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COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />million,2V well in excess of the $5.5 million figure <br />calculated using DOI's formula from the Front Range cities' <br />biological opinions. <br />Yet FERC Staff has recommended that the Districts make <br />even further land -based habitat enhancements for endangered <br />species. While not identified directly in the basin -wide <br />programs DOI has cited in the Front Range opinions, some of <br />FERC Staff's recommendations call for monitoring conditions <br />with basin -wide import for endangered species. Examples are <br />the requirements for studying vegetative encroachment as <br />well as monitoring the use and efficacy of required <br />enhancement programs. FERC Staff has estimated the costs of <br />xthese programs at $6.9 million over the next thirty <br />�O <br />years .3 -0� Additional Staff recommendations are intended to <br />L91 FERC Staff estimates that costs would be $6.52 <br />million initially plus $84,000 /year for the Districts to <br />purchase, develop and maintain two habitat complexes on the <br />Platte River between J -2 and Chapman. A third habitat <br />complex between J -2 and North Platte is estimated to cost <br />$3.1 million plus $38,000 /year. In addition, the Staff <br />estimates that developing and maintaining five additional <br />tern and plover islands would cost the Districts $875,000 <br />initially plus $140,000 /year thereafter. RDEIS at E -16, <br />Table 8. With 5% escalation and 8% discounting of annual <br />recurring costs, over a thirty -year license these measures <br />are estimated to cost $12 million for enhancements below J -2 <br />alone, and $16 million in all. <br />30/ These figures include $490,000 initially, then <br />$30,000 /year for channel morphology studies and $140,000 <br />initially and $275,000 /year for monitoring programs. <br />Escalating annual costs at 5%, then discounting at 8t, the <br />Staff - estimated total of initial and annual costs is $6.9 <br />million. The vast majority of the programs included in FERC <br />Staff's monitoring program are directed not at monitoring <br />compliance with any license conditions but with monitoring <br />(continued...) <br />- 17 - <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />