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COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND RESPO <br />IRRIGATION DISTRICT <br />be avoided by NPPD either if it did not contract to buy <br />power after 1995 or if the existing license were not <br />renewed."' Although NPPD's present obligations to meet <br />costs would be void, Central's multiple use facilities would <br />not cost substantially less to operate; there would simply <br />no longer be a revenue share from hydro to help meet those <br />costs. <br />This method of examining net economic value may in some <br />circumstances be useful for analyzing a pure electric <br />utility project, but it simply does not work for a multiple <br />use facility marketing wholesale power. If the goal is to <br />assess Central's ability to raise funds and pay for <br />environmental enhancements, alternative methods must be used <br />to determine net economic value.L" <br />ii. FERC Staff Erred in its Assessment <br />of the Value of the Projects from <br />NPPD's Point of View <br />Even if FERC Staff believes it is <br />relevant to examine the value of Project No. 1417 from an <br />electric utility grid perspective, there are several errors <br />in FERC Staff's assessment that must be corrected. <br />7/ Although, as discussed below, negotiations regarding <br />power sales to NPPD are ongoing, no agreement exists to sell <br />power produced at the canal hydros to NPPD after 1995. <br />Z21 Howard J. Axelrod, Analysis of Economic Analysis <br />Performed by FERC Staff 3 (July 1994) ( "Axelrod, Economic <br />Analysis "), attached as Vol. 2, Ch. I, App. I -A. <br />- 43 - <br />