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<br />; <br />, <br />~I <br /> <br />based on a least-cost solution. This is an "apples and <br />oranges" comparison in which power impacts are significantly <br />understated. Economic values should be put on comparabl'e <br />terms in the DEIS. <br /> <br />" <br /> <br />, <br /> <br />* A major deficiency in the DEIS is the failure to include <br />the anticipated cumulative economic and environmental impacts <br />from construction of replacement power capacity using <br />nonrenewable resources. Such an impact analysis is necessary <br />to a sound decision-making process. <br /> <br />Non-use value economics is being tested for possible inclusion in <br />the final EIS. Inclusion of non-use values without appropriate <br />review and comment is a major concern since "...including non-use <br />value potentially could alter the outcome of the economic <br />evaluation of the alternatives." (pg. 165) Considerable <br />uncertainty remains with regard to the validity and reliability of <br />techniques used to estimate non-use values, which affects the <br />credibility of the results. <br /> <br />* How is bias avoided in collecting value information? <br /> <br />" <br />.... <br />;..... <br />'. <br />..... <br />'> <br />" <br /> <br />I..l~ <br /> <br />* For which resources are non-use values being computed? <br /> <br />" <br /> <br />* What is the basis for excluding non-use values for power <br />users? <br /> <br />,.,. <br /> <br />* How does the non-use of power differ from other non-users <br />of the local resources? <br /> <br />::"1 <br /> <br />.~; <br /> <br />* What is the basis for the market (geographic) size for the <br />analysis? <br /> <br />, <br /> <br />....~ <br /> <br />* What resource impacts in the non-use value economic <br />evaluation are reversible and non-reversible? <br /> <br />~ <br />.j; <br />..... <br /> <br />" <br /> <br />* How are reversible impacts used so as to prevent skewing of <br />results? <br /> <br />~.;,. <br /> <br />~, <br />R <br />'j <br /> <br />* What non-reversible impacts are considered? <br /> <br />* What is being done to assess the non-use value of fossil <br />fuels which would be used for replacement power? <br /> <br />According to the contractor conducting the non-use study (HBRS): <br />"Sound environmental economic analysis must be based on a sound <br />scientific understanding of the underlying physical and biological <br />effects of dam operations." Since Adaptive Management has been <br />proposed in recognition of the need to continue learning and making <br />adjustments, today we remain uncertain as to the effects of dam <br />operation alternatives on the environment. Therefore, "neutral <br />depictions of the physical and biological impacts of the proposed <br /> <br />8 <br />