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COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />of the 1,928,700 total acres in the basin directly served <br />with surface water, 225,000 (or 12t) receive water stored in <br />or passed through Lake McConaughy.F <br />The Projects' proportional role in the Platte River <br />basin could also be based on their relative effect on flows. <br />Such measures suggest lot to 15t would approximate the <br />Districts' role in the basin. DOI has indicated in this <br />proceeding that it estimates the Project's contribution to <br />"total consumptive use" in the basin to be between 9.5% and <br />10.8t.v <br />Simons & Associates performed hydrologic studies to <br />assess the long -term changes in North Platte, South Platte, <br />and Platte River streamflow.11 Simons evaluated reductions <br />g Platte River Management Joint Study, Platte River <br />Habitat Conservation Program (Draft May 17, 1993) ( "PRMJS, <br />Habitat Conservation Program "). <br />1-' DOI, U.S. Fish and Wildlife Service, Grand Island <br />Field Office, Estimated Water Storage and Consumptive Use <br />For Proiarts 1417 and 1835, at 12 (July 17, 1990), <br />Attachment 9 of The Department of the interior's Comments <br />Under Section 10(i) of the Federal Power Act (Nov. 15, 1990) <br />( "DOI, 1990 10(1) Comments "). This is based on average <br />annual "consumptive use" estimates for the Projects of <br />299,775 acre -feet and 344,210 acre -feet. Id. at 12. These <br />estimates are very similar to the estimates being used by <br />DOI in Section 7 consultations with the Front Range cities. <br />5g, e.g., DOI, Front Range Biological Opinion 29 -30 <br />(June 2, 1994) ( "DOI, Front Range Opinion ") (discussing <br />depletions in the basin), attached as Vol. 2, Ch. X, <br />App. X -E. <br />F Simons & Associates, Platte River System Hydrologic <br />Analysis (Jan. 1990) ( "Simons, Hydrologic Analysis "), <br />previously filed as App. IV, Tab A with Central and NPPD, <br />Joint Response of the Central Nebraska Public Power and <br />Irrigation District and the Nebraska Public Power District <br />(continued...) <br />- 6 - <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />