Final Environmental Impact Statement Volume II Appendix K, Part 2

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COMMENTS OF U.S. ENVIRONMENTAL PROTECTION AGENCY RESPONSES TO U.S. ENVIRONMENTAL PROTECTION AGENCY EPA -17 The RDEIS does not indicate that any coordination on EPA -18 potential 404 issues between FERC and the Corps Omaha District (cont.) has occurred. In order to ensure that the supplemental measures for habitat restoration can be constructed as described in the RDEIS, FERC should coordinate with the Corps prior to release of the final EIS and identify how the general permit being developed by the Corps will be consistent with construction of the proposed habitat restoration areas. v O� In anticipation of an increase in activities involving habitat restoration on the Platte River system, the Corps initiated discussions in October 1993 with governmental and nongovernmental groups about the feasibility of developing a CWA section 404 general permit (GP). Discussions to date have involved federal and state regulatory agencies in Nebraska as well as representatives from the National Audubon Society, the Platte River Whooping Crane Trust, CNPPID, and NPPD. Based on review of the RDEIS it is evident that certain supplemental measures proposed for the Platte River are either not addressed in the draft GP or may run counter to conditions currently developed in the GP. For example, wet meadow restoration would likely involve the placement of fill materials to restore hydrology. However, the draft GP is focused on restoration activities restricted to the channel(s) of the Platte. These actions would require section 404 authorization. This example demonstrates the importance of Corps /FERC coordination to ensure alignment between activities identified in the RDEIS and the requirements of section 404. 3. Priorities of Supplemental Measures FERC concludes that the maximum present value of the costs of relicensing should not exceed $45 million in order to maintain an economically viable project with its benefits to irrigation and recreation. According to FERC, subtracting the estimated $5.9 million cost of changing the hydropower operating regime leaves $39.1 million as the maximum cost of supplemental and enhancement measures. FERC concludes this would be sufficient to fund all Priority 1 and 2 measures. EPA -18 The economic analysis presented in the RDEIS is based on a 30 -year period using 5 percent inflation and an a percent discount factor. The Office of Management and Budgets Circular A -94 addresses private power projects and recommends a discount rate of 74. In light of Circular A -94, we believe that the analysis should be re- examined. The supplemental measures are an integral part of the implementation of whatever preferred alternative is finally chosen as a result of this relicensinq process. As identified in 15 The economic analysis has been extensively modified to reflect current Commission policy.