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.Q <br />o. <br />COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />Production Costs. The "without Projects" plan removes <br />118 MW of hydroelectric capacity producing 450 GWh /yr in <br />energy on average, though available energy varies <br />significantly. It responds to these losses with the <br />installation of two 160 MW peakers early (in 2003 and 2006 <br />instead of 2007 and 2010), with installation of a 182 MW <br />capacity coal plant early (in 2008 instead of 2012), and <br />with expansion of that coal plant by 118 MW to 300 MW.W <br />The result is that during the four year period from 2008 to <br />2012, up to 262 megawatts of capacity is added beyond the <br />118 MW replaced. <br />The vast majority of the difference in attributed <br />"economic value" between the two expansion plans occurs <br />during the four years from 2008 to 2012.b' This difference <br />corresponds directly to the early construction of a 300 MW <br />coal plant under the "no Projects" plan and the resultant <br />availability of substantial excess capacity.p' During that <br />four year period, the added fossil units replace not only <br />the 450 GWh previously provided by the hydro units, but also <br />1200 GWh from other generation, including substantial <br />W NPPD, Comments of Nebraska Public Power District on <br />the Scoping Document for the Revised Draft_ Environmental <br />Impact Statement and the Commission Staff Report on Scoping <br />Meetings, Attachment R, Table A -3 (Feb. 12, 1993) ("NPPD, <br />Comments on RDEIS Scoping'). <br />bI S= RDEIS, App. G, Tables G -4, G -5. <br />N/ NPPD, Comments on RDEIS Scoping at Attachment R, <br />Table A -3. <br />- 44 - <br />RESPONSES TO CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />