Final Environmental Impact Statement Volume II Appendix K, Part 2

Home Browse Search

COMMENTS OF U.S. ENVIRONMENTAL PROTECTION AGENCY EPA-45 2. Although there is a substantial amount of information provided in Section 2.13 and Appendices E and G, the analysis in Section 5.0 does not appear to make use of this information in the evaluation and selection of alternatives. Instead, the evaluation of alternatives appears to involve qualitative assessments, rather than use of the specific economic information provided elsewhere in the document. EPA-46 3. The document discusses potential environmental effects at length, but does not attempt to place monetary values on these effects. Monetizing potential impacts (to the extent possible) would provide a basis for assessing costs and benefits of alternatives, which the net present cost method used in Section 2.13 does not do. Even if all impacts were not fully monetized, the use of monetary values would provide a more comprehensive evaluation of the alternatives. In the specific comments provided below, the recreation analysis is identified as one area where improvement could be made. EPA -4714. On p. 2 -40, para. 5, the RDEIS states that "[t]he indirect costs associated with impacts are addressed in Section 4.0, where impacts are described in quantitative terms to the extent x possible." The sentence should be revised to indicate that none lof the impacts addressed in Section 4.0 were monetized. 00 .p EPA-48 5. PP. 2 -42, 2 -43. The net present value approach is correct. Two issues regarding this approach need to be addressed in the final EIS. First, the unit costs or inputs for computed values need to be provided as part of the description accompanying Table 2 -12, which uses the computed values to evaluate alternatives. Without description of inputs, independent assessment of the correctness of the analysis is difficult. Second, the RDEIS does not carry the analysis of net economic value far enough. Table 2 -12 aims to evaluate the potential economic burden of each alternative on existing facilities -- one way of measuring cost effectiveness. However, Table 2 -12 is not accompanied by an analysis identifying the implications for each alternative. Are there some alternatives that are too expensive? Or some components of alternatives which, considered on a basis of cost effectiveness, can be eliminated or modified? EPA 49 6. This analysis is again taken up on p. 5 -40, where the RDEIS indicates that $45 million combined cost for relicensing measures and operating effects is presented as the maximum threshold. The final EIS should explain how this threshold was selected, and what the potential consequences of exceeding it would be. Would exceeding this level adversely affect the marketing of hydropower? What would be the effect on electricity prices for each alternative? Is the difference between $0.06 /kWh and $0.066 /kWh a significant difference? 23 RESPONSES TO U.S. ENVIRONMENTAL PROTECTION AGENCY EPA45 The purpose of the Commission's economic analysis is to provide an approximation of the potential project power benefits and costs. The analysis helps to support an informed decision as to what is in the public interest with respect to a proposed license. The economic information is available for the Commission to use as it deems appropriate in it s licensing decision. EPA -46 We have provided monetary estimates of impact where they can reasonably be estimated (e.g., pumping costs at Gerald Gentleman Station and canal maintenance costs). EPA -47 ,Quantitative" does not mean the same as "monetary." We have described instream flow and reservoir storage impacts in terms of exceedance frequencies, which are quantitative. EPA -48 The economic analysis has been thoroughly revised to reflect current Commission policy. EPA -49 Refer to the foregoing response to EPA -48.