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r, <br />N <br />A <br />COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />leave no doubt that DOI sought a basin -wide solution from <br />the relicensing of these Projects.2�1 There are strong <br />similarities between the section 10(j) recommendations and <br />the Joint Study's proposed Habitat Program,'L" which <br />describes basin -wide recommendations to be achieved by a <br />cooperative effort involving three states, government <br />agencies, conservation organizations, and water power <br />interests. Yet a very substantial portion of the program <br />has been recommended by DOI to be undertaken by the <br />Districts alone. "/ <br />DOI has essentially put forward its entire "wish list" <br />for the region to see how much FERC Staff will force the <br />L61 See DOI, May 19, 1994 Comments; DOI, 1990 10(i) <br />Comments. Although for convenience in identification in <br />this filing Central sometimes alludes to these DOI filings <br />as 10(j) recommendations, in Central's view, they do not <br />meet the requirements to legitimately be styled 10(j) <br />recommendations. As they do not identify specific items <br />that should be put in Central's and NPPD's licenses, they <br />can be no more than comments. The May 1994 "revised" <br />recommendations further cannot be considered 10(j) <br />recommendations because under present circumstances such <br />comments are not subject to change under FERC regulations. <br />c <br />'l.= Central, Response to the Department of the Interior's <br />Revised Comments Under Section 10M of the Federal Power <br />Act May 19. 1994 (July 18, 1994) ( "Central, Response to <br />DOI's May 19, 1994 Commenta "). <br />221 The Joint Study's Habitat Program represents initial <br />cooperative efforts (by DOI, the States of Colorado, <br />Nebraska and Wyoming, water and power interests and <br />conservation organizations) to develop a plan permitting use <br />of Platte River resources by a variety of interests now and <br />in the future, while at the same time assuring that the <br />requirements of the Endangered Species Act will be fully <br />met. <br />ff Bp App. B, attached to this Volume (compare Orig. <br />10(j) and Habitat Program). <br />- 22 - <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />