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COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />in historic mean and peak flows during the month of June <br />(the peak runoff and germination period), assigning <br />responsibility for changes based on May and June storage <br />records for mainstream reservoirs. This study concluded <br />that reductions in peak flow were predominantly caused by <br />water development upstream of the Projects, ultimately <br />allocating 85t of peak flow reduction to upstream reservoirs <br />in Wyoming and 15t to Lake McConaughy, though Simons noted <br />that both numbers were too high because they did not take <br />into account the many small diversions in the river <br />system.91 <br />The role of these Projects and others in a basin -wide <br />environmental program is also presently being explored <br />�D <br />within the context of a recent MOA'a signed by Secretary <br />Babbitt of the Department of the Interior and the Governors <br />of the States of Wyoming, Nebraska and Colorado. <br />The purpose of the MOA is "to initiate the development <br />of a mutually acceptable Platte River Basin Endangered <br />Species Recovery Implementation Program" (Basin -Wide <br />Recovery Implementation Program) to address the needs of <br />listed species in Nebraska's Platte River basin upstream of <br />F (...continued) <br />to the Federal Energy Reculatory Commission's December 7. <br />1984 Deficiency Notice (May 5, 1990) ( "Joint Response "). <br />91 Id. at 73. <br />!-a MOA, see supra n.2. <br />- 7 - <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />