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COMMENTS OF CENTRAL NEBRASKA PUBLIC POWER AND <br />IRRIGATION DISTRICT <br />value of Project No. 1417 based upon the type of expansion <br />plan analysis FERC Staff conducted should have been <br />calculated to be negative $40.35 million. <br />CEN -201 iii. A "Net value" of zero or Lower is <br />erected Using Staff's Analytical <br />Techniaue <br />FERC Staff should have expected a <br />result near zero using the methodology it selected. <br />Typically, a utility considers replacing an aging, probably <br />inefficient, but fully depreciated unit with a more <br />efficient modern unit with higher capital costs. From a <br />system planner's point of view, the existing plant has <br />positive economic value if the fully allocated cost of <br />.replacing it is higher than the fully allocated costs of <br />�O <br />continued operation. The information provided by NPPD <br />clearly showed that the situation is entirely different <br />here: the production costs for the new coal fired <br />generation22' are substantially less than the average costs <br />of existing hydropower production.W So purely from an <br />electric utility planner's perspective, giving no <br />W NPPD, Comments on RDEIS Scooina at Attachment K, <br />Table A -5. <br />'—it RDEIS at 2 -46, 5 -40. FERC Staff itself acknowledges <br />that power production costs at these units are very high <br />compared with power from other sources used by NPPD, even <br />before the costs of environmental enhancement are included. <br />RDEIS at 2 -46. <br />- 47 - <br />