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. Me. 80b McCuc February 14, 1997 Page 2 OPSTUDY'computer model, source code and associated input and output files uscd,in, developing the comparison of alternatives, results, and conclusions discussed in the DBO; the spreadsheet or other analyses, data and assumptions used in deriving the estimates of economic values ot~ and tinancial capabilities to sustain mitigation costs for, among others, irrigation water supply, as set forth in Appendix A to the DBO; an indication as to whether the FWS required irrigators served by other federal water projects in the Platter River Basin to conserve a specified amount or percentage of water, whether NPPD and Central are each to be responsible for effectuating 50% of the required water conservation, and whether the Service intends that conserved water requirements include natural flow water, and, if so, whether it intends for the Districts to condcnln such natural flow rights. and how the anlOunt of water c-6nserved~wi11-lJe- --- measured, and for all cost and conservation data from other water conservation projects required by the Service in other projects. NWU is keenly interested in FWS's responses to these questions raised by the Districts, To date, however, meaningful responses to these and other important questions have not been forthcoming. Accordingly, NWU is limited in its ability to provide the Service with fully informed comment at this time, but respectfully retains the right to supplement this submission. COMMENTS NWU's primary concerns with the DBO relate to the base flow proposals, the various economic analyses, particularly related to irrigation value and mitigation costs, the DBO's water conservation proposals, and the prospective drought protection capabilities of Lake McConaughy. Base Flow Proposals Approximately 90% ofNPPD and 50% of Central's diversions consist of natural flow water. In order to accommodate the FWS base flow proposals, the Districts would inevitably have to intrude on natural flow water right owners property rights. Yet the DBO mitigation analysis fails to address the condemnation costs associated with such a reallocation of water rights. Moreover, the DBO does not delineate any legal authority for requiring the Districts to condemn property that is not project related. Economic Analyses Comparing the DBO's economic valuation of irrigation provided by the projects with the value of recreation clearly demonstrates how fundamentally flawed is the DBO. Recreation appears to be valued by a --multiplier effect" analysis, which reflects the total contribution' of recreation participants to the local economy, while the irrigation value is based on a much more