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r <br />w <br />N <br />COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />CEN -10 were not discussed further as part of comparing alternatives <br />(coat.) or reaching conclusions. <br />The failure to assign costs or value to the baseline <br />case is very disturbing because of what it says about FERC <br />Staff's approach to balancing: continuing commitments have <br />no role to play in the public interest balance. Despite <br />many acknowledged benefits to recreation and the <br />environment, the baseline is weighed as if it maximized the <br />developmental interests the Projects were originally built <br />to serve. <br />By including only new environmental and recreation <br />programs and their associated costs and impacts on other <br />interests, the Staff struck a flawed balance. This flaw <br />drives the Staff to its policy of requiring any enhancement <br />asked for up to the ability of the Districts to pay. <br />Implications extend far beyond the relicensing of Project <br />Nos. 1417 and 1835; if representing FERC policy, the Staff <br />will assume that any existing operating regime represents <br />only the developmental interests it was officially built to <br />serve. No matter how much one project may contribute to <br />recreational and wildlife interests, none of its <br />contributions will be recognized when competing interests <br />are balanced. The licensee will, however, be expected to <br />continue to make these contributions. <br />Since only the costs and benefits of new programs will <br />be recognized, the same new programs will be proposed no <br />- 30 - <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />