Final Environmental Impact Statement Volume II Appendix K, Part 1

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CEN -5 7C COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND IRRIGATION DISTRICT preferred alternative because the Staff felt that the Districts could provide no more water without jeopardizing drought protection for existing irrigation interests and recreational use of Project facilities.n' Not only does the Nebraska State Plan represent as much as the Districts can offer, the discussion above shows that it represents a willingness to contribute far more than they should have to offer. 2. A_$5.5 Million Contribution for Land -Based Environmental Enhancements is the Districts' Fair Share for Endangered Species The Front Range cities were also required to contribute an "equitable share" of land -based environmental enhancements. DOI's assessment of the basin -wide need for land -based enhancements was based on an estimate by the Joint Management Study (Joint Study). The Joint Study proposed an additional 19,000 acres plus buffers (rounded to 20,000 acres) between Lexington and Chapman to be purchased and developed as habitat complexes and tern and plover islands.2°' DOI indicated that $2,500 /acre would be needed to purchase, develop and maintain these habitat areas, so its total estimate of the costs of needed land -based habitat m RDEIS at 5 -19 to 5 -21. 28' PRMJS, Habitat Conservation Program, see supra n.6, at 6. S.ee also infra section III.B. and the table in App. B, attached to this Volume, comparing details of the Joint Study Habitat Program with DOI recommendations for these Projects and with FERC Staff's recommended license requirements. - 15 - RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND IRRIGATION DISTRICT CEN -5 It is the Commission's policy to defer to the expertise of the responsible fish and wildlife agencies regarding the biological basis for their 100) recommendations. The Commission includes 100) recommendations as conditions of any license issued, unless the Commission determines that a fish and wildlife recommendation is inconsistent with the Federal Power Act or other applicable law. The basis for inconsistency, if any, may result from the Commission's determination that implementation of the recommendation would not result in a properly balanced outcome, after equally considering developmental and nondevelopmental purposes. The latter is required under the Federal Power Act. The staff is recommending the Reasonable and Prudent Alternative (RPA) be included as part of the basin -wide Cooperative Agreement signed in 1997 by Central and other parties including Interior and NGPC. The staff believes the RPA combined with other measures comprising the Agreement will provide appropriate mitigation and enhancement of resources associated with Project 1417.