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COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />contribute no more than their fair share in light of <br />competing interests, the Districts' role in the region, and <br />the many benefits the Projects provide. In this case, the <br />enhancement measures suggested by FERC Staff not only exceed <br />the Districts' fair share; these measures would financially <br />cripple Central. <br />Central engaged Dr. Howard J. Axelrod, P.E., a noted <br />utility economist,R' to independently review FERC Staff's <br />economic evaluations. His report shows that the Staff has <br />applied a flawed economic analysis which creates the <br />impression that there is a "pot of gold" to be found here. <br />That impression is false. Central is a small local unit of <br />government providing big irrigation, wildlife and <br />W recreational benefits on a shoestring budget. Properly <br />performed economic analyses' —`1 confirm that Central cannot <br />provide sums approaching 808 of $39 million for further <br />environmental enhancements. <br />CEN -16 I a. FERC Staff's Determination of "Net <br />Economic Value" is Flawed <br />FERC Staff apparently views net economic <br />value as one measure of the Projects' ability to pay, <br />assuming that any "value" it identifies can be converted to <br />73/ Dr. Axelrod is Vice President at R. J. Rudden <br />Associates, Albany, New York. His resume is attached as <br />Vol. 2, App. I -B. <br />'—'/ Central notes that NPPD preliminarily indicated it <br />may not be in complete accord with all aspects of Central's <br />evaluation of the use of planning models. <br />- 41 - <br />