Final Environmental Impact Statement Volume II Appendix K, Part 1

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COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER IRRIGATION DISTRICT the basin's estimated depletions. Under the Front Rang formula, the Districts' 11% "equitable share" of the 3e acre -feet shortage is 42,460 acre -feet per year. Withc making any of FERC Staff's proposed modifications to tk Nebraska State Plan, this amount of water is more than generously provided for under this plan. The Staff calculates that under the Nebraska State Plan, the Proj will on average release 85,000 acre - feet /year from stor that would not otherwise be released in order to meet k flow requirements and to supplement these releases witk additional releases from the environmental account.m' water contribution substantially exceeds the 42,460 acx feet which represents the Districts' share under the Fx Range formula. Perhaps more importantly, the Nebraska State Plan delivers actual water that can be scheduled to the habitat u' RDEIS at 4 -6, Table 4 -3. Central believes that this number is significantly smaller than the volumes that would actually be released because OPSTUDY modeling matches water perfectly with need in a way unlikely to be accomplished in reality. E= Vol. 2, Ch. III, section C.; Central, Comments of the Central Nebraska Public Power and Irrigation District in Support of the Nebraska State Plan 16 (Feb. 9, 1993) ( "Central, Comments Supporting the Nebraska State Plan ") (average size of environmental account is 60 kaf, and releases to maintain base flows average 29 kaf per year). In addition, the Staff modeled the Nebraska State Plan in the RDEIS in a manner that frequently leaves water unused in the environmental account. It would clearly be released and put to use for wildlife in the real world. ,$gg Vol. 2, Ch. III, section B. Clearly, if very different plans were made for use of the environmental account, larger quantities of water might bypass the hydros, increasing power production losses substantially. - 13 -