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<br />00-0912 <br /> <br />likely would,' establish a precedent in FERC relicensing proceedings <br />for the Federal taxpayers paying for the new conditions imposed on <br />projects that are undergoing relicensing. <br /> <br />Rc l:U mmenu it ti on <br />Audubon cannot support this provisIOn and recommends that the <br />Management Alternatives Work Group delete 'this provision from the <br />Program. <br /> <br />3.0 INSTITUTIONAL ARRANGEMENTS <br /> <br />National Audubon has no specific comments or <br />recommendations regarding this section at this time. <br /> <br />4.0 PROGRAM COSTS <br /> <br />4.1 Annual Program Management Costs <br /> <br />There may be some justification for including a law <br />enforcement component in the Program once there is land to manage <br />and protect, but that justification is not provided and it is unlikely <br />that the Program would require such enforcement in the early years. <br /> <br />4.2 Participation Costs <br /> <br />The draft contemplates a $40,000 contribution from <br />"conservation organizations" in the form of in-kind services. While <br />Audubon and the Platte River Trust would certainly qualify for <br />participation, based on our current habitat management programs, <br />Audubon cannot commit to make an increased financial investment <br />in the Platte, just to support our involvement.in the Program <br /> <br />The voluntary participation of conservation groups in this <br />Program should not obligate or require them to "manage" habitat <br />acquired and developed as part of the plan unless they receive <br />corresponding benefits. This may not pose an immediate problem, <br />but it could certainly discourage additional public interest groups <br />from joining and contributing to the plan. <br /> <br />I'age 12 July 30, 1993 <br />NatiolHll Audubon Society. Comments on: <br />I)RM.JS-l\tIA \VG 's Draft II Platte River H..hitat COllservation Pro~ralll." <br />