Final Environmental Impact Statement Volume II Appendix K, Part 1

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N v COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND IRRIGATION DISTRICT includes parts of seventeen counties, only three of which are served by Central.'/ This region formerly maintained a number of wetlands now drained and plowed. This loss of non - riverine wetlands is completely unrelated to Project operation.f7/ Nonetheless, DOI recommended that the Projects purchase, restore and maintain 4,750 acres of wetlands in the Rainwater Basin,f6/ or 20* of the total Venture. In brief, DOI's recommendations for these Projects are totally out of line with the Projects' role in the Platte River basin. CEN -81 2. FERC Staff Should Resist Efforts to Use this Proceeding to Obtain Basin-Wide oals Faced with lengthy lists of expensive recommended programs and DOI's refusal to assign priorities or to indicate what portion of these programs the Projects should provide, FERC Staff has simply proposed that the Districts implement as many of the resource agencies' recommendations as FERC Staff believes they can afford.'—' In essence, the Staff acquiesced in the principle of assigning an entire basin's enhancement burden to two M/ R. A. Gersib €t Al., NGPC Rainwater Basin Joint Venture Implementation Plan 9 (1992) 17/ Indeed, Project No. 1417 has contributed to wetland recovery by raising and then stabilizing the water table, leading to abandonment of agriculture in some low lying areas. fv RDEIS at 4 -94. L9/ RDEIS at 5 -46. 25 - RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND IRRIGATION DISTRICT CEN-8 The potential relicensing of these projects offers an opportunity to establish an improved balance among developmental and nondevelopmental resource values. During the initial license terms, power generation revenues have helped defray irrigation costs. In looking ahead to the next license term, the staff believes it is appropriate to use some portion of power generation revenues to defray fish and wildlife habitat improvement costs.