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00 <br />COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />enhancement programs for endangered species was $50 million. <br />In the biological opinions, the Front Range cities' <br />"equitable share" of $50 million was spread over the 20 year <br />life of the permits sought, and an annual fee was derived to <br />be paid into a DOI fund dedicated to the purchase and <br />development of land habitat. <br />Based on the 11V share of total depletions DOI suggests <br />for Projects Nos. 1417 and 1835, under the Front Range <br />formula the Districts' "equitable share" of a $50 million <br />dollar land -based enhancement program is $5.5 million. That <br />sum should include both initial and continuing costs, and <br />corresponds to slightly more than the acquisition and <br />development price of one 2000 acre habitat complex under <br />DOI's cost estimates. <br />The RDEIS' recommendations for land -based enhancements <br />for endangered species are far in excess of the Districts' <br />fair share under the Front Range formula. Many of the <br />measures proposed by FERC Staff dg correspond directly to <br />provisions in the basin -wide programs used by DOI to develop <br />the Front Range formula; there are simply too many measures <br />required of these two Projects. FERC Staff proposes the <br />construction of three habitat complexes between North Platte <br />and Chapman (two below J -2), and five tern and plover <br />islands. The Staff estimates that the measures cost $16 <br />- 16 - <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />