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CEN -10 <br />w <br />COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />environmental contributions; it specifically speaks to- <br />efforts to "protect" and to "preserve" recreational and <br />environmental qualities as well as to enhancement. <br />Nevertheless, the Staff took an inconsistent approach to <br />balancing with respect to current operations. While <br />recognizing on the developmental side of the balance all the <br />existing benefits to irrigation, FERC Staff evaluated the <br />benefits of the Projects to the environment entirely in <br />terms of incremental improvements from baseline. <br />An incremental change assessment is appropriate and <br />consistent with the requirements of NEPA when used to <br />measure the relative impacts of alternatives. It is not <br />appropriate to use such methods to assign an absolute number <br />to the cost or value of an alternative for use in section <br />10(a) balancing. Looking only at incremental changes in <br />this context amounts to a determination that any value given <br />to the environment by the baseline is "free" or that it <br />offers no value to wildlife, recreation or other interests. <br />FERC Staff obviously believes that the Projects as <br />presently run (in other words, the baseline) have <br />considerable value to wildlife and recreation; the RDEIS <br />recommends the perpetuation of all programs in existence <br />now, including "interim" programs voluntarily initiated by <br />Central through amendments to its annual license.H' Yet <br />once the benefits of the programs were acknowledged, they <br />'v RDEIS at 2 -8. <br />- 29 - <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />CEN -10 The staff acknowledges the positive contributions made by the projects. <br />The focus in the EIS is on alternative ways to improve current conditions. <br />