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COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />Districts to finance. DOI's instream flow recommendations <br />correspond to 100% of its proposed flows for the basin.39' <br />Although DOI did acknowledge that these flows might not be <br />achievable all of the time,' —L' no guidance was offered as to <br />what lesser amounts might be acceptable for the Districts to <br />provide as their share. In addition, land enhancement <br />programs DOI recommends comprise a major portion of the <br />Joint Study's Habitat Program, far in excess of the 10 -20% <br />figures even DOI uses to characterize the Projects' share of <br />impacts on the basin. For example,'' —" the Joint Study's <br />Habitat Program recommends that an additional 19,000 to <br />20,000 acres of land be purchased to complete nine habitat <br />�j complexes along the Platte River between Lexington and <br />to <br />Chapman.R' DOI in its section 10(j) recommendations <br />L91 5= App. B, attached to this Volume (compare 1994 <br />10(j) and March 1994 basin -wide recommendations). <br />iw 5=, e.g., DOI, May 19, 1994 Comments at 3 (stating <br />that the Department does not expect the licensees will be <br />able to meet the flow targets 100 percent of the time). <br />L" For a complete comparison of DOI's recommendations <br />for the basin with those for the Projects, see the Tables <br />attached at App. B, attached to this Volume. <br />2i PRMJS, Habitat Conservation Program at 7. The <br />Habitat Program calls for a habitat complex "between each <br />bridge" consisting of open river channels and wetland meadow <br />between 9 pairs of bridge crossings on a total of about <br />28,000- 30,000 acres, but acknowledges existing contribution <br />of about 10,000 acres through the reach, leaving 19,000 <br />acres for the Habitat Program to address. While early <br />drafts of the Habitat Program suggest this acreage must be <br />between Lexington and Chapman, recent biological opinions <br />for other Platte River Basin projects have suggested that <br />this habitat may be located anywhere below North Platte. <br />5ee, e.g., DOI, Front Range Opinion at 30. <br />- 23 - <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />