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COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />CEN -14 costs, which FERC set at zero for the baseline case.°§§' <br />(cont.) FERC Staff also set to zero in the baseline case the costs <br />of providing staffing and monitoring to comply with the <br />myriad provisions of a modern license which have not, to <br />date, been part of Central's license.0 The effects of <br />these omissions on the Staff's assessment of "ability to <br />pay" are obvious. <br />CEN -151 b. Costs of Enhancement Programs are <br />Underestimated by FERC Staff <br />Another factor in FERC Staff's <br />overestimation of the Districts' ability to pay for <br />Enhancement proposals is the Staff's underestimation of <br />their costs. In determining that the proposed environmental <br />enhancement license conditions would cost $37 million, plus <br />up to $2.3 million in unpriced requirements, FERC Staff has <br />omitted a number of costs and underestimated others. <br />In Volume 2,ff Central describes in some detail the <br />Staff's errors in estimating the costs of its <br />recommendations. They include, for example, underestimating <br />the cost of monitoring programs by $155,000 per year; and <br />W Central, Response to Information Reouest 4 of FER <br />(Sept. 20, 1993) ( "Central, Response to July 20. 1993 Item 4 <br />FERC Request "); RDEIS, App. G, Tables G -7 and G -8. <br />=" Compare RDEIS, App. G, Table G -7 with Central, <br />Response to July 20. 1993 Item 4 FERC Request, same chart <br />(columns entitled Regulatory Compliance and Environmental <br />Enhancement were omitted from RDEIS). <br />W Vol. 2, Ch. IV and App. IV -A. <br />- 38 - <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />CEN -15 Cost estimates for all environmental improvement measures have been <br />reviewed in light of RDEIS comments. Updated cost estimates can be <br />found in Appendix H. <br />