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A <br />COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />filed in this proceeding as "revised 10(j) comments. "211 <br />DOI estimates that an additional 386,000 acre -feet of water <br />would be needed at Grand Island to meet its goals in the <br />median water year.V In the Front Range biological <br />opinions, the "equitable share" of 386,000 acre -feet was <br />multiplied by $5.50 /acre- foot /year to cover water delivery, <br />and the projects were responsible for the administrative <br />costs of acquiring the water. <br />DOI has indicated that it assigns a 330,000 acre -feet <br />depletion to the Projects,P" which corresponds to 111k of <br />Ul DOI, The Department of the Interior's ReviseA <br />Comments Under Section 10(j) of the Federal Power Act <br />(May 19, 1994) ( "DOI, May 19, 1994 Comments ") . <br />22' DOI, FOIA Response 45f Memorandum from Mark Butler <br />( "Butler Memorandum "), attached as Vol. 2, Ch. II, <br />App. II -B -8. DOI's preliminary deficit number was <br />calculated as follows: (1) DOI ranked each year from 1943- <br />1992 according to the total volume of flows past Grand <br />Island, designating the highest 33% wet, the lowest 25% dry, <br />and the remaining 42$ normal; (2) For each year, DOI <br />compared the total volume of flow past Grand Island in the <br />years 1943 -1992 with the total volume of flows recommended <br />for each period in that year (for example, May 11 to <br />Sept. 15) when target flows are the same. DOI used wet, <br />normal or dry year targets depending on the total annual <br />flow for the year; (3) For those periods in the year when <br />targets exceeded total volume, the differences were summed <br />to get the annual deficit; and (4) The average annual <br />deficit for the historic "normal" years is 386,000 acre - <br />feet. <br />at Central believes that both the 330,000 acre -feet <br />number and the 3,000,000 acre -feet total depletion figure <br />which DOI has suggested using on at least a preliminary <br />basis for the basin are inflated because they do not <br />adequately take into account return of diverted water <br />through drains and as river gain and run -off. Water which <br />is returned and then reused is counted again and again as <br />depletions. <br />- 12 - <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />