Laserfiche WebLink
X <br />L <br />.A <br />N <br />COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />regimes -- estimated for the Nebraska State Plan by the <br />Staff to be $1.5 -2 million in dry years over a thirty -year <br />license. <br />Overall, the cost of the Staff's preferred alternative, <br />exclusive of power losses, is $52 million plus unpriced <br />programs, rather than $37 million plus unpriced programs, as <br />estimated by the Staff. The unknown costs of unpriced <br />components, and the uncertainty in all the estimates, would <br />doubtless push the price far higher than $52 million. If <br />the Staff believes it appropriate to impose costs <br />approaching the limit of Central's ability to pay, it must <br />protect Central from unintended financial ruin. It is <br />simply not enough to require "strict cost accounting" and <br />annual reportingLY and to hold out the possibility of <br />reopening costly legal proceedings as a remedy to errors.nl <br />A cap on the costs of enhancement programs is essential. <br />2. FERC Staff Significantly Overestimates the <br />Economic Burden that Central Could Afford <br />In addition to underestimating the burden it <br />proposes to impose on the Districts, FERC Staff <br />substantially overestimates Central's ability to pay for <br />enhancement measures. As indicated throughout this <br />document, Central believes that the Districts should <br />Iv RDEIS at 5 -41. <br />N' Platte River Technical Workshop Project Nos 1417 <br />and 1835 Tr. at 144 -145, June 9, 1994 ( "1994 Technical <br />Conference "). <br />- 40 - <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />