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w <br />00 <br />COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />alternatives which include them. If, as the Staff suggests, <br />there is significance in the percentage of a project's <br />"value" that is expended for non - developmental purposes, <br />that percentage is appropriately calculated only when based <br />on the full contribution, not simply the incremental change. <br />Central's existing baseline environmental and <br />recreational programs are not free. As described in more <br />detail in Volume 2,91' many have continuing annual costs. <br />They include, for example: the public education activities <br />including eagle viewing programs at Johnson No. 2 Hydro and <br />Lake Ogallalla ($50,000 /year); lost power production at <br />Kingsley because of bypass flows through the Howell - Bunger <br />Valve for dissolved oxygen ($150,000 /year); and coordination <br />with NGPC and others on recreational and wildlife programs <br />on Project lands ($40,000 /year). Total direct costs to <br />Central for existing environmental recreational and public <br />education programs come to $442,000 per year, or <br />$9.1 million over a thirty -year license. <br />In addition, considerable value to fish and wildlife <br />continues to accrue from programs involving substantial past <br />investments by Central, such as Central's extensive <br />conservation program ($31 million since 1954 for <br />improvements, $178,000 in 1993 and 1994 to organize and <br />support the Central Nebraska Regional water Conservation <br />Task Force), and enhancement efforts at the Funk Lagoon <br />M1 Vol. 2, Ch. IV, and App. IV -C. <br />- 36 - <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />