portions of the North Dakota law also applies to the Minnesota siting 

In Minnesota, the determination of need for a proposed energy facility is made 
by the state energy agency before the siting authority, the Minnesota Environmental 
Quality Council (EQC) , completes its site-related studies. These two agencies 
and processes have a complex relationship which requires further clarification 
(Hynes 1976). The energy agency is responsible for conducting independent energy 
demand and forecasting studies which are compared to the 15-year, long-range plans 
required annually from the state's utilities. At present, the energy agency issues 
a certification of need for a specific facility application rather than certifying 

- 22 - 

the need for a certain amount of energy generation. This affects siting con- 
siderations in terms of plant size and design and thus infringes, to some degree, 
upon the siting evaluation options open to the EQC. A clearer definition of the 
responsibilities of these two agencies Is necessary. 

In addition to 15-year, long-range plans, utilities must submit five-year 
facility development plans similar to those required by North Dakota. Minnesota's 
siting law does not include a "notice of intent" clause. 

The funding provision for Minnesota' s siting process Is notable In that the 
EQC's baseline environmental studies, siting criteria development, site Inventory 
preparation and other activities not Involved In the evaluation of specific applications 
are financed from an assessment made annually by the council against the state's 
utilities. Each utility's share is based on a percentage of its annual gross 
revenue from retail kilowatt-hour sales in the state expressed as a ratio of the 
total sales and revenue of all utilities in the state. The council's assessment 
must be based on its actual annual expenses with provision for adjustments of over- 
payments or underpayments for each utility. 

Minnesota's siting process features a strong general policy of public partici- 
pation. This includes the establishment of a power plant siting advisory committee 
which may be composed of 15 to 25 persons appointed by the EQC for a one-year term. 
The committee must Include a majority of private citizens and at least one repre- 
sentative each from the utilities, regional development commissions, county govern- 
ments and municipal governments. Additionally, advisory committees are formed for 
each individual site or corridor application considered by the EQC. The EQC is also 
required to hold an annual public hearing regarding its Inventory of potential sites 
and corridors, its regulations and any other aspects of its activities set forth in 
the regulations. These features should be closely examined for application to Montana's 

The Minnesota power plant siting advisory committee developed siting criteria 
and subsequently conducted a statewide siting inventory which identified suitable 
candidate siting areas from portions of the state not specifically removed from 
consideration by exclusion and avoidance type criteria. Minnesota's law presently 
requires the state to identify specific suitable sites. At the time the inventory 
was published in 1975, the identification of candidate areas was considered an 
Interim step toward this goal. 

The siting committee was aided by the EQC and an outside consultant firm in 
developing the siting criteria. The committee set up a series of educational 
forums to obtain information on the technology, environmental impact and primary 
policy issues involved in siting power plants. It was decided that nuclear and 
fossil fueled plants should be evaluated separately where their site requirements 
and environmental impact potential differed. Site requirements and site impacts 
relating to engineering or plant design characteristics were calculated for a 
1,000 megawatt unit. 

- 23 

A number of policy issues required analysis and decisions before the inventory 
could proceed. The committee was aided by the following list of "preferred" site 
selection criteria included in the Minnesota siting rules and regulations (Minn. 
Regs., MEQC 74(c)(3)): 

(aa) Preferred sites require the minimum population displacement 
and disruption of local communities and institutions. 

(bb) Preferred sites minimize adverse health effects on human 

(cc) Preferred sites do not require the destruction or major 

alteration of land forms, vegetative types, or wildlife habi- 
tat which are rare, unique, or of unusual importance to the 
surroi'nding area. 

(dd) Preferred sites minimize the visual and audible impingement 
on waterways, parks, or other existing and proposed public 
recreation areas, 

(ee) Preferred sites minimize the removal of valuable and productive 
land and water from other necessary uses and minimize conflicts 
among water users. 

(ff) Preferred sites maximize reliability with respect to climate 
and geology. 

(gg) Preferred sites permit significant conservation of energy or 
utilization of by-products. 

(hh) Preferred sites are located near large load centers. 

(ii) Preferred sites maximize the use of already existing operating 
sites and transportation systems, 

(jj) Preferred sites allow for larger rather than smaller generating 

The rules and regulations include a similar list of criteria for corridors and 
transmission line routes. 

Some of the policy questions examined by the committee are presented below. 
Detailed statements which expressed the majority opinion on each issue were pub- 
lished with the site Inventory (MEQC 1975). 

(la) Should water Impoundment be allowed to provide make-up water 
during dry years from smaller streams? 

(lb) Should a distinction be made in the kinds of Impoundments to be 

- 24 - 

(Ic) Should criteria be established for determining what portion 
of a stream can be diverted for storage and consumption? 

The majority voted "yes" on all three questions, 

(2) Should the inventory identify areas suitable for power parks 
(assumed generating capacity of 15,000 to 20,000 megawatts)? 

The majority voted "no", due to the lack of adequate informa- 
tion needed to answer important questions raised by this issue. 

(3) Where should power plants be located relative to urban 

The committee favored locating fossil fuel plant sites close 
to urban areas, but stated that nuclear plant siting should 
be more conservatively considered in relation to safety para- 

(4) What consideration should be given to proposed land uses? 

Proposed land use was left for future, more detailed investiga- 
tions in regions identified as siting candidate areas; existing 
land use was included in the study. 

(5) Should unreliable or marginal data be used? 

This issue was resolved by creating a "supplemental considera- 
tions" category which included important Information not con- 
sidered accurate enough for inclusion in the inventory. 

The state was inventoried at a mapping scale of 1:500,000. As noted above, 
there were Inadequate existing data for some of the environmental elements con- 
sidered most important in determining suitability or unsuitability for siting. 
These supplemental considerations included air quality, hydrology, water quality 
and geologic hazards. The environmental elements which were included in the 
inventory were either considered constraints to siting or opportunities favorable 
to siting. These elements were classified and combined by the process shown in Figure 
III-l on the following page. 

The final results of the inventory included the identification of 40 candidate 
siting areas for either nuclear or fossil fueled power plants. The areas ranged 
in size from 428 square miles to 3 square miles. 

- ^J - 

Figure III-l 











Fedora! Reguiotions — 
State Regulations — 
ExcluJcd Land Ai eas 


Land Use Areas 




Indian Reserx'ations — 
Military Reservations 

Laixl Forms 


National Forests 
Wildlife Habitat - 

Visual & Audible Buffers — 

for Recreation Areas - 
Agricultural Lands — — 
Forest Larvds 

Iron, Copper-Nickel 







Water Supply —. 
Load Centers — 
Highways — 






Other Wildlife 

Other Vegetation 

Otlier Social/Cultural 
Geologic Hazards — 
Air Ouaiity 

HydrologyAVater Ouaiity 


- 26 - 


Minnesota's siting inventory was published in Tnid-1975 with the expectation 
that review by the public, the utilities and other state agencies would result 
in modifications of the criteria and the candidate areas maps. However, the 
inventory was not accepted by the EQC. Some of the major criticism of the study 
originated within the Minnesota state agencies. A major topic of contention has 
concerned the relative accuracy of the data which were used in the study and the 
effects created by eliminating other types of data. 

Another major problem concerned public interpretation of the candidate area 
maps. The siting committee Intended that the maps would provide geographic guide- 
lines for the state and the utilities to consider in searching for suitable sites. 
The maps were not Intended to precisely define areas where siting would be absolutely 
prohibited or specifically allowed. Sites could be proposed in areas not specifi- 
cally designated as candidate areas, but this was not generally understood by the 
public, and the utilities expressed strong objection to the potential public 
pressure which they felt would result if the maps were formally accepted by the 
state and then not "followed" in future site proposals. 

Still another related problem concerns the siting act's requirement that the 
state Identify specific suitable sites. The candidate area Inventory was intended 
to provide the principal basis for a specific site selection study. Since the 
inventory was unacceptable, the EQC has been meeting over the past year with other 
state agencies and utility representatives in an attempt to reorganize the criteria 
and resolve disagreements concerning the data to be utilized. 

The problems of the Minnesota siting inventory must be considered by any state 
attempting a similar study. The absence of reliable data or lack of agreement on 
the relative worth of available data is a critical problem (see Section V for 
further discussion). Also, the exact use of the inventory must be decided at the 
beginning of the study. Exclusion criteria may be developed to define areas which 
are unsuitable for siting, but many specific policy issues must be explicitly 
defined before a general siting inventory can be used to legally close entire areas 
to future siting. 

As was noted previously, Minnesota has a problem of jurisdictional overlap 
between its siting agency and the agency responsible for determining the need for 
new facilities. While it may be possible to alleviate this problem through better 
clarification of each agency's role, consolidation of the two functions under a 
single administrative unit would be a potentially more optimal arrangement. 

E. Maryland 

The Maryland Power Plant Siting Act of 1971 is one of the older siting laws 
and is certainly the most unique. The act is focused upon long-range site planning, 
scientific research for all types of power plant siting problems, and state acquisi- 
tion of potential power plant sites for future use. 

- 11 - 


Utilities are required to apply to the Maryland Public Service Commission (PSC) 
for a certificate of public convenience and necessity before a power plant or trans- 
mission facility may be constructed. However, this procedure occurs near the end 
of the siting process. A description of the process and the accompanying program 
of siting research must begin with an explanation of Maryland's site funding pro- 
vision. The siting law created an "Environmental Trust Fund" which finances all 
siting activities and research through a surcharge on the kilowatt hours of 
electric energy generated in the state. This surcharge is added to consumer power 
bills. According to the law, the surcharge may not be continued beyond 1985; in 
the meantime, it is providing an average annual operating budget of $7.5 million 
for the siting program. This budget is expended through a staff of seven profes- 
sionals and a contractual structure involving approximately 150 scientists (Maryland 
Energy and Coastal Zone Administration 1976). 

Maryland's Power Plant Environmental Research Program coordinates the scientlfi( 
research contracts which account for most of the program's expenditures. This 
program is comprised of four sub-programs which are briefly described below: 

Impact Assessment Program : This program monitors, assesses and models 
all types of environmental impact resulting from existing power plants and 
evaluates new technologies designed to minimize impact. 

Research Program : Through this program, general ecological baseline 
studies and research of Maryland's environmental resources and socio-economic 
structure are applied to the problem of siting and operating power plants with 
maximum benefit to society and minimum detriment to the environment. 

Site Evaluation Program : This program is responsible for detailed site 
suitability investigations at sites proposed by utilities and sites identi- 
fied by the state. This work forms the basis of recommendations to the PSC 
for its consideration of all facility applications. Additionally, this program 
is responsible for adopting methodologies to predict future electrical needs 
and make independent demand projections for each utility service area in the 

Site Acquisition Program : The purpose of this program is to identify, 
investigate and acquire an inventory of suitable plant sites for potential 
future use. 

The site evaluation and site acquisition programs implement the long-range 
site planning objectives of Maryland's siting process. The PSC must undertake 
"a long-range environmental evaluation of power plant building sites ... to 
facilitate providing adequate electric power on reasonable schedules at reasonable 
costs with the least possible depreciation of the quality of Maryland's environment 
. . ." (Article 66C, Section 768, Ann. Code of Md.). The PSC annually evaluates 
the long-range plans of Maryland's public electric companies and forwards a ten- 
year plan of proposed sites to the Secretary of Natural Resources. The Secretary 
is then responsible for preparing a preliminary environmental statement for each 
proposed site, and those sites deemed acceptable are investigated in detail 
through the Site Evaluation Program. The detailed site studies must be published 

- 28 - 

at least two years before any construction is expected to begin on those sites. 
An application for a facility must be filed at least two years prior to commence- 
ment of construction. 

Fn addition to the activities described above, a cumulative environmental report 
on all |)ower plants operating in the state is published biennially. This report 
addresses state environmental policy concerns and must include "a section devoted 
exclusively to the question of growth and the specific growth-related factors which 
necessitate specific additional increments of electric energy by development of a 
site in the ten-year plan". (Article 66C, Section 768(4), Ann. Code of Md.) 

The state is authorized to purchase a number of facility sites sufficient to 
satisfy the growth requirements outlined in the biennial report. The siting law 
provides for a minimum of four and a maximum of eight potential plant sites in the 
site inventory. The four sites are to be distributed through four regions (Eastern, 
North-Central, South-Central and Western Maryland) which approximate the service areas 
of the main utilities in the state. In recognition of the tight certification and 
construction schedules facing utilities, the state makes these sites available 
to utilities whose proposed sites have been judged unsuitable or whose efforts 
to acquire a site have been unsuccessful. The purchase price of a site is based 
on the appraisals of two independent agents and a utility may lease or purchase the 
site from the state at its fair market value. The state estimates that during the 
period 1973-1985, it will have acquired six sites and sold four sites, 

Maryland is just beginning to search for sites based on regional site screening 
methodologies such as those used in Minnesota, North Dakota and Oregon. Maryland 
has acquired one site in its south-central region and another site has been 
approved for acquisition in the north-central region. These sites were located 
through a general search for available tracts of land. For example, the site in 
the north-central region was federally-owned, surplus land (Massicott 1976). It 
was decided, however, that this approach presented too great a chance for over- 
looking sites which would cause the least adverse impact on surrounding areas. 
Therefore, two separate studies were initiated to develop and conduct an inventory 
process to identify candidate sites in Maryland's eastern and western regions. 

The study relating to the western region is a demonstration project being 
conducted by Oak Ridge National Laboratories (ORNL) and the Nuclear Regulatory Com- 
mission. It is nearly completed. ORNL utilized a regional siting analysis method 
known as the ORNL Land Use Screening Procedure (LUSP) (Dobson 1976). ORNL-LUSP is 
a combination of methodological and data manipulation techniques, designed to 
simulate the results or consequences of alternative siting policies. The principal 
conclusion of the ORNL study, which would apply to any state or agency attempting 
to conduct a similar inventory, is that there is no "right" set of criteria, and 
thus, there are no "best" candidate siting areas except as these criteria and 
areas reflect the official siting policy of the region under study (Dobson 1976, p. 6-1) 

- 29 - 

ORNL applied 22 separate sets of criteria to different types of facilities in 
order to demonstrate the conclusion stated above and to portray the flexibility 
of the LUSP system. The study also experimented with several sets of values or 
weightings applied to the various elements included in the study. ORNL sub- 
sequently identified candidate siting areas in Western Maryland based on the many 
sets of criteria which it developed. The Maryland siting agency will now have 
to adopt specific criteria and select a final slate of candidate areas. 

The ORNL study also tested the applicability of the Maryland Automated 
Geographical Information System (MAGI) to siting issues. MAGI is a geographic 
data base file which was designed in 197A by the Maryland Department of State 
Planning to serve a variety of needs. The ORNL study concluded that "since the 
construction of a geographic information system is the greatest potential con- 
straint to the development of an automated (site) screening procedure, the data 
base should be designed to serve diverse uses .... Costs can be minimized by 
including only those data variables which receive high importance weights on 
numerous criteria matrices." (Dobson 1976, p. 7-1). The study recommends that 
"siting criteria should be defined early enough to serve as guides in determining 
data requirements .... Geographic information systems constructed in ... an 
a priori manner contain numerous variables which are expensive to obtain, and are 
relevant only to a few specific applications." (Dobson 1976, p. 7-3). On the 
whole, the ORNL study concluded that the MAGI data were extremely accurate and 
precise. The MAGI system therefore places Maryland in an excellent position to 
conduct its own automated site selection studies once policy and formal siting 
criteria are established. 

The screening study for Eastern Maryland is being handled by a private con- 
sulting firm. Three specific sites are to be selected from the study results. 
The consultant is being assisted in criteria development by an advisory committee 
composed of representatives from each county in the study area, environmental 
groups, utilities and staff members from each of the state agencies participating 
in the power plant siting program. Two sets of site criteria must be developed: 
facility criteria, including minimum requirements for entry of various types of 
facilities into an area and the optimization factors for location (e.g., proximity 
to transportation and markets); and site and related physical /ecological and human/ 
cultural criteria. Designation of candidate areas must be accomplished first; 
detailed site-specific studies within these areas will then lead to identifica- 
tion of three suitable facility sites. The consultant is required to hold three 
public Information briefings during the candidate area selection process. 


Maryland's siting program is clearly committed by policy and statute to collect 
and analyze a tremendous volume of data. Also, the state has assumed the burden 
of public accountability for site selection. The state's position has been 
described as follows: 

- 30 - 

"(T)he state, not the applicant, should, decide on the significant 
issues to be addressed at any given site, collect the necessary data, 
define appropriate alternatives, and carry out the analyses. It is 
the ultimate of bureaucratic irresponsibility to ask the utilities to 
to prove beyond doubt that which is not provable. On the other hand, 
it is necessary that the agency given authority over siting have the 
responsibility for providing adequate energy at reasonable costs as 
well as for protecting the environment." (Md. Energy and Coastal 
Zone Admin. 1976, p. 4) 

The program's funding scheme was organized to finance its demanding data 
handling responsibilities, but a recent report indicates that prior to January 1975 
funding was lower than expected because the surcharge on electricity sales was not 
collected from out-of-state consumers of Maryland-generated power due to a loop- 
hole in the law. This problem was no sooner corrected than the rate of consumption 
of electricity fell and induced a second significant shortfall in expected revenue. 
The shortage has been absorbed primarily in the research and site acquisition pro- 
grams, and as a result, several projects have become impossible to complete on 
schedule. Due to its dependence on revenues provided by the sale of electricity, 
the siting program could be adversely affected by energy conservation measures, 
increased efficiency in the use of electricity, and other occurrences which would 
result In reduced consumption of electricity. 

The program's 1976 long-range plan indicates that national economic uncertainties 
have hampered utility planning and that uncertainties in both future demand and 
future capital availability have forced utilities to ahift construction plans "from 
long lead time, capital intensive forms in favor of designs with shorter lead 
times, lower capital cost per kilowatt installed, and smaller capacity per unit" 
(Md. Energy and Coastal Zone Admin. 1976, p. 33). This trend disrupts the siting 
program's short-terra site evaluation plans because it requires continual shifting 
of priorities in order to complete evaluations on schedule. The cost of evaluation 
has ranged up to $1.4 million per site for utility-owned sites and up to $1.7 million 
for state-owned sites. The cost difference is due to the need to develop plant 
designs for the state-owned sites. The state estimates it will be evaluating 
about 1.4 sites per year through 1985. 

Maryland's siting act requires public hearings on facility applications and 
the long-range plans of the program provide for the notification and involvement 
of local government officials in site evaluation and site selection activities. 
Additionally, there is a Power Plant Siting Advisory Council which has general 
oversight and advisory responsibility for the siting program and is composed of 
representatives from the legislature, local government, utilities, environmental 
groups, universities and state agencies. However, it appears that a policy of 
general public involvement has not been strongly mandated by the siting act nor 
has it been adopted as a major policy objective of the program. The 1976 long- 
range plan states that: 

- 31 - 

"Efforts are now under way to develop an active, rather than passive, 
interaction with the public during the evaluation process at each 
site. Although the program is completely open to the public, with 
all reports, data and communications available, indications are that 
public interaction does not yet occur early enough in the evaluation 
process." (Md. Energy and Coastal Zone Admin. 1976, p. 35) 

F. California 

Through legislation which became operative in January 1975, California instituted 
one of the most comprehensive, long-range energy planning policies in existence. 
This legislation, entitled "The Warren-Alquist State Energy Resources Conservation 
and Development Act" (Section 25000 et seq. , Ca. Pub. Resources Code 1975), created 
the Energy Resources Conservation and Development Commission (ERCDC) and assigned 
it the following responsibilities. 

(1 ) Siting and certification of thermal power plants and electric 
transmission lines. 

(2) Forecasting and assessment of energy demand and supplies. / 

(3) Development of energy conservation programs and standards. 

(4) Development of a program for research and development in energy 
supply, consumption and conservation and the technology of 
siting facilities. 

(5) Development of contingency plans to deal with possible short- 
ages of electrical energy or fuel supplies. 

The implementation of these five functions has resulted in an energy organiza- 
tion of considerable size headed by five commissioners from the following legally 
specified backgrounds: (1) law, (2) engineering/physical science, (3) environ- 
mental protection, (4) economics, and (5) the public at large. The commission 
is presently composed of approximately 230 staff members and is operating on a 
budget of approximately $25 million (Nichols 1976). Nearly half of this amount Is 
federally funded with the balance supplied through a surcharge added to consum(>rs' 
power bills. 

The commission has expended most of its efforts thus far in organizing its 
various divisions and interpreting its responsibilities. However, the extent 
of the commission's mandate, especially as related to facility siting, is out- 
lined in the following section of the law: 

- 32 

The commission shall "collect from electric utilities, gas utili- 
ties, and fuel producers and wholesalers and other sources forecasts 
of future supplies and consumption of all forms of energy, including 
electricity, and of future energy or fuel production and transporting 
facilities to be constructed; independently analyze such forecasts in 
relation to statewide estimates of population, economic, and other 
growth factors and in terms of the availability of energy resources, 
costs to consumers, and other factors; and formally specify statewide 
and service area electrical energy demands to be utilized as a basis 
for planning the siting and design of electric power generating and 
related facilities." (Section 25216(b), Ca. Pub. Resources Code 1975) 

A major responsibility of the commission is the preparation of a biennial report 
which in part, is to include: a five- and ten-year energy demand statement as described 
in the above quote; a list (with maps) of all existing generating sites, indicating 
those where expansion has been identified as feasible; a list (with maps) of areas 
appropriate for additional electric generating sites, including capacity to be 
installed, which the commission has determined will be required to meet the ten 
year energy demand. This list is only a small portion of the information required 
for the report, but it includes the main clauses relating to siting and indicates 
the potential future extent of California's involvement in energy facility planning. 
If this mandate becomes fully operational in terms of its information base and 
administrative organization, the commission could decisively share the energy plan- 
ning position traditionally held by the utility industry in California. 

Some significant portions of California's siting statute are listed and sub- 
sequently discussed below: 

(1) Designation of siting authority, 

(2) Submission of five-, ten- and twenty- year plans, 

(3) Filing of notice of intent, 

(4) Submission of site alternatives, 

(5) Designation of multiple facility sites, 

(6) Identification of unsuitable areas, 

(7) Selection of candidate areas. 

The commission has the exclusive power to certify all sites and related facil- 
ities. The issuance of a site certificate supercedes any applicable statutes or 
regulations of any state, local or regional agency, or federal agency to the extent 
permitted by federal law. It should be noted, however, that the California Public 
Utilities Commission (PUC) retains the authority to grant a facility a certificate 
of public convenience and necessity. ERCDC certifies the need for a facility and 
has exclusive authority over siting, but the PUC must evaluate a facilitiy s effect 
on the rate structure. The relationship between ERCDC and PUC requires further 
clarification in determining the need for specific facilities. The commission is 

- 33 - 

also authorized to adopt relevant land use, public safety, environmental and 
other standards, except for air and water quality, to be met in designing or 
operating facilities to protect public health and safety. 

Utilities are required to submit detailed five-, ten- and twenty-year load 
forecasts on a biennial basis. The forecasts must be computed through a standard 
methodology established by the commission and must be accompanied by a listing 
of additional generation facilities which will be needed to meet the load and 
the general location of such facilities. 

Prior to applying for certification of any specific facility, a notice of 
intent to file such an application must be submitted. This notice allows the 
suitability of the proposed site to be determined prior to the filing of the 
actual application. The notice must include three alternative site locations 
for the proposed facility(s), with a summary of the design criteria, fuels to 
be used, construction and operation methods, and a statement of the relative 
economic, technological, and environmental advantages and disadvantages of each 
alternative site. The commission is required to solicit comments on the notice 
from all appropriate agencies, hold public hearings and prepare both a preliminary 
and a final report. The notice may not be approved unless the commission finds 
the proposal in accordance with the ten-year forecast and the provisions of any 
applicable land use plans. Further, it must find the two alternative sites 
acceptable, although the commission has discretionary power to approve a notice 
based on a single site if the applicant has made a good faith effort to find 
acceptable alternatives and has failed. 

If the commission finds all of the applicant's proposed sites unacceptable, 
in spite of a good faith effort by the applicant to comply with this requirement, 
the commission must identify a suitable site for the proposed facility. The com- 
mission has not yet adopted a plan or policy for implementing this provision, 
although the candidate area selection process discussed later in this subsection 
may be refined for this purpose. 

An applicant may propose a site which will accommodate a potential maximum 
generating capacity in excess of the amount being proposed for Initial approval. 
Such a proposal must contain information regarding the ultimate number and type 
of units proposed for the site, the installation schedule, the amount of cooling 
water ultimately to be required, and a statement of the impact at the site when 
fully developed. If the commission approves such a notice, the site is designated 
a potential multiple-facility site. The commission may specify conditions to 
insure that future additional facilities will not exceed the carrying capacity 
of the site. 

All of the above described activities are completed before an application is 
filed. The maximum time allowed to complete the review of a notice of intent 
and issue a decision is 17 months, although this time may be considerably shorter. 
The commission must issue a decision on an actual application within 18 montlis of 
the time of filing. Public hearings on the application must be held no later than 
2A0 days after the filing date. A facility may not be certified unless it conforms 

- 3A - 

with the ten-year demand forecast established by the conraiission. 

The commission's role in site selection was analyzed in a staff report com- 
piled by the Facility Siting Division in September 1976. A specific provision 
In the law stipulates that parks, wilderness and natural reserves, areas for 
wildlife protection, recreation and historic preservation, and estuaries in a 
natural or undeveloped state shall not be approved for facility siting unless 
the commission determines such use is not inconsistent with the primary use of 
such land. The Siting Division has concluded that this provision effectively 
prohibits the siting of energy facilities in such areas. 

The division has developed a "candidate area selection process" to compile 
a list of areas appropriate for additional electric generating sites. Public 
input and coordination with other planning and regulatory agencies must form the 
basis of this process. The division's position is stated as follows: 

"The development of (a) Candidate Area Selection Process cannot 
occur in a vacuum. The interests of the public, voiced as a 
concern among interested citizens, or as represented by other 
state agencies, must be considered in the long-term planning for 
energy facilities. Decisions which will seriously affect the 
options for siting future energy facilities will be made with or 
without participation by the Energy Commission. It should be 
considered that it will only be by direct participation in state- 
wide planning that this Commission will retain necessary options." 
(CERCDC 1976a, p. 7) 

The staff assumes that a significant commitment to public participation must 
be made and it recommends that the commission develop and implement a program to 
achieve this objective. 

With the above considerations in mind, the Siting Division sought to develop 
a siting selection methodology which would be responsive to all types of generation 
facilities as well as sensitive to the concerns of the public. The methodology 
was split into two levels: statewide screening and regional screening. 

The first phase of the methodology requires designation of the statewide 
screening guidelines or criteria to be considered. These factors were initially 
identified within the staff and then modified through public input acquired at 
a series of four public workshops. In the absence of policy guidelines to establish 
the relative importance of various factors, it was decided that at the statewide 
level, factors would only be identified as "constraints" or "opportunities" and 
they would represent areas large enough to be mapped at a scale of 1:500,000. A 
constraint reflects some condition which would restrict siting or would be adversely 
affected by siting, while an opportunity identifies conditions or resources which 
offer advantages in siting. The factors ultimately selected for inclusion in the 
statewide screening process were further categorized in terms of high avoidance 
areas and significant areas . The former category includes factors representing 
"last choice" areas which are either an important resource or a hazard to 
potential sites. The latter category includes factors which should be given 

- 35 - 

special consideration in area-specific site planning, but which remain undefined 
in importance at the statewide level. An example of some of these factors or 
criteria and their respective classifications is presented in Figure III-2 on 
the following page. 

These factors allow some reduction of the total study area to be considered. 
However, identification of actual candidate areas will not be accomplished at the 
statewide level. The statewide criteria are primarily of use in evaluating the 
site planning programs of utilities and in providing a framework to define how 
and where other agencies may have already limited siting options. The statewide 
factors also provide important "signals" to the utilities concerning the informa- 
tion and conditions the state considers important to siting. 

The regional screening process has not been undertaken. Whereas the factors 
included at the statewide level were deliberately not weighted or compared, factors 
to be used in regional screening must be more specific and must be weighted in 
terms on their relative importance and potential magnitude of Impact. Further, 
at the regional level, factors must be developed for each power plant type and 
fuel type. These may vary in importance in different regions. Also, public 
involvement in the regional screening process would require more emphasis than 
at the statewide level. 


The regional screening process was formulated, in part, to cope with the plan- 
ning problem presented by California's geographic diversity. The regions of the 
state vary greatly in their geographic/natural environmental features as well as 
in their energy demand characteristics. It may be necessary to study the regions 
somewhat independently in order to accord all areas fair treatment. 

Certain types of areas are granted special status under California law which 
removes them from favorable siting consideration. However, it is Important to note 
that California has chosen to develop only "high avoidance" criteria rather than 
exclusionary criteria, except where areas are legally protected from siting. The 
commission probably does not have the authority to close an area to siting on the 
basis of its own policy delineations. Further, the California siting division 
staff believes that very few areas not already legally protected from siting are 
totally incompatible with all forms of energy facilities. For example, if all 
state forest lands were declared closed to siting, it could be argued that a 
small hydrogeneration facility would not adversely Impact the primary uses and 
characteristics of the area. Montana will have to deal with these same consider- 
ations in deciding how to protect the natural and cultural features it deems most 
important. In the absence of a definitive policy for assigning "importance" to 
the many factors required to select candidate areas (or to rule out other artMs 
not specifically protected by statute) , California may not make specific site area 
designations and instead may concentrate on developing sound criteria to guide the 
utilities in their specific site selection activities for given plant types 

- 36 - 
Figure III-2 




1. Prime Ai'.ricu] tura] Land 

?. Af.rirul t ur;i] Pic serves 
3. Kacl] anils 

A. Parks nn:l V'ildcrnosE Arcar 

5. Coiistn] Zone 

6. - Coastal Scenic Areas 

7. - Consla] Mon-.«renlc Areas 

8. - CoarUal Inciiist rial-L'rban 

9. Coastal PvOGcrve Arcr.s 

10. l^esert and Sciri-arit! Art as 

11. Sceni c llighv.'ays 

12. Existing Energy raclJitlcs 

13. Military Bar.os 

JL4.. r_Act 1 v(^ Kil It ary_ r.asr s 

- Boirb and MisL;ile 'J'aviint 
15. Areas and "est Arenr. 

- Surplus !!i]itary 
16. rro{>prty ^ 

17. State and National I'ovcsts 

- National Forest Wijder- 

18. ness & p Ir.iltlve Areas 
flir.torical , ArcTiaeolof.icil 

19. and Cultural Resources 

- Desif.iiatod Historical, 
20. Arciiaclof.ical T, Cultural 
— -/.Tear;" 

r.t .il iwiile 

~. nj II i t - 
j l.llll 








rj ll 

i: U' 


Proposed addition - public 

'■Piopoced addition - staff 

*Proposcd addition - public 

''Proposed add ition - public 

Proposed addition - public 

Proposed add 't I.or,_r_r' 1 9 Lf_ 
Proposed addition - staff 

Propos ed ad rilli(-n - staff 

Proposed addition - staff 

Delete - see below 

Proposed addition - staff 

•Proposed .'.[ic'cia) .'tuJy 

- 37 - 

and designs (Nichols 1976). 

It is unclear how the commission will eventually interpret its legal directive 
to identify candidate site areas. Recent information indicates that the site 
selection methodology will not be implemented beyond the delineation of broad 
statewide criteria and equally broad identification of "areas of importance" for 
any type of development activity. It appears that a major factor in this deci- 
sion is the problem of coordinating all of the various levels of administrative 
and regulatory agencies and their accompanying policies in a manner which would 
permit the regional siting process to occur. Although the commission has the 
legal mandate to command this type of coordination, it may not be exercised in 
accordance with the selection of candidate siting areas. 

The long-range planning advantages of combining comprehensive energy demand 
research and conservation activities with the energy facility siting function are 
quite obvious. An administrative arrangement of this type may not be organizationally 
feasible for the immediate future in Montana. However, this approach should be 
seriously evaluated as a long-term planning option. 

The relationship between long-range facility siting and land use planning 
is another complex area which must be considered. Montana presently does not have 
a comprehensive land use plan and most land use responsibility currently rests 
with local government. Land use planning is inherently a process of balancing 
competitive needs; siting decisions should be closely coordinated with this process. 
California has not yet achieved this coordination, but as was mentioned above, 
its energy commission has the authority to deal with the problem as well as 
specific authority to set land use standards to be applied to the design and 
operation of energy facilities. 

G. Analysis 

The six state siting processes reviewed in this section provide a basis for 
discussing the choices, opportunities and problems the State of Montana must con- 
sider in developing its own siting process. This report has been based upon the 
assumption that Montana must become involved in long-range energy planning and 
energy facility site selection if optimal decisions are to be made in the future. 
A large portion of this report is concerned with the development of siting criteria 
and application of the criteria to classify areas of the state in terms of their 
suitability for siting. However, it must be emphasized that this activity cannot 
occur in isolation. It is dependent upon state involvement in the projection of 
long- and short-term energy demand and the subsequent determination of the need 
for new facilities at a point in time which will allow optimal site planning to 
occur. It is also dependent upon technological developments in plant design and 
size and the potential future reduction of many types of adverse environmental 
impact. Further, in a fundamental sense, site planning depends upon interagency 
coordination, public involvement, and availability of information. 


38 - 

One long-term aspect of energy planning which the State of Montana must define 
is the level of involvement it will have in the determination of need for future 
energy facilities. The States of California and Maryland have established a leg- 
islative framework which, in theory, allows them to assume, or at least jointly 
occupy, the position traditionally held by the utilities in forecasting energy 
demand. In a less broadly defined sense, Oregon and Washington also are making 
independent analyses of the information included in utility long-range plans. 

These four states have had varying success in fulfilling their planning roles, 
and in California in particular, the process is so new that a definitive evaluation 
cannot yet be made. Both Maryland and California are characterized by extremely 
well funded programs which can provide broadly-based expertise in making defensible 
energy demand projections. Recent information from California indicates that, 
for the present, projections will be developed for general regions and service 
areas in the state, but that there will be no attempt to specify the number of 
megawatts required (Brown 1976). Maryland has apparently been able to meet its 
responsibility for developing an on-going, ten-year plan which delineates all 
future energy facilities needed for the ten-year period. However, the exact 
relationship or differences which have existed between this plan and the infor- 
mation submitted by the Maryland utilities is not known. 

Energy demand forecasting is not the major concern of this report. However, 
a state cannot adequately prepare for the siting of future energy facilities unless 
it possesses the best available information for determining the amount of energy 
which will be needed at a future point in time. Utility long-range plans have been 
the chief source of this information, but general experience has shown that due to 
differing objectives and responsibilities, the utilities and the states are fre- 
quently in disagreement on many aspects of forecasting methods and results. The com- 
plexity involved in making forecasts compounds this problem. Further, forecasting 
"formulas" utilized in the past have proven increasingly inadequate for preparing 
forecasts which accurately reflect changing energy consumption patterns and the 
increased effects of energy conservation measures over the past four or five 
years. As a result of these changing trends and related economic uncertainty, 
utilities have had to shorten the planning periods or "lead times" allowed for 
developing new energy facilities. At the same time, the states have had to 
become much more involved in the formulation of energy projections in order to 
avoid being "surprised" by sudden, legitimate needs for new facilities which could 
confound long-range site planning efforts. The primary means of avoiding this type 
of situation is to insure state access to energy supply and demand data, conserva- 
tion data and research concerning alternative means of meeting energy needs. 

The level of state involvement in energy demand forecasting outlined by the 
Maryland and California laws may not be essential to insure adequate state access 
to necessary information. For example, Oregon and Washington conduct independent 
demand studies with relatively small staffs and budgets. California law requires 
all utility demand projections to be formulated according to a methodology developed 
by the state, although the utilities may submit additional information using their 
own processes. This provision may potentially simplify the state's analysis of 
the utilities' projections and it could alleviate some of the need for state 

- 39 - 

duplication of utility forecasting activities. A similar provision in Montana's 
law could greatly enhance the state's position in dealing with energy demand infor- 
mation while a broader program of state involvement in this area is being considered. 

The utility long-range plans required by the siting act are presently a 
principal source of energy demand information available to the State of Montana. 
Although the general national uncertainty surrounding accurate determination of 
future need for energy facilities may not be easily overcome, the information 
included in utility long-range plans must be accurate to the greatest extent pos- 
sible. The problem of insuring accuracy could be handled by adding a special 
enforcement clause to the Major Facility Siting Act which would specifically apply 
to the long-range plans and would provide the state with some recourse if informa- 
tion in the plans is found to be incomplete or falsely presented. Also, maximum 
interaction should be encouraged between the state and the utilities in formulating 
energy demand fore'^asts and in sharing all types of relevant information. It is 
imperative that the State of Montana remedy its present position of determining 
the need for a proposed facility solely on the basis of the individual application 
evaluation process mandated in the siting act. The state must be intimately 
acquainted with the potential need for a facility within a time frame that is 
equivalent to the applicant's initial planning activities. 

A statewide siting study and development of site criteria are activities 
which respond to the problem situation described above. If the state can pro- 
vide an informational and geographical framework to guide the utilities' initial 
facility planning and siting studies, the application and evaluation process can 
be streamlined and will permit much more effective use of the evaluation time 
period presently provided by the siting act. This front-end involvement would 
certainly be preferable to the state's present reactive position in the siting 

The scheduling of site criteria development and a subsequent statewide siting 
inventory must be clarified. A siting study cannot proceed until appropriate 
criteria have been developed. The following section of this report discusses the 
types of problems and issues which must be considered in this process. Criteria, 
in turn, depend upon the type of study mandated by the state's siting legislation. 

The six states analyzed in this report essentially represent three siting 
inventory alternatives and one situation which is basically comparable to Montana's 
present siting process. This latter example is the State of Washington. In the 
absence of a state mandate to conduct a siting inventory, an inventory was 
initiated by the publicly-owned Washington utilities. It is questionable whether 
such a study would provide an appropriate basis for state decision-making; however, 
the preferred site selection criteria and the methodology used in the Washington 
study should be examined for potential applicability to a state-initiated study 
in Montana. 

The three inventory alternatives mandated in the other five states' siting 
legislation may be characterized as follows: 


40 - 

Maryland Responsible for selection and acquisition 

of sites. 

California Responsible for designation of specific 
Minnesota suitable sites. 
North Dakota 

Oregon Responsible for designation of suitable 

and unsuitable areas. 

The characteristics of the siting inventories conducted in each state are summarized 
in the table on the following page. 

Maryland's unique siting process is based upon a program of extensive siting 
research and an extremely expensive commitment to site-specific studies. Appro- 
priate funding is a key element which must accompany a program of this type. Mary- 
land's land use situation is a major factor underlying its siting process. The 
competition between varying types of land uses is so intense on a statewide basis 
that the state felt it necessary to acquire specific sites, especially sites repre- 
senting the least total adverse impact to surrounding areas, in order to preserve 
them from other conflicting land uses or development before they can be utilized 
for future energy facilities. Montana may never be characterized by this type 
of problem. The expense of conducting the site-specific studies required to justify 
the direct selection of sites may not be warranted. Also, in this type of siting 
process, the state is ultimately responsible for regulating activities at the sites 
it selects. Further, this approach would require the state to assume some respon- 
sibility for the design of future facilities in order to select appropriate sites. 

Maryland's approach would not be feasible for Montana without entirely recon- 
structing the existing siting legislation and creating a new funding mechanism, pre- 
sumably similar to Maryland's and California's surcharge on consumer power bills. 
Also, this type of siting process might not be necessary to insure that optimal sites 
are chosen for energy facilities in Montana. 

At present, California, North Dakota and Minnesota are legally responsible for 
designation of specific suitable sites. Thus far, these states have not fulfilled 
this responsibility. A review of the subsections for each state will show that 
North Dakota has completed an inventory of unsuitable areas based upon exclusion/ 
avoidance criteria at the county level and is presently considering amending its 
law to require only this level of study; Minnesota completed an inventory which 
reached the level of identifying candidate site areas from larger areas not desig- 
nated unsuitable. Due to problems with basic resource data and problems of 
coordination between various state agencies, the study was not accepted. Efforts 
to resolve disagreements and develop revised criteria are presently on-going; 
California developed a regional process for identifying candidate areas, but the 
anticipated problems involved in achieving interagency coordination for a more 
detailed study have, for the present, halted this process at the point of develop- 
ing general statewide criteria which will identify broad areas of "importance" 
to siting and other forms of development. 

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- 42 - 

Oregon's law calls for designation of areas suitable and unsuitable for 
siting. This designation was accomplished through a broadly defined, regional 
inventory using very general criteria. It is important to note that Oregon con- 
siders its unsuitably designated areas closed to siting. North Dakota's existing 
situation is quite comparable to Oregon's even though the legal mandates of the 
two states are presently quite different. The actual prohibition of siting in 
an unsuitable area may not be necessary if a state's unfavorable consideration 
of applications for sites in such areas is guaranteed. This topic will require 
further legal analysis before Montana's specific course of action can be deter- 

The relative uncertainty presently characterizing the siting processes 
in Minnesota and California must be carefully considered. Both states are question- 
ing the advisability of actually identifying specific suitable sites for all the 
reasons mentioned above in relation to Maryland, as well as the attendent adverse 
effect this type of designation can have upon an area before development occurs. 
The disadvantages of direct site selection may, in fact, outweigh the advantages. 

Both Minnesota's and California's siting agencies are apparently in favor 
of carrying the siting process as far as identifying candidate siting areas from 
a more general designation of suitable and unsuitable areas. As noted previously, 
this would involve the application of preferred siting criteria ( i.e. , criteria 
designating geographic elements favorable to siting) to areas not designated 
unsuitable in a more general, regional study. 

This step must be evaluated at both theoretical and practical levels. The 
more specific the criteria and size of area to be considered, the more precise 
the data requirements and the more intricate the required coordination between 
various regulatory and administrative agencies. In a practical sense, these two 
considerations are responsible for most of the problems in both California and 
Minnesota. It is essential to note that Montana will be confronted by these same 
concerns in conducting any type of siting inventory. On a theoretical level, 
there may be advantages to designating suitable candidate siting areas; however, 
the same legal problems involved in closing some areas to siting would apply if 
the intent, in this instance, was to permit siting only within candidate areas. 
If, on the other hand, candidate areas primarily are intended to serve as strongly 
recommended geographic guidelines for future siting, it appears that the same 
objective could be served by designating areas unsuitable to siting and developing 
a definitive set of "preferred" site criteria which would guide a potential appli- 
cant's efforts to find a specific site within areas not designated unsuitable. 
This latter alternative could be considerably less costly to the state in the 
long run, while essentially providing applicants with preferred site criteria 
to consider in combination with specific plant designs in locating a specific 
site. Additionally, candidate area selection could be authorized at some future 
time after an acceptable inventory of suitable and unsuitable areas has been completed. 

Oregon, North Dakota and Minnesota assigned responsibility for criteria 
development to an independent task force composed of members of the public at 
large and representatives of special interest groups and governmental units. 
Montana should consider a similar arrangement, although it would also be 

43 - 

important to insure that the task force contain members with expertise in the 
various disciplines of concern to siting. A task force would require advisory 
assistance from the state siting agency and all other agencies having related 
concerns or expertise. Also, the siting agency could assume responsibility for 
actual application of the criteria in data gathering and mapping activities, 
although consultants carried out this responsibility in North Dakota, Minnesota 
and Maryland. However, potential future conflicts of interest, especially within 
state regulatory agencies will be avoided if the task force is responsible for 
criteria development. 

The overall objective of comprehensive state involvement in long-range 
energy planning and facility siting can be effectively instituted through the 
development of siting criteria, completion of a siting inventory, and improved 
state access to and analysis of data required for energy demand forecasting. 
However, these measures involve long-term projects which may not be completed 
in time to meet short-term planning needs. The discussion of the six states 
included in this section has revealed at least one type of provision which could 
be immediately included in Montana's siting act to permit earlier state and public 
review of utility facility planning and siting-related activities. The Oregon, 
North Dakota and California laws require that a potential applicant must file a 
notice of intent to file an application for a certificate to construct a major 
facility at least one year prior to filing the application. The notice must dis- 
close the specific site location being considered for the facility. The pro- 
vision is not intended to extend the time required for state evaluation of the 
facility. Rather, it provides a readily available means of insuring public 
awareness of site location plans. It also provides the state and the applicant 
the opportunity to confer on the suitability of a given site and identify problems 
as well as areas of agreement prior to the actual application and evaluation 

Most of the states discussed in this section have featured some type of 
public involvement in the siting process which has gone beyond public hearings 
and gathering of public comments on siting studies and related activities. In 
North Dakota, Minnesota and Maryland, public involvement has specifically been 
incorporated in the form of siting advisory committees which assist the siting 
agency in the consideration of individual facility applications. The input from 
these committees may be helpful in identifying problem areas. The committees 
generally are composed of representatives from legally specified interest groups 
and occupations as well as the public at large. The public involvement concept 
is essentially carried over to the creation of special task forces to develop 
siting criteria rather than assigning this task to state officials. A task force 
should also be responsible for providing for public review and input into its 
activities. Montana should consider adopting a general policy encouraging public 
involvement of this type. 

- 44 - 


At its most basic level, the process of energy facility siting depends upon 
and is defined by criteria, "Criteria" is a rather broadly defined term which 
refers to the complex inter-relationship of policy delineations and basic data 
needed to compare and evaluate geographic areas in terms of their suitability 
or unsuitability for siting. All of this information must be identified and 
categorized in some comprehensive system. Several ways of classifying or con- 
ceptualizing siting criteria will be discussed below. 

Site criteria are based upon policy or legal designations which establish 
the general relative importance or status of some natural or cultural environmental 
element and infer the relationship of that element to an activity such as facility 
siting. For example, air quality standards and policies requiring minimization 
of adverse environmental impact dictate the need to consider air dispersion and 
meteorological characteristics in any area being evaluated for siting. "Meteorology" 
thus would be included in the criteria list for a siting study, but would require fur- 
ther definition and refinement to reflect the objectives and level of detail 
required by a specific study. It must also be noted that meteorological infor- 
mation, as well as information from any other field, acquires meaning for a siting 
study only when considered in terms of a total relationship with other environmental 
elements and the impacts of an energy facility. It is not surprising that most 
elements which must be considered in locating an optimum site are regulated through 
some type of legislation or policy. Therefore, whether one develops criteria 
which will identify areas favorable to plant siting or criteria which will identify 
unsuitable areas, a legal or policy base is almost always present. 

This suggests one way of organizing criteria. Some land uses, by legal 
definition, absolutely prohibit the siting of any type of energy facility in an 
area. The most common example of this type is a national park or some other 
specifically protected area of natural, scenic or historic significance. Other 
similar types of areas, such as state parks or recreation areas may have less 
stringent legal protection or more vaguely defined policy status and may not be 
absolutely closed to siting but remain highly incompatible with this type of 
activity. These various types of resource areas may be grouped in two categories 
called "exclusion" and "avoidance" area criteria, respectively. Other types of land 
use or capability (prime agricultural land, for example) may not have a legally 
defined relationship to activities such as siting, but through policy delineation, 
these land areas may be included in an exclusion or avoidance category. Although 
these types of land uses are most representative of exclusion/avoidance criteria, 
areas with characteristics which would adversely affect a facility may also be 
so designated. An example of this type would be an active fault or earthquake 


Exclusion/avoidance criteria represent a conceptual means of classifying 
information for purposes of declaring areas unsuitable to siting. However, this 
objective could be reversed to reflect resource information in a way that would 
define areas of optimum suitability for plant siting. In this instance, resource 
and land use characteristics would be viewed as opportunities or constraints. 
Opportunities might include such factors as adequate water availability or prox- 
imity to existing transportation corridors. Constraints would be any of the types 
of factors included in exclusion/avoidance criteria. Additionally, criteria 
could be developed which would establish the characteristics preferred sites 
should possess. These criteria might not be directly included in the siting 
inventory but could serve as guidelines to future applicants for specific sites. 

The classification of criteria may vary considerably in relation to dif- 
ferent types of energy facilities. Fossil fueled, nuclear and hydroelectric 
generating plants and various types of conversion plants produce different types 
of impacts upon the environment. They also present different demands upon a site 
in terms of water requirements, foundation suitability, etc. Likewise, the 
siting of transmission facilities presents a completely separate set of concerns. 
An inventory of suitable and unsuitable site areas must take these differences 
into account and, thus, area designations will vary for the different facility 
types. Since the specific requirements and specific impacts of a plant are 
dependent upon specific design characteristics and pollution control technologies, 
inventory studies are often based upon representative characteristics, such as 
for a "typical" 1000 megawatt plant. However, a broad inventory to designate 
suitable and unsuitable areas would probably not require this level of detail. 

Another criteria consideration concerns the specific level or degree of 
measurement which is applied to any given factor. The criteria to be included 
in a study or inventory will depend upon the objectives and specificity of detail 
required. For example, designation of suitable and unsuitable areas could be 
accomplished through use of very broadly defined criteria which might consider 
the general characteristics of entire air sheds or major stream drainages, assuming 
that data availability would permit inclusion of these two factors. On the other 
hand, a study designed to identify candidate siting areas or specific sites would 
require much more detailed units of measurement to reflect the air dispersion 
characteristics of specific areas or the flow characteristics of a specific 
stream within a certain number of miles from a potential siting area. 

As units of measurement become more specific, two requirements become 
apparent. First, the data needed to meet the objectives of the study must be 
available at a scale and level of accuracy which will permit reliable determina- 
tions to be made. If the data are not available, compromises in the criteria 
become unavoidable. Second, there must be a methodology for assigning the units 
of measurement and subjectively weighting the various criteria for purposes of 
trade off and comparison between areas. The methodology must be capable of 
dealing with the level of detail required to meet the study objectives. 

The credibility of any siting study is based upon the def ensibility of its 
criteria and the accuracy of the basic data involved. Data and methodology- 
related matters are discussed elsewhere in this report. The defenslbility of 

- 46 - 

criteria is a separate matter which is largely dependent upon supportive policy 
delineations. The results of a statewide siting study can be expected to stir 
controversy in terms of public opinion as well as impacts upon many separately 
administered concerns. The decision to include some criteria and exclude others 
must ultimately rest with the best judgment of the task force or agency responsible 
for the siting inventory. The inventory results are obviously most secure if there 
is some provision for their legal inclusion in a state's siting rules and regula- 
tions after proper public and governmental review and modification procedures have 
been completed. Nevertheless, the defensibility of the criteria depends upon 
their basis in official state policy. Therefore, the more that a study can be 
guided by such existing policy, the more secure its results will be. The follow- 
ing paragraphs elaborate upon a few siting-related policy issues which the State 
of Montana may be called upon to consider in the future. 

Two issues of major concern in Montana and other states of the Great Plains 
are the alternative uses to be applied to a limited water supply and the protection 
or status to be accorded to agricultural and timbered lands in the face of mounting 
pressure from other land uses. These matters have received considerable attention 
in recent years and the amount of reliable information has increased proportionately. 
However, Montana has no specific policy concerning the siting of energy facilities 
or other industrial facilities in relation to surface and groundwater availability 
except for protecting the status of existing water users. This situation may be 
partially resolved by current water policy-related activities, but a statewide 
siting study may eventually be required to address this issue as a specific siting 
problem. If areas or water drainages with a questionable carrying capacity for 
future, non-agricultural uses should be avoided, this should be a specific policy 
decision. Likewise, the importance of agricultural and timbered land should be 
addressed, perhaps in terms of the land's productive capability. As was discussed 
in Section III, some states have taken this step by including such land in an 
avoidance criteria category or by setting a limit upon the number of acres which 
may be considered for alternative uses within a given size study area. 

Another important policy issue concerns the siting of energy facilities near 
urban areas as opposed to siting in remote, sparsely populated regions. The environ- 
mental, social and economic trade-offs involved in such decisions have been well 
documented. However, this issue exposes one of the most critical gaps in existing 
policy and research. Most elements of the natural environment have a well- 
established basis for protection from adverse impacts created by human activities. 
The basis for protection of certain cultural, economic and social elements is 
much less well defined. No general policy has been established to identify the 
elements of human life style and cultural carrying capacity which should be pro- 
tected. Also, mechanisms for making accurate predictions of future social and 
biological impact in areas slated for development have been generally lacking. 
These types of policies and analysis techniques must be developed if optimal siting 
decisions are to be made in the future. 

The issue of urban vs. rural siting involves many arguments inherent to the 
related issue of siting near load centers vs. siting near fuel supply districts. 
These choices naturally pose separate problems for the different types of energy 
facilities. The safety-related aspects of nuclear plant siting may argue against 
proximity to population centers. For fossil fueled plants, however, economic 

- 47 - 

considerations and impacts upon human health must be weighed against the minimized 
environmental- and community-related impacts associated with more urban locations. 
Also, the effects of transmission lines upon other land uses and questions of 
reliability and efficiency require consideration. 

The siting of energy facilities at "dispersed", single facility sites must 
be compared with the potential development of energy parks or multiple facility 
sites in the future. Although a few studies have considered this issue, it appears 
that more information is needed regarding the potential impacts of clustered 
facilities before definitive policies may be formulated. Additionally, the state 
would need to consider a general size (in megawatts) for an energy park before 
designing the "carrying capacity" studies which would be required to identify 
potentially suitable siting areas. The water and fuel requirements of clustered 
facilities coupled with the technological problems of meeting various pollution 
standards may effectively eliminate most siting options. Further, policy resolu- 
tion of the load center vs. mine mouth siting issue and a definition of need for 
future facilities in Montana may render clustered facility siting a moot consider- 
ation. Also, long-term commitments to multiple facility development would require 
extremely careful planning to insure flexibility in terms of changing energy demand 
conditions and incorporation of new technologies. 

In addition to the above policy considerations, there are other technical 
and policy-related topics which strongly affect siting and the development of j 
appropriate criteria; however, these topics require detailed study before specific 
siting recommendations can be formulated. Included in this category is the trans- 
boundary effect of siting facilities near interstate or international boundaries 
or in any location which would impact a neighboring region under separate govern- 
mental administration. While it appears unrealistic to place arbitrary limits 
upon this type of siting, many procedural policies should be adopted to insure the 
fullest possible interaction between all potentially affected parties at the 
earliest possible stage of project planning. Further, mutually acceptable prin- 
ciples of environmental protection and minimization of all types of adverse impact 
should be negotiated to guide future development plans. 

Another topic requiring technical investigation is the synergistic effect 
of siting two or more types of energy generation, conversion, or industrial facil- 
ities in close spatial proximity. This topic will acquire additional importance 
if multiple facility siting is considered in the future. Also, a separate, but 
related concern involves the feasibility of recycling conversion by-products and 
utilizing waste heat. Both of these concerns would involve concentrations of 
facilities in a single area, and as related to siting, they would require carrying 
capacity studies to evaluate specific locations. These studies should also be 
applied to existing sites. It must be noted that many technical aspects of mini- 
mizing synergistic environmental impacts have not been acceptably resolved. There- 
fore, this problem requires further analysis of policy options as well as technical 

The siting of an energy-related facility involves indirect impacts by pro- d 
vidlng potential encouragement to various future types of industrial development. " 

- 48 - 

This must be considered in terms of a specific seosraphical context as well as 
general economic influence. Various aspects of community and land use impact 
are obviously involved, as is the overall question of future economic growth. 
It is clear that some sites or site areas are far better equipped to handle in- 
direct impacts than others. It is also clear that the choice of location for a 
facility will affect the magnitude of resulting economic activity. Although 
this problem already must be considered in evaluating specific facility applica- 
tions under the siting act, Montana presently does not have a definitive policy 
for dealing with it as a site planning problem. This is also true of the other 
concerns briefly discussed above. 

Several other examples of siting criteria which may require policy guidance 
and which might be formally included in the siting rules and regulations upon 
completion of a site inventory are listed as follows (stated as preferred site 
characteristics) : 

(1) Permits maximum use of existing generation, trans- 
mission and transportation facilities. 

(2) Permits recycling of conversion by-products and 
significant energy conservation. 

(3) Permits minimum disruption of local communities. 

(4) Avoids destruction of vegetation types and wildlife 
habitat which are unique or of special significance 
to an area. 

This discussion has not been intended to provide specific site criteria 
recommendations for a Montana siting study. Rather, it is expected that this 
discussion will serve as a preliminary outline of criteria topics and organiza- 
tional options which should be considered in designing a siting study. In con- 
clusion, the two most essential goals of criteria development must be (1) the identi- 
fication and subsequent assessment of the factors most important to siting, from 
both "avoidance" and "preferred site" points of view, and (2) the insured credi- 
bility of the study results. The discussion of other states' siting activities 
presented in Section III may provide useful guidance in meeting the first goal. 
Also, the widest possible range of interests and areas of expertise should be con- 
sulted for criteria development. 

In terms of the second goal, the importance of a strong policy base for 
all criteria included in the study cannot be over-emphasized. Therefore, the 
siting agency or task force should be authorized to investigate or commission 
the outside investigation of the policy issues mentioned in this discussion, as 
well as other siting questions requiring further study. Also, criteria develop- 
ment must proceed in terms of the accuracy and reliability of available data. 

- 49 - 

A very useful by-product of this process should be the identification of 
data categories as well as geographic areas within Montana which require further 
research and data collection efforts before the existence of an adequate state- 
wide resource data base can be claimed. 

50 - 


As noted in the preceding section of this report, a statewide siting inven- 
tory will depend upon numerous types of basic resource data which must be cate- 
gorized and defined in terms of site criteria. It was further noted that the 
specificity and types of criteria are determined by the overall objectives of 
the study and that studies designed to delineate areas unsuitable for siting 
would require more general criteria and more generalized data than a study 
designed to identify specific sites or candidate site areas. Although criteria 
can be established to indicate the types and specific levels of detail of 
environmental elements which should be applied to a siting inventory, the avail- 
ability of data will determine the degree to which these criteria can be applied 
in the immediate future. If certain data are not readily obtainable at a level 
of accuracy or reliability sufficient to meet criteria specifications, compromises 
in the criteria may be unavoidable. 

This raises an important point. The generation of new resource data is an 
extremely expensive process which involves extensive field studies, analysis 
of remote sensing and aerial photographs, and detailed comparisons of various 
existing maps and other data sources. The development of siting criteria will 
unquestionably reveal many "gaps" in Montana's existing resource data base which 
must be filled if siting activities, land use planning and resource management 
efforts are to be improved in the future. In this sense, the siting study can 
be expected to provide some specific direction for future data collection efforts. 
However, it is unlikely that the scope of the siting study will permit incorpora- 
tion of a major effort to generate new resource data. The time and expense involved 
would be too great. Since the funding required for generation of new data is very 
substantial, every effort should be made to secure federal cooperation and support 
as well as a major funding commitment from the state. This activity should 
proceed separately from the siting study and most optimally, it should be based 
upon the results of the study as well as extensive interaction with other users 
of resource data in the state who could help identify the most critical gaps in 
existing information. 

A preliminary assessment of certain categories of Montana's existing resource 
data was undertaken to provide background information for this report. As a 
result, some general observations and comments may be made. For a number of 
categories, adequate data exist on a statewide basis to allow formulation of 
criteria which could be utilized in a regional study designed to designate 
areas unsuitable for siting. This is especially true of many types of human 
resource data such as population and demographic characteristics, and economic 
and social data. Coverage of natural resource data is generally not as compre- 
hensive because both the quality and quantity varies considerably between cate- 
gories and between various regions of the state. For example, baseline surface 

- 51 - 

water quality data has been collected for nearly all of the perennial streams 
in the state. However, there is a critical lack of information regarding ground- 
water quality (Karp 1976). Wildlife distribution and fisheries data, especially 
for the major game species, is generally available on a statewide basis, but this 
type of inventory information may not be applicable to a siting study unless it 
conveys something about a particular area or region which would be adversely 
affected by siting. For example, critical areas, habitat areas of exceptional 
quality and areas of high population density probably should be included in 
"avoidance" type criteria. However, this type of information may not be included 
in general species distribution data. 

A major problem is evidenced in attempting to assess the general availability 
of land use and land capability data and vegetation types data as well as most 
wildlife information. A great deal of data exist, but very few parameters or 
classifications of information within these general data categories have been 
uniformly covered on a statewide basis. Much of the information has been compiled 
or mapped by different agencies or study teams in different regions using different 
mapping scales. Also, some of the data are more up to date than others. 

For some data categories, such as air quality and meteorology, existing 
information could be generalized at a regional level, but the following two figures 
indicate the areas where studies adequate for specific types of environmental 
assessment actually have been completed. A considerable amount of new data would 
obviously be required if a siting inventory is conducted at this level on a state- 
wide basis. 

It generally appears that criteria based on existing data could be developed 
for a regionally oriented siting study. The experience provided by a similar 
siting study conducted in Oregon supports this conclusion. However, this state- 
ment must be qualified by noting that it may be impossible to map ideal criteria 
for each data category which should be included. Lack of accurate data or general 
lack of coverage for some data categories may require modification of some criteria 
or potential elimination of other criteria. These decisions will be a major 
responsibility of a siting task force. 

The difficulties involved in making an accurate assessment of existing natural 
resource data have implications which extend far beyond the needs of a statewide 
siting study. Every major natural resource study conducted in Montana is con- 
fronted with the demanding task of gathering fragmented existing data and either 
combining it to form a comprehensive "picture" for a given geographic study 
area or commissioning a new study to supply missing information or supplement 
inadequate existing information. The fact that most resource studies have dif- 
ferent objectives and require different levels and combinations of data compounds 
the problem by requiring that similar data inventory processes be repeated over 
and over. 

Decision-making and regulatory agencies must remain free to initiate studies 
and data collection efforts designed to meet their specific needs and responsibil- 
ities, but better coordination and standardization of existing data and a mechanism 
for the cateloging and storage of both new and existing information would clearly 
represent an improvement of the present situation. This type of coordination makes 
sense, but it will not be achieved without assigning specific authorization and 
funding to a specific agency, office or advisory unit. 


- 52 - 






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- 54 - 

Such a designation would require creation '^f a data assembly and storage 
system. In turn, the establishment of this system would require many specific 
decisions, including: 

(1) Identification of potential system users and, to the greatest 
degree possible, delineation of each user's major information 
needs (i.e., data categories, scale and level of detail, as 
well as specific operational needs) . 

(2) Definition of mutually exclusive data categories for storage 

(3) Provision for double filing of data in both its original study 
format and in categories developed for the overall storage 

(4) Setting of data accuracy standards. 

(5) Development of uniform mapping standards to guide future resource 
data collection activities to the greatest extent possible. 

Several principles of operation for this type of system are immediatcdy evident, 
The system should be designed to accommodate the widest possible range of user 
needs. Therefore, it should be designed by those users to the greatest extent 
practicable. One administrative option which would provide this user input is 
the creation of a steering committee or board (made up of potential system users) 
with directive powers and oversight responsibility for the activities of the 
agency or office assigned to develop and maintain the system. It is assumed that 
other on-going efforts to improve the mapping of resource data in the state could 
be coordinated with the development of this system. 

The potential designation of one agency to be responsible for assembly and 
storage of resource data could have an especially significant and beneficial 
effect on the statewide siting study if the authorization for these two activities 
is granted within a similar time frame. A data assembly and storage agency as 
well as other state agencies would be able to provide important assistance to 
the criteria development effort in providing advice concerning the availability 
of various specific types of data. Additionally, as noted previously, the siting 
study could be expected to uncover specific data needs which could give direction 
to future data collection efforts. If funding is secured, these efforts could be 
designed primarily to improve the general resource data base for all users rather 
than solely serve the needs of a single study. 

- 55 - 


A statewide siting Inventory and most other types of resource planning and 
management activities require the assembly and analysis of a considerable volume 
of resource information. Efficient execution of this task involves two comple- 
mentary data handling requirements. First, a system must be established to coordinate 
the assembly and storage of basic resource data (i.e., soils, vegetation types, 
slope, land use, etc.). As was discussed in Section V, this system must be based 
upon clearly defined, mutually exclusive data categories, but it must be flexible 
enough to meet the needs of a wide range of users. 

A second requirement concerns the availability and coordinated management of 
computer hardware and software capabilities needed to efficiently store, analyze 
and otherwise manipulate all types of spatial data on a statewide basis for deci- 
sion-making purposes. This latter requirement will be the principal concern of 
this section of the report. 

It is important to note that this requirement can be fulfilled by a single, 
well-designed computer system, although specialized software not needed for data 
storage would be required for data manipulation and analysis. The use of a system 
or systems to coordinate data storage and data manipulation functions is a manage- 
ment concern which should not be confused with system capabilities. 

The following discussion of automated data management must acknowledge a set 
of concerns entirely separate from system capability analysis. These concerns 
are concentrated upon a general lack of understanding by many decision-makers 
and other potential users of the services an automated data system can provide 
(Salmen 1973). Also, automated data systems may be viewed with some suspicion, 
partially because of system-related barriers, such as complex programming processes, 
which only system programmers and designers can operate. Additionally, decision- 
makers may not adequately perceive the complexity or volume of information required 
to assess various types of planning problems. As a result, inappropriate types 
of responses may be made. 

These concerns are a major problem because justifications and explanations 
of data systems, which may seem self-evident on an empirical basis, must be 
carefully prepared and presented to potential users if the systems are ever 
to be utilized. The need for improved communication and presentation of system 
capabilities will be discussed in subsequent portions of this section. 


- 56 - 

A. System Components 

A general discussion of the computer system components and capabilities 
needed to assist resource management and planning efforts is presented below. 
This discussion is exerpted from a 1975 Montana State Government publication 
entitled "ERGIS Data Bank for Land and Resource Utilization" (DNR&C 1975). 

The major operations involved in assembling a data system include: (1) 
input material analysis; (2) input device selection; (3) storage format deter- 
mination; (4) storage device selection; (5) output format and device selection; 
and (6) data manipulation requirements. These operations and their relationships 
are graphically presented in Figure VI-1 on the following page and are described 
as follows: 

Input Material Analysis 

The source and format of input materials determine the data input hardware 
system design as well as software generation. Most input materials are in 
cartographic map format and may be categorized in terms of the range of scales 
and physical sizes of input maps and the number of maps that need to be digitized, 
All geographic information can be categorized into three groups: point, line 
and polygon. Points represent historical sites, buildings, wells and springs. 
Lines represent topographic contour lines, highways and streams. Polygons repre- 
sent soil patterns, vegetation patterns and lakes. These data may be delineated 
by location (point, line or polygon) or by descriptoi , such as the name of a soil 
type, vegetation community or highway classification. A separate group of input 
materials includes remote sensor imagery such as black and white air photos, 
infrared or multi-band imagery and radar imagery. If these kinds of data input 
are used, an extra dimension is added to the complexity of the data bank. This 
includes the interpretation process, either an automated or manual technique, 
and the process of correcting imagery distortion caused by sensor equipment. 

Input Device Selection 

As the format of input material is known, the next step is to design the hard- 
ware and software of the input system. Three types of input devices can be 

(1) Manual input system, using a manual digitizer to digitize 
the point, line and polygon. Also, the descriptors are 
inserted manually. 

(2) Semi-automated input system, using an automated digitizer and 
either a raster scanner or a flying spot line follower to 
digitize points, lines and polygons. If the input material 
is a colored map, the description can be automatically 
recorded. If delineation and descriptor of data are both 
shown on the map, the descriptors must be manually inserted. 

- 57 - 





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- 58 

(A scanner map cannot be directly plotted out through a 
linear or incremental plotter because the relationship 
between the points is not indicated (i.e., points are 
not grouped consecutively to form the line as shown on the 
original map). Therefore, regrouping or vectorizing 
the points is essential for plotting purposes.) 

(3) Automated input system, using an automated digitizer 

and also using a pattern recognition technique to auto- 
matically record the descriptors. If the descriptors 
that the data bank has to work with are numerous and 
varied, an extensive software effort or specialized hard- 
ware is required. Also, if the effort of developing an 
automated process for descriptor recognition cannot be 
offset by the time saved from using the manual method in 
accomplishing the same amount of work, then the manual 
approach is recommended. 

A satisfactory input subsystem should meet requirements of efficiency, economy, 
flexibility, accuracy and reliability. Further discussion of these requirements is 
as follows: 

Efficiency and Economy : The degree of automation relates to the character and 
quantity of input materials. It is a cost-benefit and efficiency-related decision. 
It is absurd to be automatic for the sake of automation only. If the manual approach 
requires thousands of hours of manpower to do the digitizing work, then it is neces- 
sary to use the automated approach. The amount of input material, the frequency of 
use and the time allowed to input all necessary materials are major considerations. 
Also, manual digitizing will present a greater chance of human errors and inaccuracy 
which in the end will require more effort in data correction or editing. But, if 
the quantity of input materials is small and the descriptors are in a very com- 
plicated pattern, then it is better to use a manual digitizer. 

Flexibility : The more varieties of input materials that can be processed by 
the system, the higher the flexibility. This flexibility can be achieved either 
by a manual or an automated digitizer. For an automated digitizer, higher flex- 
ibility usually requires a higher level of system sophistication. 

Accuracy and Reliability : If the input material is a map, then the inherent 
accuracy of this map is beyond the control of the data bank. This inherent accuracy 
is a factor to be considered due to its influence on the output accuracy. The 
accuracy of a map results from the accuracy of the projection method, the resolu- 
tion of the hardware that interprets the original material (such as black and 
white and infrared air photography), the accuracy of map compiling and drafting, 
either manually or mechanically, and the stability of the medium on which the 
map is drawn and printed. 

If the input material is from remote sensor imagery, the same factors used for 
maps have to be considered, unless the input system is directly connected with the 

- 59 - 

remote sensor with an auxiliary system capable of automated data interpretation. 
If the input system is using a manual digitizer, possible human error should be 
considered and may require incorporation of an editing process. 

The reliability of input hardware, either a manual or an automatic digitizer, 
relates to its accuracy (or overall accuracy), resolution, repeatability, linearity, 
orthogonality, scan curvature and stability. 

Format Determination 

Data storage relates to file format detemiinatlon, coordinates system determin- 
ation, storage format determination, and storage device selection. Further dis- 
cussion of these four items is presented as follows: 

File Format Determination : The file format is closely tied to the efficiency 
of the entire system. It not only saves data storage space and enhances the ran- 
dom accessibility of data retrieval, it minimizes the time required for data man- 
ipulation. There are two means of constructing a data file: one is by using one 
data file per data variable for a unit area with a predetermined size or the entire 
data bank region, and the second is by using one data file per unit area for all 
or multivariables. 

Coordinates System Determination ; When a data file for the entire study region 
exceeds a certain size, it is economical to divide the file into small sections or 
sub-files. This will greatly benefit the data output or retrieval subsystem, 
because when a small area is to be retrieved from a large file, it is necessary to 
search through the entire file, thus consuming a great deal of time. If the entire 
file is divided into small sections, then only sections that are cut through by 
the boundary lines of the retrieved area and the sections within the boundary lines 
are needed for file searching. To divide the regional file into small sections, 
one can use either arbitrary grid systems or geological survey coordinate systems. 
The factors that have to be considered are input device capability (i.e., the 
size of input material as limited by input device), required input efficiency, 
random accessibility of stored data (i.e., the nature of data retrieval in order 
to achieve efficiency), and data manipulation technique used. 

Storage Format Determination : The data storage format for an input system is 
rather simple. It takes the input digital format as its storage format. The 
retrieval and manipulation systems, however, place many constraints on the format 
determination. There are two major types of storage format: grid format and poly- 
gon format. 

A grid format presents the land use and resources data by uniform modular cells. 
These modular cells can be squares or parallelograms or any other uniform shape 
such as hexagons and octagons, if necessary. However, the square shaped cell 
is used most commonly. The data within a modular cell can be presented either in 


- 60 - 

percentages, which is termed "percentile cell format", or represented by the 
dominant datum only, which is termed "dominant cell format". 

According to the cell size, the grid system can be represented by either 
regular cell size (i.e., macro-cell) or micro-cell size. The difference between 
the two sizes is based upon the scale and the actual ground size represented by 
each cell. The dividing standard is rather arbitrary, but the micro-cell is 
defined as that cell size smaller than or equal to 1/2500 square inch. (This size 
is related to the size and scale of the input material.) Any larger amount is a 
regular cell. For example, if input material with a scale of one inch equal to 
one mile is used, a cell size smaller than or equal to 0,256 acres is called a micro- 

In general, micro-cells of a regional and statewide data bank will have to 
utilize an automated data input machine because a manual input method would be 
too time-consuming and costly. 

A polygon format represents a closed area or plane bound by line segments, 
A line segment is a line defined by intersection points (i.e., the beginning and 
end points of this line segment) or a closed circle. 

Selection of storage format depends a great deal on the requirements of data 
manipulation, although input methods used may create an extra burden in reaching 
the desired storage format. For example, if polygon format is desired, then data 
input from a raster scanner which is in run-length coding format must be vectorized 
in order to be stored in the polygon format. On the other hand, if grid format 
is desired, data input from a manual digitizer or line follower which is in a 
linear, incremental or polygon format must be converted into a grid format before 
going into the storage device. 

In polygon format, lines are defined by points or vectors; areas are defined 
by lines. The denser the digitized points or vectors, the closer this line 
approaches its original configuration. The accuracy of the data builds at the 
expense of the storage space available. 

The grid system is prevailingly used in computer mapping due to its ready 
availability. The early grid system was developed under the limitations of the 
hardware system because most people have easy access to a computer line printer 
while having very limited access to a manual digitizer and plotter. Converting a 
geo-information system into a grid system is risky because a grid system is 
unnatural to the geo-information characteristics. It may also distort the infor- 
mation furnished by geo-information systems to a degree, depending upon the cell 
size of the grid system when compared with the scale of the geo-information 
system. Grid systems have their own advantages, but it is extremely important 
to conduct a reliability analysis prior to using the system in order to determine 
the size of the grid cell and to determine whether or not the grid system is com- 
patible with the study intent. 

- 61 - 

Polygon storage format may be compared to grid storage format as both formats 
relate to data retrieval. Retrieval criteria consist of random accessibility, 
flexibility and compatibility. Random accessibility requires data output of any 
arbitrary geographic boundary area desired. This Involves file separation and 
file mergence. In order to separate a geographic area from an existing polygon 
format data file, it is necessary to read in the X-Y coordinates of the lines 
forming the area and search out the maximum and minimum X-Y coordinates of 
each polygon in the file to determine whether it should be included, and if so, 
check all line segments to determine which ones fall within the desired area. 
The mergence of two areas or files involves an even more complex series of steps 
to insure that all border-line segments are properly identified and matched. 

In order to separate a geographic area from an existing grid format data 
file, a rather simple process can be used to eliminate all cells outside of 
boundary lines. Therefore, assuming that the data files have the same complexity 
and can provide a similar level of accuracy, from the viewpoint of file separation, 
the grid format will provide higher efficiency than the polygon format. Mergence 
of the data file of the grid format involves only rearrangement of coordinates 
of certain cells, a rather simple task of mathematic addition and subtraction. 
Therefore, from the viewpoint of data file mergence, the grid format is more 
efficient than the polygon format. 

Higher flexibility of data retrieval demands a capability of arbitrary output 
format. Data stored in a polygon format have the greatest accuracy (i.e., the i 
original inherent accuracy that can be provided by the input device) and the ' 
greatest flexibility because these data can be plotted out at any desired scale. 
Whether the plot-out is an enlargement or reduction in scale, the accur&cy of 
the original data file Is preserved (although enlargement will not enhance the 
accuracy of the original data file). The data can also be converted to the grid 
system with any reasonable and desirable cell size. 

If data were stored in a regular cell size grid system, these data can only 
be aggregated upward toward a more crude level rather than disaggregated downward 
toward a finer level. In this grid system, aggregating upward without losing 
control of reliability can be conducted in only one fashion; that is, using the 
width or length of the original cell as the interval unit and aggregating in an 
integral interval. In each cell, whether it is a percentile cell or a dominant 
cell, the data are not described by location-related coding. Therefore, no 
method exists that can break the individual cell without losing control of reliabill 
Disaggregated downward, the data will more likely lose their original reliability 
or accuracy. 

Because the accuracy of the dominant type, micro-cell size grid system 
is similar to that of the polygon system (i.e., based upon the inherent accuracy 
of the input material minus the resolution, e.g., 1/100" and 1/400", of an 
input device such as the raster scanner), this grid system will have flexibility 
of arbitrary output format similar to the polygon system if the square of the 
scan resolution is used as the cell size. The least accurate is the percentile 
type, regular size grid system because of its relatively large cell size and lack j 
of location specifications within each cell. I 

- 62 - 

Data storage compatibility between two data bank systems or between different 
data sets within the same data bank depends upon the coordinates system and scale 
used. For grid systems, it also depends upon the size of the cell. Data com- 
patibility is directly affected by the data input system and data storage format. 
Different data sets, either from different data banks or the same data bank and 
with the same coordinates system and scale, are compatible. Through a software 
effort, one coordinates system or scale can be converted to another. 

Data stored in a polygon or micro-cell format have higher compatibility than 
data stored in a regular cell size grid system because this grid system has con- 
straints due to cell size, as well as differences in coordinates system and scale. 
If data sets use different coordinates systems, even though they have the same 
cell size, they are incompatible. 

Usually no location specifications are coded within a percentile cell format. 
Therefore, one cell system cannot be converted to other coordinates systems without 
losing data reliability. The degree of reliability loss depends upon the cell size 
and the complexity of data. The smaller the cell size and the less complex the 
data arrangement within each cell, upon conversion into another coordinates system, 
the less reliability is lost. 

As related to data manipulation criteria of reliability, accuracy and efficiency, 
the micro-cell grid system offers the greatest advantages. The polygon system 
offers reliability and accuracy, but is rather inefficient. 

Storage Device Selection 

Many data storage devices such as cards, tapes, drums and discs are available. 
For a large bulk of data, cards are not recommended as large quantities are needed, 
thereby presenting a handling problem. Cards also lack endurance. Tape has the 
benefit of storing large amounts of data on a relatively small magnetic tape, but 
it may lack random accessibility. A drum or disc storage device offers long- 
lasting durability, random accessibility, and relatively small physical dimensions. 

Output Format and Device Selection 

Because the input and storage systems have already been built into the required 
output format (either polygon or grid format), the output is only a matter of calling 
the storage data. The important function of the retrieval system is the establish- 
ment of random accessibility and optional scaling. 

There are three major output devices available: line printer, matrix plotter, 
and linear or incremental plotter, which can be either a drum plotter or a flat-bed 
plotter. The first two devices are usually used for grid format output. The third 
device is usually used for polygon format output, but can be used for grid format 
output if necessary. 

- 63 - 

Data Manipulation Requirements 

Data manipulation can be divided into two categories: (1) the manipulation 
of a grid system which includes percentile cell and dominant cell subsystems; 
and (2) the manipulation of a polygon system. Under each of these two categories 
are two subcategories. One is to generate a new data set from a known data set 
that is already stored in the data bank. Examples are generating a slope and 
aspects analysis map from topographic data, or generating a construction compat- 
ibility map from a soils type map. The second is to merge two different data sets. 
This is known as the overlay (compositing) technique, and it relates to different 
mathematical evaluation or combination methods. The following comparison between 
the polygon overlay system and the grid overlay system is based upon the criteria 
of reliability, accuracy and efficiency. 

The polygon overlay system, offering an original delineation of data type, 
has a higher rate of accuracy and reliability than the regular cell size grid 
system. Again, this is because the data in each cell of the grid system are not 
location specified. Because the micro-cell size grid system can provide accuracy 
similar to the polygon system, these two systems have a similar level of reliability. 
In a situation where a regular size grid system must be used for the overlay tech- 
nique, it ic necessary to conduct a reliability study to determine the cell size. 
Cell size determination depends upon the accuracy level of the original data, the 
configuration complexity of each data set, and the nature of the study. If the 
accuracy of the input map is about i 500' when compared with the ground truth, 
it is of no value to use a cell size smaller than 500' x 500' due to the possi- 
bility of the entire cell carrying completely false information. On issues related 
to the configuration complexity of the data set, it is empirically recommended 
that no more than three data types should be contained within one cell. Concerning 
the nature of the study (i.e., the study objectives), a fine level decision-making 
study should use either a dominant type micro-cell size grid system or a polygon 
system. The scale selection is also essential. 

In order to use the overlay technique of superimposing one polygon format 
map on top of another, a complex series of steps are needed to check all points 
of polygons which overlap in order to determine the exact configuration of new 
polygons created by the overlay process. The superimposing of two grid format 
maps is a rather simple mathematic addition as long as the grid systems of two 
maps are compatible with each other. 

B. Discussion of Computer Systems and Programs 

Several data handling systems have been examined for potential application to 
resource planning activities in Montana. Before discussing these systems, an 
important comment must be made. There are many data manipulation techniques 
which can be used to achieve approximately the same study results. Also, there 
are many types of statistical calculations and computer programming variations 
which will provide supplementary planning information that is very helpful to 
decision-makers. These types of software generally can be written or acquired at 
a relatively minimal cost. However, all types of data manipulation must be per- 
formed within the context of some overall organizational methodology. "Methodo- 
logy" may be defined as the entire planning process and succession of activities 


- 64 - 

required to evaluate some problem or proposal and reach a decision. Methodology 
must be based upon existing state policy and legal requirements which delineate 
the issues and types of information to be considered in any specific type of 
proposal. These topics are discussed in the criteria section of this report. 
Data manipulation and analyses occur near the end of the evaluation process, but 
it is essential to note that these techniques will not provide an "answer" to 
a given problem. At best, data manipulation will reveal the choices which exist 
if the relative importance of the various data elements involved in a study are 


The generalized map analysis planning system (GMAPS) was developed at the 
Colorado School of Mines and features a composite computer mapping capability 
(Turner 1976, p. 15). The GMAPS program is operated from small teletype terminals 
which are connected to a DEC System-10 computer at the School of Mines. A very 
attractive feature of the system is its accessibility to non-technical users. 
The system is operated through a program which displays a series of questions on 
the terminal screen. The user's responses command the operations to be performed. 
These commands are listed in the following table. 

Table VI-1 

Available GMAPS Transactions 







New Data 







Gives GMAPS instructions. 
Lists the areas and factors in 

the catalog. 
Changes the current area. 
Duplicates a file and assigns 

a new name. 
Masks specified areas out of 

a file. 
Reads and checks new data. 
Assigns numeric values to an 

alphameric file. 
Deletes areas and factors. 
Arithmetically or logically 

combines factors. 

- 6S 

Table VI-1 Cont'd. 





Prints a symbolic map. 
Prints a gray- tone map. 
Prints statistics for a 

Exit from GMAPS 

I = input transactions which allow the entry of new source 

maps to the analysis. 
= output transactions which produce all the map and 

statistical displays. 
C = create transactions which allow for the creation 

of new map forms from existing maps. 
S = system transactions which involve "housekeeping" 

tasks needed during the operations of GMAPS. (Turner 1976) 

Further description of the GMAPS system components is presented below. 

GMAPS accepts map input through the use of manually coded map sectors. Each 
sector is a block of 120 by 120 cells; each cell contains a single data element 
or character. The data are coded in symbolic format (numbers or letters) on a 
sector form sheet or "P-card" . It should be noted that only the points of change 
in the data, which are scanned from left to right, need be recorded. The number 
of acres per cell is flexible and depends primarily upon selection of a suitable 
scale of resolution for the problem being addressed (Turner 1976a). 

Data are stored as a sequence of matrices, each equivalent to one sector. 
The format is cellular. 

Data are output through a line printer which can produce gray-tone maps 
or symbolic maps and histograms which delineate the percent of map area assigned 
to each map variable or valuation code. The output maps can be checked and edited 
for accuracy by overlaying them on the original source map. It should be noted 
that this method of cellular input can present a stretching problem which results 
in locational distortion of data. 

GMAPS contains a number of significant data manipulation capabilities. As 
many as ten separately weighted maps can be overlayed and combined to produce 
a single composite map. Each map is weighted as a whole and all elements included 
within each map are ranked by numeric codes in a possible range of zero to nine. 
A logical compositing technique allows two maps to be merged on a cell-by-cell 
basis so that up to ten pairs of conditions can be checked. The sensitivity of 
each factor valuation also may be statistically calculated. This reveals the 
"margin" or valuation for that factor which would be required, when combined with 
any other factor or factors, to produce alternative study results (i.e., a 

- 66 - 

different preferred site or route designation) . Various study areas may be 
selected for analysis from within a larger mapped region. 


The generalized computer aided route selection (GCARS) system was also developed 
by Turner in 1968 and may be considered a partnership operation of GMAPS. GCARS 
is an example of linear programming which applies minimum path analysis tech- 
niques to numerical cost models to generate a series of ranked alternative routes 
or corridors, "Cost" in this context is a measure of desirability which combines 
directness of route and least cost of all factors considered. The numerical 
cost models represent various objectives. They are stored as matrices but may be 
conceptualized as three dimensional surfaces (see Figure VI-2 below) with the 
"valleys" representing least cost. 




Figure VI-2- Basic concept of GCARS system 
(adapted from Turner 1968). 

The computer analysis proceeds cell by cell, choosing the path of least cost. 
Second, third, and successively less desirable alternatives are discovered by 
raising the "cost" values of the cells or links of the preferred route so these 
won't be selected in the same sequence again. The composite model is derived 
through use of GMAPS compositing routines. 

67 - 

GCARS produces maps of the routes or superimposes the routes on appropriate 
gray-tone maps. Statistical summaries are also produced which provide the user 
with various numerical analysis of the length and cost of each route. 

Discussion of GMAPS/GCARS 

Ecological Consultants, Inc. : The GMAPS/GCARS system presently is programmed 
through centralized computers at the Colorado School of Mines and is available 
through a consulting firm called Ecological Consultants, Inc. (ECI) . ECI is 
primarily interested in providing the GMAPS/GCARS methodology, rather than simply 
providing software capabilities. A computer terminal and training in use of the 
terminal and the GMAPS/GCARS analysis procedure are supplied to clients. If a 
project is contracted, ECI takes responsibility for converting all source data 
into sectors and placing them in the system. 

The arrangement involved in utilizing GMAPS/GCARS through ECI is not applicable 
to Montana's situation. As shall be discussed later, the State of Montana already 
possesses computer hardware and software which can perform functions similar to 
those provided by GMAPS. Therefore, advantages of purchasing ECl's services, 
as well as a terminal connected to the Colorado School of Mines computer, appear 
negligible. i 

Los Alamos Scientific Laboratory (LASL) : The GMAPS program could also be 
available to the State of Montana through the Los Alamos Scientific Laboratory 
at Los Alamos, New Mexico. The Federal Energy Research and Development Adminis- 
tration sponsors the Regional Energy Assessment Program (REAP) , which is partially 
administered through a special LASL research group known as Q-10. This program 
concentrates upon "resource utilization problems and opportunities likely to 
arise in the course of energy development activities in the Mountain States . . . 
of Idaho, Montana, Wyoming, Nevada, Utah, Colorado, Arizona and New Mexico". The 
specific goals of the program are listed below: 

(1) To provide the basis for the development of a rational 
energy policy for the utilization of resources in a 
manner to minimize detrimental effects. 

(2) To provide long-term projections of energy, water, and 
mineral production and utilization for the region. 

(3) To provide a means for the evaluation of the impact of 

new technology so that these factors can be incorporated into 
both regional and research planning. 

(4) To evaluate the importance of legal and institutional 
constraints on regional growth, energy consumption and 
production (REAP 1976, p. 1). i 

68 - 

Under the auspices of this program, LASL is interested in providing assistance 
to the states listed above. 

LASL possesses highly sophisticated computer hardware which the Q-10 Research 
Group has utilized to apply advanced research in spatial data handling techniques. 
LASL utilizes the basic GMAPS program but has made several improvements to increase 
efficiency, increase display capabilities and extend editing capabilities. 

Any of the eight Mountain States may undertake a jointly funded spatial 
data research project with LASL. Such a project must satisfy REAP's energy plan- 
ning criteria before LASL's involvement could be justified, but it appears that 
many aspects of a statewide energy facility siting study would provide this jus- 
tification. Other considerations are as follows (Vogel 1976) : 

(1) LASL has an in-house restriction on hiring new staff; 
therefore, the availability of existing staff to work 
on new projects is a major constraint. 

(2) LASL cannot "sell" its computer capabilities; any projects 
accepted must involve data analysis and application of 

(3) In a joint project, the state would be responsible for all 
input data and for preparing this data in the manually 
coded cellular format required by GMAPS. The state would 
also be responsible for assigning weights to the various 
data elements included in the study. 

(4) LASL would process the data and produce either gray-tone 

or colored maps which it would then composite and otherwise 
analyze to produce the study results. 

The possibility of negotiating a joint study between the State of Montana 
and LASL remains an option for the future which could be tapped for many types 
of statewide or area-specific resource and energy-related studies. LASL could 
apply many sophisticated computer hardware capabilities to such a study which 
would probably be economically unfeasible for a state to duplicate by itself. 
This specifically refers to display capabilities, techniques for accurate analysis 
of remote sensing data, and other advanced research techniques. However, the 
advantages provided by these capabilities may not substantially affect study results. 
The potential advantage of shared funding would have to be evaluated in terms of 
the specific monetary costs involved, the study objectives, and the comprehensive 
costs and benefits for each partner for a specific project. 

69 - 


A cellular composite mapping program known as CMS II is available from the 
Federation of Rocky Mountain States (FRMS) and Is presently being utilized by 
the Montana State Department of Community Affairs (DCA) . This program contains 
many data manipulation capabilities, but also presents some potential problems 
for users. The original CMS I program was written In COBOL computer language 
and was developed for use In UNIVAC and CDC computers. In 197A, FRMS secured a 
grant to redevelop CMS I for use In more widely distributed IBM computers with 
ANS-COBOL compilers (FRMS 1976a, p. 2). The new program Is called CMS II. It 
can be adapted to many types of input and output devices and It will accept 
various types of input data as indicated in Figure VI-3. The input may be manually 
coded or automatically digitized. Cellular storage format is required. 

Data manipulation capabilities include compositing, cell aggregation, various 
statistical and logical computations, and a polygon to cell conversion program. 
However, the conversion program is not operational at this time. A detailed 
description of CMS II is provided in the users manual available from FRMS and 
available for inspection at DCA. 

Through the computer system operated by DCA, Montana was the first state 
in the Federation to utilize CMS II. The primary problem DCA and others have 
had with CMS II is its inefficiency in terms of the length of time the hard- 
ware must take to perform the program operations. This inefficiency is directly 
related to CMS II 's COBOL program language. Therefore, other programs with 
similar capabilities written in more Inherently efficient languages may be con- 
sidered preferable in terms of long-run cost. 

Department of Community Affairs 

The Research and Information Systems Division of DCA is a data collection 
unit within Montana State Government which deals with many types of information 
(i.e., demographic, social, economic, natural resource, etc.). This division 
has the computerized capability to store and analyze spatial data. DCA has not 
always been oriented toward the collection or handling of natural resource data, 
but it has been acquiring increasing amounts of this type of Information in 
response to various user contracts and data analysis projects over the past 
few years. As a result, programs such as CMS II have been acquired. Additionally, 
DCA was designated Montana's land use planning agency by executive order of 
the Governor in July 1975 with attendant responsibility to develop and maintain 
a centralized information system containing appropriate data. DCA depends upon 
outside consultants for semi-automatic digitization of source data. The data 
is stored in both polygon and regular cellular format. It is felt that both 
formats serve necessary functions. However, a reliable conversion program for 
transferring data between the two formats is essential. 


- 70 - 

VeA^aX^Zz Inpttts and OlUpuX6 














n«t. resources 

seasonal chge 

black 1 white 


popn. eharact. 


loclal f»ctor$ 

land uses 



econ. eharact. 


plans, zones 

land cover 

land cover 

legal bdrles 



r^opticdi A 

i 1 

multl- \ / photo \ 

polygonal A 

master map\ 

/outside \ 

proj'n to 



XY trace 

k dict'ry. 


CHS grid 








Into CKS 


sr\y Stat. 

Interpol 'n 


land uses 


to cells 

areas. In 



Into CKS 

, grid 

, by CKS i 

, CMS grid 1 I fed into 1 


\r/ \y \y \:^ 

J — -^, 


■ r 



T. i CMS map file 






4^ 4^ 4^ 4^ 4' 4' 




























Figure VI-3 
Federation of Rocky Mountain States, 1976a. 

- 71 - 

DCA has been involved in a project with the Department of Revenue for 
the past year and a half to digitize the comers of all the section boundaries 
in the State of Montana. When this project is complete, it will significantly 
increase the accuracy of the DCA grid system. 

DCA utilizes a drum plotter for production of polygon maps and a line printer 
to produce its cellular map output. These hardware devices are located at the 
Department of Highways. Output forms include gray-tone and symbolic maps and 

The DCA system possesses map compositing and analysis capability as well 
as various types of logical and statistical analyses capabilities. Additionally, 
the system has programs for cell aggregation, file separation and file mergence 
for any combination of data factors. 

Environmental Resources Geo-Information System (ERGIS) 

The data handling system presently owned by the Montana Department of Admin- 
istration but principally used by the Energy Planning Division (EPD) of the Montana 
Department of Natural Resources and Conservation has been described in the 1975 
publication referenced and quoted earlier in this report. 

ERGIS' use as a data bank would necessarily involve very large amounts of 
input data, frequent use, and relatively short amounts of time to process input 
materials to required specifications. ERGIS' function as a tool to be used in 
decision-making, with the accompanying demand on its data manipulation capabilities, 
has not been considered a separate or additional load factor. However, this 
function clearly places demands on the system (beyond its data storage functions) 
which strengthen the conclusion that automatic digitization is essential (DNRC 
1975, p. 71). Thus, a raster scanner was selected for the system input device. 
This imposed the input format requirements identified in the discussion on input 
device selection (see Section IV-A of this report) (DNRC 1975, p. A3). 

A longitude-latitude coordinate system was selected for ERGIS. This coordinate 
system theoretically does not present compatibility barriers to potential inter- 
action with other systems, but it has not yet been utilized or applied to a 
specific project. 

Data is digitized, stored and manipulated in a dominant type micro-cell 
grid format. This format appears to combine the advantages of accuracy, flex- 
ibility, and compatibility with other systems provided by polygon storage, with the 
greater data manipulation efficiency ( i.e. , compositing) and random accessibility 
provided by cellular storage. 


72 - 

ERGIS is not restricted to any particular output device. A line printer and 
matrix plotter are presently utilized. 

ERGIS' data manipulation capabilities include: file separation and file 
mergence to provide random accessibility of data (this allows for selection of 
new study areas and other types of data configurations which may vary from the 
initial input arrangement); vectorization of scanned data to return the data to 
its original configuration for display purposes; conversion of run-length codes 
into polygon format; aggregation of cells which can be scaled to a size equiva- 
lent to the smallest cells used in regular grid systems; line thinning to reduce 
data boundary lines to one-cell width; and calculation of acreages. 

ERGIS has an efficient compositing program which has been successfully sub- 
stituted in some of DCA's work for the more inefficient CMS II program. ERGIS 
does not possess an automatic corridor selection technique. Routes or corridors 
are traced manually through analysis of the shaded areas shown on composite maps, 

C. Summary Discussion 

The data systems described above require further discussion in terms of their 
relationship to the management of resource data in Montana. The first portion of 
this subsection deals with system-related concerns. 

The advantages and disadvantages of manual and automatic or semi-automatic 
system input devices have been discussed in Subsection IV-A. The volume and 
complexity of data to be handled with efficiency, flexibility and reliability 
are the basic factors to be considered in evaluating digitization techniques. It 
was intended that the input material for ERGIS' raster scanner should "be limited 
to descriptor maps with different colored dots representing different descriptors 
and colored maps ... to simplify input material categorization" (DNRC 1975, 
p. 72). However, ERGIS' capability to handle color has not been utilized fully 
because of difficulties in scanner recognition of certain color variations. There- 
fore, manually drafted "black and white maps" of publication quality with separate 
overlays for descriptors have been used for most of ERGIS' input. Thus far, this 
has not presented a hardship in that most of the map information put into ERGIS 
has also been published by EPD and therefore has required manual drafting anyway. 
However, depending on the complexity and volume of data involved, it appears 
valid to raise the question of whether the manhours required for manual preparation 
on input for the scanner fully offset the manhours which would be required for manual 
or semi-manual digitization. Access to a cartographic staff is required by the 
present situation. The scanner can record a finer degree of detail than may 
be manually feasible, but it appears that the potential for human error has a 

73 - 

nearly equal chance of affecting some portion of either process. Most sources 
consulted during this study have noted that manual and semi-manual digitization 
techniques have not economically inhibited commercially competitive firms nor have 
such techniques adversely affected the management of relatively large amounts of 
data in short periods of time. 

It should be noted that ERGIS was not fully applied to a major project before 
publication of the Anaconda-Hamilton transmission line study by EPD earlier this 
year. Thus, there has not been an adequate basis for comparison of ERGIS with 
alternative systems. 

This discussion is not intended to prove either type of digitization superior, 
but it does touch on issues affecting future data handling choices for Montana. 
In the past, DCA's digitization work has been contracted to out-of-state consulting 
firms using semi-automatic techniques. Examples also exist of state agencies 
and other users pursuing cost-inefficient digitization arrangements on their 
own, perhaps due to unawareness of the options open to them through DCA or EPD 
or perhaps because these options have involved the complications noted above (i.e., 
reliance on out-of-state contractors or extensive manual input preparation) . 

Compatibility between systems is another major factor affecting future data 
management within Montana, as well as future data exchanges within the western 
region and with federal information sources. Compatibility may be analyzed in 
several ways, including comparisons of coordinate systems, coding mechanisms, and 
storage formats. For example, several systems discussed in this report utilize 
the CMS II program or are compatible with it because of similar coding (i.e., 
use of P-cards) which is cellular based. Thus, GMAPS, as it is utilized by ECI 
and LASL, and CMS II as utilized by ECI, LASL and DCA are compatible and data 
programmed through these systems could probably be transferred or exchanged with 
a minimum of programming adjustments. 

Likewise, a number of programs have been or are being developed which address 
the problem of converting data from cellular format to polygon format or vice 
versa. It should be noted that these are two separate operations posing separate 
technical problems; they are not merely the reverse of one another. ERGIS has 
a program for conversion of micro-cell data to polygons which is presently opera- 
tional, although all of ERGIS' data is in run-length coding format. A portion 
of the CMS II package used by DCA was supposed to provide conversion from poly- 
gons to cells, but this program has not worked properly and some specific directive 
or assignment of personnel to work on the problem would be needed to make It 
operational. Also, ERGIS' micro-cells are essentially equivalent to overlaying 
a very small grid on a very large-scale data base. The micro-cells are still 
cellular in format and their properties actually could be duplicated by a more 
conventional cellular system through the process just noted if there was a 
rationale for incurring the cost. 

- 74 - 

The principal ERGIS characteristic which i'' not featured in the other systems 
and which would have to be considered in any transfer of data between these systems 
is the run-length coding format. The run-length code is presently a part of the 
software which operates the scanner and all of the scanner's output is in this 
format. The means to trade ERGIS data with data programmed through CMS II presently 
exists. However, it involves the use of two programs: One to convert CMS II 
information and one to convert ERGIS data to an intermediate form which both systems 
can accept. This intermediate form is from the CMS II package and it would output 
information in CMS II' s coding format. ERGIS information (within its own code) 
is more compact and therefore cheaper to store. If it were necessary or desirable to 
transfer ERGIS data to any other cellular system, the ERGIS files would probably 
have to be decoded. 

The most important compatibility problem is not related to system design, 
since programs exist or can be written to overcome most of the technical problems 
of data exchange. Management of these systems is a far more formidable barrier 
to the coordination of Montana's existing computer hardware to meet user information 
needs (the data bank function) as well as decision-making requirements (data mani- 
pulation and analysis). The most significant aspect of this problem has been the 
lack of close coordination and communication between the agencies which manage the 
systems. This has been evidenced through a general lack of awareness of one 
another's activities as well as unfamiliarity with the contents of one another's 
data files or the specific potential for compatibility between the systems. 

A closely related issue concerns the fact that ERGIS is presently not a data 
bank, even though it has the system capability to be utilized as such. At the 
present time, ERGIS contains only data used in facility siting-related studies 
performed by EPD. The bulk of this information is not source data which could 
automatically be applied to other uses. Rather, it is manipulated data which 
has been input in terms of its relation to various electric transmission line 
impacts. Although the system has been oriented toward its potential use in making 
siting decisions, this does not imply that EPD has no need or inclination to use 
the system as a data bank, especially with regard to processing future siting 
studies. However, development of this function has not yet occurred. Also, the 
ERGIS system generally has not been used outside of the Energy Planning Division. 

This situation may partially be explained by noting that no authorization 
or funding has been granted to either EPD or ERGIS' present owner, the Department 
of Administration, to develop the system's full potential. The lack of coordina- 
tion between ERGIS and the DCA system also may be explained by a similar lack of 
specific direction as well as a general lack of perception of common goals. 
Until such official directives and funding are assigned, the coordination effort 
and the accompanying expense of system development will not be undertaken. The 
concerns mentioned initially in this section — lack of user awareness and under- 
standing of the computer services available — have also been adversely affected by 
the general lack of coordination of services, especially as they relate to natural 
resource data and resource planning activities. 

- 75 - 

It is in the state's best interest to achieve coordination of its existing 
computer capabilities. State coordination of resource data assembly and storage 
activities is a complementary objective which is discussed in Section V. A 
portion of the following recommendations offers a means of dealing with the overall 
coordination problem. 

- 76 - 


Criteria Development and Siting Inventory 

The Major Facility Siting Act should be amended to require that a special 
task force be funded and commissioned by the Legislature to develop criteria to 
be utilized in a statewide siting inventory and to assume oversight responsibility 
for the inventory effort. The criteria ultimately developed and utilized by the 
task force should be formally included in the rules and regulations of the Major 
Facility Siting Act . 

This recommendation recognizes the need for comprehensive long-range planning 
in the siting of energy conversion facilities. Its implementation will provide 
front-end assistance to both regulatory agencies and to applicants. 

A siting inventory must be based upon a series of criteria which identify 
and categorize the complex information needed to compare and evaluate geographic 
areas in terms of their relative suitability for energy facility siting. Develop- 
ment of adequate siting criteria will be a major effort in Itself which will deter- 
mine the subsequent quality of the siting inventory. A special consideration of 
the task force should be the establishment of exclusion and avoidance criteria 
categories which, respectively, would classify land uses and areas where siting 
would be absolutely prohibited or permitted only in the absence of reasonable 

Some types of criteria may require important policy-related decisions if they 
are to be included in the inventory. These include, but are not limited to, 
determination of the extent of non-agricultural uses to be allowed in areas of 
limited surface and ground water supplies; the protection or status to be 
accorded to agricultural and timbered lands as these areas relate to potential 
facility siting; and the siting of facilities near urban areas as opposed to 
siting in remote, sparsely populated regions. 

The task force should be authorized to investigate or fund the investigation 
of topics which will require development of appropriate criteria, but which will 
require in-depth study before recommendations may be made. These topics include 
the transboundary effect of siting facilities near interstate or international 
boundaries; the synergistic effect of siting two or more types of energy generation 
or conversion facilities in close spatial proximity; and the indirect impacts of 
siting created by increased economic activity and development in a site area. 

The task force should include individuals with established expertise in both 
natural and cultural environmental disciplines which will affect or be affected 
by siting decisions and should also include representatives from a wide range 
of interest groups concerned with siting decisions, including, at least, the 
public at large, local governments, industry, utilities and agriculture. 

Ik - 

The task force should be assisted and advised by all governmental agencies 
having- expertise or regulatory responsibilities affected by siting decisions. 
However, future decisions by the Department of Natural Resources and Conservation 
and other land use-related decisions by other agencies should not be compromised 
or influenced by these agencies' roles in criteria development. Potential future 
conflicts of interest of this type will be avoided if a task force independent 
of these agencies is responsible for criteria decisions. 

The siting inventory should be directed toward designation of areas within 
the state that are unsuitable for future siting of energy facilities. The 
designation of unsuitable areas is preferable to designation of specific suitable 
sites because the latter option ultimately would require that the state conduct 
costly site-specific studies without benefit of specific plant design characteristics 
to justify site selections. Designation of unsuitable areas should be accompanied 
by development of preferred site selection criteria to guide future applicants' 
proposed site selection activities. 

Data Collection, Storage and Retrieval 

One Suate agency should be designated the resource data assembly and storage 
unit, charged with the maintenance of resource data files to meet the planning and 
decision-making needs of other state agencies, county and local governmental units, 
and the widest possible range of other uses . , 

A general lack of interagency coordination and the preoccupation of each agency 
with its own area of responsibility has resulted in fragmentation of responses 
to land use and resource management problems. These types of problems, by nature, 
involve many complex, overlapping concerns which it has been impossible to consoli- 
date administratively. Portions of the information needed to solve these problems 
may potentially be applied in many different contexts by different agencies, but 
nonstandardization of resource information has hindered coordinated use. The 
above recommendation would provide a means of correcting this situation. 

Implementation of this recommendation will require funding and expansion 
of appropriate staff within the agency assigned this responsibility. However, exist- 
ing and potential users of resource data must have major input into the design of 
a data storage system, selection of data storage categories, designation of data 
accuracy standards, and other related decisions. Agencies with decision-making 
responsibilities which require resource data should remain responsible for col- 
lecting necessary information, but with the understanding that this data would be 
stored and utilized in the overall data system. 

It should be noted that the site inventory effort will require reliable, 
standardized statewide information in many data categories. Depending upon 
scheduling and other decisions, the implementation of that site inventory recom- 
mednation and the above data assembly and storage recommendation would be highly 
comp 1 emen t a r y . 


- 78 - 

Resource data is being digitized for use in existing computer systems 
in the state. These efforts should be strongly encouraged and supported. Also, 
the digitization of reliable statewide resource information to meet immediate 
planning needs should be a major objective of the data assembly and storage 
agency. The computer hardware used for data storage can also be used for data 
maniuplation and analysis activities, but the management responsibility for each 
function must be clearly specified and considered equally important. 

A committee familiar with both the technical aspects of computer system design 
and the special requirements of resource data should be assigned the responsibility 
of evaluating the computer systems in the state and improving resource data hand- 
ling capabilities . 

The existing data processing policy committee could meet this requirement if 
members with specific understanding of geographic, resource-related data are 

The two alternatives for data digitization presently existing through the Depart- 
ment of Community Affairs and the Department of Administration appear less than 
optimal. Improvements may be achieved through better coordination of existing 
hardware. Also, the purchase of a semi-automatic digitizing device could be con- 
sidered. However, it would be necessary to compare this expense with the cost 
of continuing to contract projects to out-of-state firms. The capabilities of 
the Department of Administration's raster scanner, with its special input 
requirements and coding format, must also be evaluated before any decisions are 

With input from potential system users and the data assembly and storage agency, 
the data processing committee should review the various software capabilities 
presently available in the state and recommend other capabilities which should be 
purchased or written in light of future needs for analysis of resource data. 
Both cellular and polygon storage systems appear to offer distinct advantages 
which should be maintained, but this will require development of reliable con- 
version programs. 

Tests and comparisons between systems and data handling costs may be required 
in order to formulate optimal recommendations. 

Effort must also be devoted to develop more effective presentation of Montana's 
computer capabilities to potential users . 

Public Involvement 

The Major Facility Siting Act should be amended to adopt broad spectrum public 
participation as a principle of operation. 

- 79 

The forms of participation should not be limited to public hearings, but 
should also include advisory committees to work closely with the state siting 
agency in the power plant siting and transmission line routing processes. This 
policy also would apply to the activities of the siting inventory task force. 

Short-Term Planning 

The siting act should be amended to require the filing of a notice of intent 
to file an application for a certificate of environmental compatibility and public 
need for a major energy facility at least twelve months prior to the actual filing 
of an application. This notice must disclose the specific site location being 
considered for the proposed facility . 

A specific enforcement clause should be added to the siting act which would 
impose severe penalties upon any person who knowingly submits false or misleading 
information in the ten-year plan . 

These two provisions would serve short-term site planning needs prior to 
completion of the siting inventory; however, they should not be viewed solely in 
this context. The notice of intent would provide greater opportunity for public 
review and input into site location decisions and would allow the state and the 
applicant to confer on the suitability of a given site and identify problems as well 
as areas of agreement prior to the actual application process. This would stream- 
line the process and eliminate major delays following application. The enforce- 
ment clause is designed to insure compliance with the intent of the ten-year utility 
long-range plans presently required by the siting act. These plans are the state's 
principal source of information regarding future plans for construction of energy 
facilities and their proposed general locations. 

Additionally, the state should consider developing a specific methodology 
which utilities would be required to follow in formulating the energy demand fore- 
casts required in the long-range plans. This would allow more efficient state 
review and analysis of the forecasts while the future level of state involvement 
in projecting energy demand is being determined. 


- 80 - 


1. Adair, Frederick S. 19 16- 11 . Executive Director, Office of Nuclear Energy 
Development, Washington Department of Commerce and Economic Development. 
Telephone Communication, November 22, 24; January 6. 

2. Annotated Code of Maryland, Cumulative Supplement, 1973. Power Plant 
Siting Act, Article 66C, Section 766-771. 

3. Ball, R. H. , et al. , 1972. California's Electric Quandary: II. Planning 
for Power Plant Siting. Santa Monica, California: RAND, September. 

4. Bowie, Michael, 1976. Staff, EDAW, Inc. , San Francisco. Telephone Com- 
munication, December 22. 

5. Brown, Barry, 1976. Project Coordinator, Facility Siting Division, California 
Energy Resources Conservation and Development Commission. Telephone Com- 
munication, December 10; 20. 

6. Brush, G. , 1976. Power Plant Siting Program, Maryland Energy and Coastal 
Zone Administration. Telephone Communication, December 20. 

7. California Energy Resources Conservation and Development Commission, 1976. 
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Development Commission, April. 

8. California Energy Resources Conservation and Development Commission, Facility 
Siting Division, 1976a. Power Plant Siting Report. Sacremento, California, 
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9. California Public Resources Code, 1975. Warren-Alquist State Energy Resources 
Conservation and Development Act, Section 25000 et seq. 

10. Council of State Governments, 1976. State Energy Management: The California 
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11. Council on Environmental Quality, 1976. The Seventh Annual Report of the 
Council on Environmental Quality. Washington, D.C.: U.S. Government Printing 
Office, September. 

12. Dobson, Jerome E. , 1976a, The Maryland Power Plant Siting Project: An 
Application of the ORNL — Land Use Screening Procedure. Oak Ridge, Tennessee: 
Oak Ridge National Laboratory, October. 

- 81 - 


13. Energy Research and Development Administration, 1976. Regional Energy 
Assessment Program — Informal Progress Report, July. 

14. Englerth, Edward, 1976. Director, Reclamation and Siting Division, North 
Dakota Public Service Commission, Telephone Communications, November 2. 

15. Federation of Rocky Mountain States, Inc., 1976. CMS II: A New Tool for 
Policy Makers. Denver: Federation of Rocky Mountain States, Inc., April. 

16. Federation of Rocky Mountain States, Inc., 1976a. CMS II: Regional Technical 
Advisory. Denver: Federation of Rocky Mountain States, February. 

17. Federation of Rocky Mountain States, Inc., 1976. Composite Mapping System 
II: Users Manual. Denver: Federation of Rocky Mountain States, March. 

18. Fort Union Regional Task Force on Energy Development, Regulation and Plant 
Siting, 1976. Final Report. Bismarck, North Dakota: Legislative Council, 

19. Hynes, John, 1976. Director, Minnesota Power Plant Siting Program. Telephone 
Communication, November 29. 

20. Karp, Richard, 1976. Water Quality Specialist, Water Quality Bureau, Depart- 
ment of Health and Environmental Sciences. Letter to Sharon M. Solomon, 
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21. Maryland Energy and Coastal Zone Administration, Power Plant Siting Program, 
1976. Contract with Rogers and Golden, Inc., and Alan/Mallach Associates. 
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22. Maryland Energy and Coastal Zone Administration, Power Plant Siting Program, 
1976. Long Range Plan. Annapolis, Maryland: Energy and Coastal Zone 
Administration, April. 

23. Massicot, Paul, 1976. Power Plant Siting Program, Maryland Energy and 
Coastal Zone Administration. Telephone Communication, December 3. 

24. Minnesota Environmental Quality Council, 1974. Rules and Regulations for 
Power Plant Siting and Transmission Line Routing, Chapter 21, 71-75. 

25. Minnesota Environmental Quality Council, 1975. Inventory 1975: Candidate 
Areas for Large Electric Power Generating Plants, April. 

26. Minnesota Statutes, 1974. Power Plant Siting Act, Section 116C.51 et seq . 

27. Montana Department of Health and Environmental Sciences, Air Quality Bureau, 
1976. Background Air Quality and Meteorological Coverage for Siting Con- 
sideration, November. 



- 82 - 

28. Montana Department of Natural Resources and Conservation, 1975. ERGIS Data 
Bank for Land and Resource Utilization. nelena, July, 

29. Montana Department of Natural Resources and Conservation, 1976. Draft 
Environmental Impact Statement on Anaconda-Hamilton 161 KV Transmission 
Line. Helena: Department of Natural Resources and Conservation, July. 

30. Montana Department of Natural Resources and Conservation, 1976. Draft 
Montana Statewide Siting Study Proposal. Helena, November. 

31. Montana Energy and MHD Research and Development Institute, Inc., 1975. 
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Report. Butte, Montana: MEMERDI, November 3. 

32. Morris, Melvin H. , 1976. Professor Emeritus, Range Management, University 
of Montana. Letter to Sharon M. Solomon, Montana Energy Advisory Council, 
November 23. 

33. Nichols, Ronald 0., 1976. Licensing Office, Facility Siting Division, 
California Energy Resources Conservation and Development Commission. Tele- 
phone Communication, November 2. 

34. North Dakota Century Code, 1975. North Dakota Energy Conversion and Trans- 
mission Facility Siting Act, Chapter A9-22. 

35. North Dakota Public Service Commission, 1976. Energy Conversion Facility 
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Public Service Commission, July. 

36. North Dakota Public Service Commission, 1976. Rules and Regulations Governing 
the Siting of Energy Conversion and Transmission Facilities. R49-22, 

37. Oregon Administrative Rules Compilation, 1975. Designation of Areas of 
Oregon as "Suitable" or "Unsuitable" for Thermal Power Plant Siting. 
Chapter 345, Division 4, Section 40-005 et seq . , January. 

38. Oregon Revised Statutes, 1975. Energy Facility Siting. Sections 469.300- 
570, 469.922. 

39. Revised Codes of Montana, 1947. Major Facility Siting Act. Chapter 8, 
Section 70-801 et seq . 

40. Revised Codes of Washington, 1976. Energy Facilities — Site Locations. 
Section 80.50 et seq . 

41. Salem, Larry J., 1973. Statewide Geographic Information Systems to Meet 
State Specific Needs and the Requirements of Federal Legislation S. 268 and HR. 
10294. Denver: Federation of Rocky Mountain States, November. 

- 83 - 

hi. Southern Interstate Nuclear Board, 1976. Power Plant Siting in the 

United States. Atlanta, Georgia: Southern Interstate Nuclear Board, June. 

43. Tillson, David D., 1977. Principal Geologist, Plant Siting and Geological 
Services, Washington Public Power Supply System, Telephone Communication, 
January 6. 

44. Turner A. Keith, 1976. Computer Aided Environmental Impact Analysis, Part 1: 
Procedures. Mineral Industries Bulletin, Vol. 19, No. 2. Colorado School 

of Mines, March. 

45. Turner, A. Keith, 1976a. Associate Professor of Geology, Colorado School 
of Mines. Personal Communication, October 18. 

46. Vogel, Richard, 1976. Q-10 Research Group, Los Alamos Scientific Laboratory. 
Personal Communication, October 20. 

47. Washington Public Power Supply System, 1975. Executive Summary Siting Study. 
Richland, Washington: Washington Public Power Supply System, December. 

48. Western Governors' Regional Energy Policy Office, 1976. Information From 
WGREPO //76-45. Denver: WGREPO, August. 

49. Wood, W. Kelly, 1976. Energy Facility Siting Coordinator, Oregon Department 
of Energy. Telephone Communication, November 2, December 20. 

50. Zink, Vern, 1976. President, TPI, Inc., Bismarck, North Dakota. Telephone 
Communication, December 20. 



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1. Colorado State University, College of Forestry and Natural Resources, 1973. 
Colorado Environmental Daea Systems, Final Report to Colorado Department 
of Natural Resources. Fort Collins: Colorado State University. 

2. Federation of Rocky Mountain States, Inc., 1976. Briefing Materials for 
FRMS. LANDSAT and Geographic Analysxs Activities. Denver, Colorado: 
FRMS, January. 

3. Federation of Rocky Mountain States, Inc., No Date. Technical Proposal: 
Adaptational Development and Prototype Implementation of an Operationally 
Oriented, Computerized, Map-Based Data Storage and Analysis System for Fish 
and Wildlife Resource Management Use. R.F.P. No. FWS-8-199. 

4. Idaho Water Resources Research Institute, 1975. Energy Plant Siting 
Legislation: A Current Appraisal for Idaho. Moscow, Idaho: University 
of Idaho. Information Circular No. 9, February. 

5. Idaho Water Resources Research Institute, 1975. Energy Plant Siting Problems 
of the Pacific Northwest. Gladwell, J.S., et al. , ed. Moscow, Idaho: 
University of Idaho, June. 

6. Jalbert, Jeffrey S. and Dobson, Jerome E. , 1976. A Cell-Based Land Use 
Screening Procedure for Regional Siting Analysis. Oak Ridge, Tennessee: 
Oak Ridge National Laboratory, October. 

7. Jalbert, Jeff rey S. and Shepherd, Alf D. , 1976. A System for Regional 
Analysis of Water Availability. Oak Ridge, Tennessee: Oak Ridge National 
Laboratory, October. 

8. New Mexico Land Use Advisory Council, 1975. Land Use Information System 
Design Study for State of New Mexico. Final Report. Albuquerque, New 
Mexico: Land Use Advisory Council, January. 

9. New York State Public Service Commission, 1974. Generating Station Site 
Survey. Draft Report on Hudson River Valley/Long Island Pilot Area Site 
Area. Albany, New York: Public Service Commission, July. 

10. Peterson, John L. , 1976. Attorney for Colstrip Units 3 and 4 Applicant 
Companies Under Montana Utility Siting Act. Letter to Lieutenant Governor 
William Christiansen, November 22. 

11. Shanahan, Ward A. , 1976. Attorney, Burlington Northern. Letter to 
Lieutenant Governor William Christiansen, November 12. 

12. Shenker, Arden E. , 1976. Attorney for Montana Department of Natural 
Resources and Conservation for Colstrip Units 3 and 4 Hearing Proceeding 
Under Montana Utility Siting Act. Letter to Lieutenant Governor William 
Christiansen, November 9. 

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13. Smedes, H. W. , et al . , 197A. Land Use Planning Aided by Computer Cellular 
Modeling - Mapping System to Combine Remote Sensing, Natural Resources, Social 
and Economic Data. Proceedings of the Ninth International Symposium of 
Remote Sensing of the Environment, Ann Arbor, Michigan, April 15, 19. 

14. Smedes, H. W. , et al . , 1976. Oblique Airphotos for Mapping, Educating User 
Groups and Enhancing Public Participation in Environmental Planning: A 

Case Study. Paper Presented at 55th Annual Meeting of Transportation Research 
Board, Washington, D.C., January 19-23. 

15. Smedes, H. W. and Turner, A. Keith, 1975. Cooperative Development of an 
Environmental Information System for Jefferson County, Colorado. Presented 
at ASO-ACSM Fall Convention, Phoenix, Arizona, October 26-31. 

16. Smedes, H. W. and Turner, A. Keith, 1975. Map Atlas of Basic Data for 
Computer-Aided Land Use Planning Studies of the Northern Part of Jefferson 
County, Colorado. Denver: U.S.G.S. Open-File Report 75-608. 

17. Southern Interstate Nuclear Board, 1972. Power Plant Siting in the United 
States — a State Summary. Atlanta, Georgia: SINB, September. 


18. Turner, A. Keith and Hausmanis, I., 1972. Computer-Aided Transportation 
Corridor Selection in the Guelph-Dundas Area, Ontario, Canada. Presented 
at 1972 Summer Meeting, Highway Research Board, Madison, Wisconsin, July 31 - 
August 2. 

19. U.S. Forest Service, Berkeley, California Management Sciences Staff, 1976. 
Analysis of Computer Support Systems for Multi-Functional Planning. Report 
III. Berkeley, California: U.S.F.S., June. 

20. U.S. Nuclear Regulatory Commission, 1975. Final Report. The Objectives 
and Institutional Mechanisms of a Regional Approach to Nuclear Power Plant 
Siting, December. 

21. U.S. Nuclear Regulatory Commission, 1975. Proceedings of the 1975 Federal- 
State Conference on Power Plant Siting, Bethesda, Maryland, April 7-9. 

22. U.S. Nuclear Regulatory Commission, Office of Special Studies, 1976. Nuclear 
Energy Center Site Survey — 1975. Washington, D.C. : National Technical 
Information Service, January. 

23. U.S. Nuclear Regulatory Commission, Office of Standards Development, 1975. 
General Site Suitability Criteria for Nuclear Power Stations. Washington, 
D.C: U.S. Nuclear Regulatory Commission, November. 

2A. U.S. Nuclear Regulatory Commission, Office of State Programs, 1976. Efficiency 
in Federal/State Siting Actions. Detailed Study Plan, October. 


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25. U.S. Nuclear Regulatory Commission, Office of State Programs, 1976. Pro- 
ceedings of the Second State-Federal Power Plant Siting Conference, Denver, 
June 16-18. 

26. Voelker, A. H. , 1976. Power Plant Siting: An Application of the Nominal 
Group Technique, October. 

27. Wyoming Conservation and Land Use Study Commission, 1974. Statewide Land 
Use Planning Program for Wyoming. Cheyenne: Wyoming Conservation and Land 
Use Study Commission, October.