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Interior's website that was and is inaccessible. Clearly, this was meant to restrict <br />public participation. Perhaps more importantly, the 30 -day comment period <br />required by the Service is in clear violation of the 60 -day review requirement of <br />the Act. Even with a court order setting their schedule, the Service cannot use its <br />own negligence as an excuse for not complying with the law. <br />Notwithstanding the unacceptable procedural elements, the economic report <br />provided by the Service was, in my opinion, completely inadequate. The <br />argument that there is little or no additional economic impact as a result of habitat <br />designation beyond the species listing does not ring true nor does it comply with <br />the recent decision of the 10`" Circuit Court regarding economic analyses. In my <br />own district, the Central Nebraska Public Power and Irrigation District's FERC re- <br />licensing shows what effects can result from such a listing. This 14 -year re- <br />licensing was long and contentious, not so much because of the existence of <br />endangered species, but because of the critical habitat designation of the central <br />Platte River for the whooping crane. I want to emphasize that it was the habitat <br />NOT the species, which caused most of the problem in that relicensing. <br />Additionally, the economic analyses provided by the Service did not consider the <br />costs incurred by individuals and businesses either directly or as lost opportunities. <br />No analysis was made of impacts to sand and gravel mining, housing <br />developments, recreation, municipal water supplies, agriculture, and I could go on. <br />Clearly this report is inadequate to depict the true costs of this proposed <br />legislation. <br />