Final Environmental Impact Statement Volume II Appendix K, Part 1

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COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND IRRIGATION DISTRICT B. The Districts• Fair Share of Basin Wide Programs for Endangered Species is Substantially Less than FERC Staff Recommends CEN -3 under the MOA, the Districts fair share of basin - wide programs for endangered species should be similar (on a proportional basis) to the interim enhancement requirements already assigned by DOI to the Front Range cities in Colorado as part of their "reasonable and prudent alternatives" under section 7 of the ESA. As indicated x w above, DOI's biological opinions propose interim measures based on allocated responsibility for basin -wide enhancement measures. Defining each project's "equitable share" as the r *tio of project depletions to total basin -wide depletions, DOT- developed a formula to determine the contribution to be made by the Front Range cities for water and for land -based enhancements. CEN-4 1. The Nebraska State Plan Offers at Least the Districts' Fair Share of Water Resources In the Front Range biological opinions, the "equitable share" of water enhancements each city was to provide was determined by multiplying the project's proportional share of the 3,000,000 acre -feet estimated total depletions in the basin (as calculated by DOI) times the total water enhancements that DOI deemed necessary. The formula used an estimate of water needs based on DOI's March 1994 instream flow recommendations for the basin which DOI - 11 - RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND IRRIGATION DISTRICT CEN -3 This comment has been overtaken by the adoption of the Cooperative Agreement. CEN -4 We note Central's contention that the Nebraska Plan offers at least the Districts' "fair share" of water resource improvements in the context of Interior's Front Range biological opinions and the formula applied in those opinions.