Comments to the North Dakota Health Department reaffirm the Tribune Editorial Board’s belief that more information is needed on the impact of the proposed Davis Refinery and that Meridian Energy Group should seek a siting permit from the Public Service Commission.

While the potential jobs and economic boost for Billings County carries a lot of importance, North Dakotans should have a clear understanding of the refinery’s impact on the Theodore Roosevelt National Park and area landowners. The park makes this a state, some would argue a national, issue. This isn’t limited to Billings County.

In a letter to the health department, the Air Resources Division of the National Park Service said more evaluation is needed of flaring caused by possible upset conditions at the refinery, which could increase emissions. "Based on our analysis, emissions from the refinery could cause visibility impairment at Theodore Roosevelt NP under upset conditions when blowdown emissions are exhausted through the flares," the letter said.

Theodore Roosevelt Superintendent Wendy Ross in the letter requested more information, modeling and analysis of air emissions during upset conditions, as well as possible mitigation. She said in the letter that the park service is concerned about future impacts to the park if Meridian decides to expand. Ross asked that the health department require additional permit review and public input prior to any expansion.

The Tribune believes instead of waiting for a decision on expansion that Meridian should ask the PSC for a site permit. This would hopefully answer the questions and concerns surrounding the proposed refinery. The park service’s letter didn’t come out in opposition to the refinery, but it did raise valid concerns.

A PSC permit isn’t required for refineries that process less than 50,000 barrels per day, and Meridian says its initial phase of the project will process 27,500 barrels per day.

If the company’s intent is to expand the refinery after it’s built, it makes sense to request a siting permit now and, if the company’s position is correct, put concerns to rest at the beginning.

Objections to putting a refinery about 3 miles from the south unit of Theodore Roosevelt National Park are understandable. The park is probably the most valuable jewel in the state’s tourism crown. The beauty of the Badlands and the variety of the wildlife lure tourists from around the world. We should be protective of the park.

The health department got about 11,000 emails during a public comment period that ended Friday. While the majority of the comments are identical they still reflect the high interest in the issue.

It’s been suggested as part of its decision that the health department require Meridian to seek the siting permit from the PSC. Health department officials aren’t sure they can require it. We hope they can and do.

Meridian says the refinery will not be visible from the park, but its analysis is limited to five observation points in the 46,000-acre South Unit. An early analysis from the National Park Service showed the refinery could potentially be seen from 630 acres in the park, including large sections of the eastern side. It's unclear if changes in the facility plans affect this early analysis.

These are issues that need to be resolved by the health department and, hopefully, PSC involvement.

At the same time, the Tribune thinks it’s doubtful the PSC would reject a siting permit. There are some who won’t be happy unless the refinery is stopped and others want to speed up the process of approving the refinery.

The Tribune wants a thorough review and safeguards adopted if necessary. The refinery offers economic benefits for Billings County and the state. That’s good, we just need to do everything right.