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O� <br />COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />areas of the Big Bend. The Nebraska State Plan water is wet <br />water, not paper water, and will actually be available to <br />the species of concern. Providing this water to the Big <br />Bend reach would also result in substantial dollar costs to <br />the Districts because of the operational changes. Besides <br />providing the water itself, the Districts would -- by the <br />Staff's low estimateAl -- incur losses of $5.9 million over <br />a thirty -year license in lost power production, plus <br />$100,000 or more to pursue needed water rights, plus <br />administrative costs. These dollar costs alone are <br />comparable proportionally to the entire sum assessed in the <br />Front Range biological opinions as the Colorado cities' <br />share of providing water, but in this case they are <br />accompanied by wet water. For the Front Range cities, the <br />fee paid is the total contribution toward water; DOI must <br />then arrange for purchase and delivery of whatever water can <br />be obtained with the funds available. Under the Nebraska <br />State Plan, there would be a definite delivery of actual <br />water to the Big Bend reach; there would be no substitution <br />of dollars for water. <br />The RDEIS suggests that the Nebraska State Plan (with <br />some modifications) was adopted by the Staff as its <br />22' ate$ infra section III.B.; Vol. 2, Ch. III, IV. <br />W Central discusses in section III.B., infra, and in <br />some detail in Vol. 2, Ch. III, why many of the <br />modifications to the Nebraska State Plan suggested by FERC <br />Staff are ill- advised. <br />ME= <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />