Final Environmental Impact Statement Volume II Appendix K, Part 1

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CEN -2 N COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND IRRIGATION DISTRICT depletions in the basin,121 the Districts' share would be 114 of the basin's enhancements.& Each of these analyses allocates responsibility based on some measure of impact on flows. Many other components of the development of the basin also affect the available acreage of various habitat types without affecting flows. They include: agricultural draining of wetlands; bridges and other shoreline construction, including Interstate -80; and bank stabilization programs. Clearly, the role of the Projects in changing the Platte River Basin, and in maintaining it in its present state, is relatively small. FERC Staff must take care in this proceeding not to burden the Projects and their beneficiaries with a disproportionate share of "restoration" or "enhancement" measures. No matter how the Districts' share is calculated, approximately 10 -154 of the goals for the basin (whether land -based or water - related enhancements) is the most these Districts should be asked to achieve. L1 In oral communications, DOI preliminarily has suggested that the Projects are responsible for 330,000 acre -feet of a 3,000,000 acre -feet depletion total. Central believes DOI's methodology serves to overestimate both total depletions and depletions by individual entities on the Platte River by inadequately accounting for the return of diverted water to the river through returns, drains and as river gain and run -off. This returned water is counted a second, third or fourth time as a depletion when diverted for reuse. L' ,fig infra section II.A.1. for a more detailed discussion of DOI's approach. - 10 - RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND IRRIGATION DISTRICT CEN -2 The Commission must equally consider developmental and nondevelopmental values in its determination of the public interest within the guidelines established by the Federal Power Act. It is the Commission's practice in relicensing to consider all aspects of the public interest, including the project(s)' potential to improve existing conditions in light of present day societal values, taking into consideration the various purposes (developmental and nondevelopmental) potentially served by the project(s).