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r , <br />Testimony of Donald D. Kraus <br />February 16, 2002 <br />experience to "adaptively manage" the Program as we intended. In addition, we naively <br />expected administrative costs of a Program to be minimal, with Program participants <br />donating needed support. Experience has shown we will need a small staff. While <br />efforts are always made to keep costs as low as possible, we need the tools for success <br />and they will cost more than we first thought. <br />Our biggest problem is where to get the money and water to carry out a Program. If and <br />when we agree on Program details, we anticipate coming to you with our hats in our <br />hands. Federal environmental law and policy are established on behalf of the entire <br />nation. Here, they are applied to migratory species that simply visit in our area, to our <br />great expense. Typically two to six whooping cranes visit in the spring for a few days. <br />Longer visits, and fall stopovers are more rare. The interior least tern and piping plover <br />arrive in June, nest, fledge their young, and are gone by mid - August. <br />If it is in the nation's interest to offer these birds special protections during their stays in <br />Nebraska, I would respectfully submit that the nation needs to help pay for those <br />protections. Nebraska has a limited population to tax and its ability to support a more <br />costly Program is limited. This is particularly true since the costs of a new depletions <br />program are also much more than anticipated. Opportunity costs of foregone <br />development could also be substantial and affect the tax base. It should also be <br />recognized that the states are contributing water to the Program with value that is not well <br />represented by the cost figures. The three major state water projects have an estimated <br />yield of 80 thousand acre -feet in reduction of flow shortages. The Cooperative <br />Agreement assigns these projects a negotiated "cost" of under $17 million over the first <br />thirteen years, but replacing that water could cost five times that amount. For these <br />reasons, I believe that the Federal Government should and will need to bear the majority <br />of costs of a Program. If not, the cost to federal policy is piecemeal litigation, risk <br />regarding outcome, lack of coordination through the basin, and delay. When we come to <br />you in Congress to ask for federal appropriations, and I urge you give us your support. <br />I would like to comment briefly on the proposed piping plover critical habitat <br />designation. Frankly, it plays into all of the fears of farmers up and down the Platte River <br />Valley about letting the federal government in the door through a Program. <br />The proposed designation for the Platte River is not well grounded in science or law. <br />Critical habitat designation is intended for areas with substantial current species use — not <br />areas where species use is rare or hoped for or expected in the future if management <br />changes are made. Areas that are already protected by other programs or plans do not <br />need to be designated. <br />These standards were applied to other rivers in the notice, but contrast sharply with the <br />proposal to designate the entire 200 -mile Platte River from Cozad to the mouth. Very <br />few piping plover nest in the central Platte River region. Those that do nest in the area <br />use managed, protected areas or sandpits near the river. Bird -use data from sandpits are <br />the only justification for including many reaches of the central Platte River, but the <br />sandpit areas themselves are excluded. On other rivers, the Fish and Wildlife Service <br />4 <br />