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7C <br />w <br />w <br />COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />CEN -10 matter what existing benefits are already provided. A <br />(cont.) licensee will be penalized if it has been a good steward of <br />the resources entrusted to it: a bad steward will bear only <br />the new burden, but a good steward will also maintain <br />existing programs. The incentives created are <br />counterproductive, this approach produces a constantly <br />higher standard for future proceedings, and FERC Staff must <br />question whether this policy should be perpetuated. <br />Central firmly believes its generous stewardship of its <br />private lands is entitled to consideration in determining <br />what added burdens will be imposed in relicensing. Ignoring <br />existing programs results in a flawed balance of costs and <br />benefits and an overestimation of ability to pay. FERC <br />Staff has an obligation under sections 10(a) and 4(e) to <br />balance all of the costs and benefits of the Projects, not <br />just the incremental changes. Widening the scope of the <br />balancing should alter the Staff's assessment from <br />determining what the Districts can pay to determining what <br />is reasonable and fair for the Districts to pay. Section <br />10(j) and other recommendations which are inconsistent with <br />this balance as struck may and should be rejected.79' <br />L9' ,fig 16 U.S.C. § 803(j)(2); Washington Water Power <br />.Cq—, 65 FERC 1 62,210, 64,438 (Dec. 10, 1993) (rejecting a <br />10(j) recommendation as "inconsistent with the public <br />interest standard section 4(e) of the FPA and with the <br />comprehensive development standard of section 10(a) of the <br />FPA [because] . the minimal benefits . . . are not worth <br />the cost . . . "). <br />- 31 - <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />