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x <br />w <br />O� <br />COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />opportunity to do so exists. FERC Staff is not required by <br />the FPA to acquiesce in this effort, and in fact is barred <br />from doing so as a matter of law and equity. <br />B. FERC Staff's Errors in Economic Analysis Would Put <br />an Unreasonable Financial Burden on the Districts <br />As discussed in section II above, FERC Staff has <br />recommended that the Districts shoulder an excessively <br />burdensome share of land -based endangered species <br />enhancement programs for the Big Bend reach. These programs <br />comprise only a portion of the many non -water requirements <br />FERC Staff proposes for the Districts. There are also <br />costly programs to enhance non - endangered species, <br />recreation and sport fisheries, cultural resources and a <br />substantial conservation program. As stated repeatedly <br />already, the Staff proposals appear to have been limited <br />only by the Staff's estimate of what the Districts can <br />afford. The discussion in section III.A. above articulates <br />in some detail the impropriety of that position as the sole <br />measure of what the Districts should pay. <br />Determining the ability to pay, however, remains <br />important. FERC Staff must be aware in performing its <br />resource balance when there is a risk of unintended <br />significant losses to existing benefits from the Projects. <br />Unfortunately, the Staff's flawed cost estimates and <br />economic analyses create the false impression that Central <br />can afford a great many more enhancement programs than is <br />- 34 - <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />