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x CEN -14 <br />w <br />�o <br />COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />($80,000). Further, 6000 acres of land owned by Central and <br />located outside the normal buffer of Project lands are <br />dedicated to wildlife and recreation. Without taking into <br />account improvements or access to the lakes, that is worth <br />at least $2.4 million. <br />The continuing dedication of thousands of acres of <br />Project lands to public use represent substantial lost <br />opportunity costs. Besides the value of the land, Central <br />gives up the opportunity to lease portions of the land for <br />recreation, hunting or agriculture ($145,000 /year), and to <br />obtain fees or other revenues in return for offering <br />$5.1 million each year in recreational value to visitors." <br />Recognition of the commitments made and existing value <br />based on actions to date is essential to performing FPA <br />section 10(a) balancing. The omission of baseline costs <br />affects not only the public interest balance, but also FERC <br />Staff's assessment of Central's ability to pay for <br />additional programs. Many costs of existing environmental <br />programs, such as the "interim" tern and plover protective <br />program, were not included in the normal operation and <br />maintenance cost figures supplied by Central and upon which <br />FERC Staff based its Appendix G calculations; Central had <br />included most of these costs as post - relicensing enhancement <br />651 Vol. 2, Ch. VI, and App. IV -C. <br />- 37 - <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />CEN -14 See response to C EN- 13. <br />