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7C <br />COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />underestimating the cost of Rainwater Basin development by <br />$4,110,000. The total amount by which the Staff understated <br />the costs of new programs is $12.4 million in initial and <br />annual recurring costs.921 These figures represent only the <br />errors which Central can now identify. The Staff is also <br />asking Central to absorb the substantial risk that over the <br />thirty -year license term, the Staff's estimates -- or <br />Central's own -- will prove inaccurate. The potential <br />impacts of this risk are highly significant if the Staff <br />expects Central to accept license conditions estimated to <br />incur costs to the full extent of Central's ability to pay. <br />In addition to underestimating the full burden of items <br />it attempted to cost, the Staff has proposed that the <br />Districts engage in a number of other activities to which <br />the Staff failed to assign any cost at all. Some, such as <br />developing procedures to implement the Nebraska State Plan <br />and helping restock Lake McConaughy after low storage years, <br />appear to be mere omissions, and Central estimates their <br />costs to be $1,360,000.'a Others, such as the <br />implementation of the Conservation Program, are unknown -- <br />but not insubstantial. In accounting for the costs of <br />alternatives, the Staff must include in its total the very <br />real increased maintenance costs associated with new flow <br />§2 Initial costs plus annual recurring costs escalated <br />at S% and discounted at 8 %. <br />' —a Vol. 2, Ch. IV, App. IV -B. <br />- 39 - <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />