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PI <br />w <br />J <br />COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />actually the case. Properly performed analyses confirm that <br />Central cannot provide sums approaching the amount needed to <br />provide its share of the Staff - proposed environmental <br />enhancements. <br />1. FERC Staff Underestimates the Costs of <br />its Proposed Programs <br />Because FERC Staff seeks to impose burdens on <br />these Projects up to the point of their ability to pay, it <br />is exceedingly important to fully recognize the costs of <br />future operations. These include ongoing operational, <br />maintenance and administrative costs, costs associated with <br />the relicensing process, added costs to be anticipated in <br />meeting the administrative requirements of a modern FERC <br />license, and costs associated with new and ongoing <br />environmental and recreational enhancement programs. They <br />also include full recognition of the losses in potential <br />revenue associated with reduced power production. <br />CEN -13 I a. FERC Staff would Require Continuing <br />Baseline Measures Without Taking Their <br />Cost into Account <br />The importance of the benefits and costs <br />associated with the baseline case to section 10(a) balancing <br />were discussed above. Both the magnitude of existing <br />benefits to wildlife and the magnitude of their costs to the <br />Districts are important components of the overall balance. <br />Continuing baseline costs are a significant part of the full <br />economic contribution toward wildlife of the proposed <br />- 35 - <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />CEN -13 The staff's economic analysis incorporates the costs of continuing Baseline <br />measures. <br />