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<br />000960 <br /> <br />Page 4--7/3'0/93 <br />John Lawson, Chairman <br />Management Alternatives <br />NAS Comments on Draft <br /> <br />Work Group-PRMJS <br />"Platte River habitat Consen:ation Prog." <br /> <br />understanding of the draft indicates that the U. S. Pishand Wildlife <br />Service would be required to pay for implementing any land based <br />measures included in the reasonabie ami pruut:lll ullt:lI)uli ve. <br />Audubon believes that would be an improper provision, and that the <br />Bureau, as the responsible managing agency, should have to bear <br />those costs. <br /> <br />S. Section 7 Consultations (Section 2.5.3) <br />Nebraska Public Power District/Central Public Power and <br />Irrigation District Consultation <br /> <br />Again, the draft document states that "The Program will assume <br />responsibility for implementing any land management <br />responsibilities required by PERC (Federal Energy Regulatory <br />Commission) to comply with the Endangered Species Act, including <br />acquisition, cleadng, monitoring, management, and maintenance." in <br />the Kingsley relicensing. Audubon has several concerns regarding <br />this proposal. This provision would establish a precedent in FERC <br />relicensing proceedings for the Federal taxpayers paying for the new <br />conditions imposed on projects that are undergoing relicensing. The <br />taxpayers have no responsibility to correct the problems caused by <br />these projects, and funding should not be provided through either <br />the Bureau or the Service budgets.. Including Kingsley in this <br />Program complicates the FERC proceeding and would delay resolution <br />of the license conditions. Audubon recommends that this provision <br />be deleted from the Program. <br /> <br />If there are questions, additional details or clarifications are <br />needed please let me know. <br /> <br />-- <br /> <br />Best reg~ <br />//=~/~/ ~ <br />~1. 'U~"i- <br /> <br />Edwar Pembleton <br />Direc~or of Water Resources Program <br /> <br />c. Audubon Platte River Task Force <br />