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authorization of the project before the complete Statement is provided, and the complete costs and benefits of the project have been tabulated.

2. Final NEPA Statement Incomplete

The draft Environmental Impact Statement provided to the Quality Environment Council and other agencies was provided to the Council on Environmental Quality (CEQ) on March 25, 1971, but was not sent to the Quality Environment Council until February 14, 1972. A statement from QEC has been requested in the office of the Bureau of Reclamation by March 15, 1972.

Much of the environmental information required to properly evaluate the North Loup Division Project is not available, and thus we reserve the right to further evaluation of the cost-benefit ratio until such time as the BOR makes available the necessary information. As an example, the unique plants and animals to be displaced by the reservoir have not been enumerated. Thus, a completely accurate cost cannot be assigned until such values are given.

3. Loss of Family Ranch Operations

Thirteen family ranch operations and 47 citizens will be disrupted by the Calamus Reservoir. In addition, there are five sets of buildings and windbreaks unoccupied. The homes, machine sheds, livestock barns and other buildings associated with these ranch operations will be destroyed. There is no way for these individuals to replace what they currently have on the ranches which include a total of 50,172 acres.

These ranches currently have 2,022 beef cows, 2,163 yearlings and about 100 horses, for a total of 4,285 head on the 50,172 acres. This demonstrates a value of just under 12 acres for each animal.

If they are forced up onto the Sandhills, there will be lost:

a. ranch buildings

b. windbreaks

c. ice-free water sources

d. hay meadows and alfalfa for growing winter feed for the livestock

e. the home that many of these people or their children have known for all of their lives.

f. lower value of their remaining property if they sell to adjacent ranches The economic impact of the project should include a dollar value loss in terms of these special categories.

Windbreaks-$75,000 per ranch-18 ranches, $1,350,000; Ice-free water sources-$10/head/year-about 5,300 head; for 100 years, $5,300,000; 2,000 acres of hay meadow or alfalfa. An added value of $200-$250 per acre, directly. However, the loss of these hay meadows is far more important than this. It means that instead of a rancher being able to have 12-15 acres per cow, he will need 20-23 acres. This means that if there are 50,000 acres of ranch land, instead of being able to run 4,167 cattle (at 12 acres per head) the rancher would only be able to run 2,500 cattle (at 20 acres per head). This represents a loss of approximately 1,650 calves each year or about $297,000 per year, even if the ranchers remain in operation (figured for 1,650 calves at 400 lbs. each and $45.00/hundred lbs.). Even at todays prices that is a loss of at least $297,000 × 100 years, or $29,700,000. (Some of these ranches have yearlings rather than cow-calf operations. The figures presented are still indicative of the losses involved.) The sociological and psychological effect of moving from a home and viewing the destruction of that home and property-13 homes with 47 people at $200,000/home, $2,600,000; the lower property value of the acres remaining after buildings and hay producing acres are gone, $20/acre and 50,000 acres. $1,000,000; total additional losses-not represented in the current cost-benefit ratios in the inundated ranches. These losses are to the property owners, $39,950,000.

4. Loss of Schoolhouse

A small schoolhouse will be covered with water. We assume that the BOR intends to replace this school. However, the children attending this school from the ranches nearby will have to travel further to reach school or will need to be transported to Burwell or another town. These costs will be in addition to construction and will be costs supported by the ranchers for each year.

5. Effects on the Human Population

The Environmental Impact Statement developed by the Bureau of Reclamation, states there has been a reduction of population in the area from 36,300 in

1940 to 24,500 in 1970. We would state very emphatically that this is not what the BOR refers to as "underemployment of the civilian labor force." The BOR has not defined the area from which they are taking their population figures.

The basic reason why population in this region has declined somewhat, is because of an increasing ability through technological advances for fewer people to farm or ranch more acres. Transportation is faster and agricultural machinery is more efficient in 1972 than in 1940. Thus, a family can farm 300600 acres today, whereas, in 1940 few farmers utilized more than 200 acres.

By simply providing another source of water, the population is not going to increase. As we will discuss more thoroughly later in this document, perhaps as many as one-third of the farmers in the reclamation district have already provided their own source of water through central-pivot irrigation. The benefits to the economy will be for those who make pipe for irrigation. However, industries are already manufacturing central-pivot irrigation systems. Others to benefit will be the large farm equipment manufacturers with their base of operations outside of Nebraska. Instead of drawing human population back to this region of Nebraska, it will be more likely to draw some of the young people to the industries outside of Nebraska.

6. Effects of the North Loup Division Threat on Current Development

The ranchers to be directly removed from their base operations and homes would have made further improvements and invested more in their operations had they not been faced with the possibility of losing their ranches. No one can measure the entire true cost of the hardship this has placed on the residents of the areas proposed for inundation. It is time to realize what such projects do to people and to remove this threat permanently.

7. The Current Irrigation in North Loup Division

The Mira Valley and Scotia areas of the Reclamation District are areas that have the greatest amounts of land currently under irrigation by central-pivot systems. Many new central-pivot irrigation systems are planned for this area in the next two years. These are preferred by the majority of farmers as they do not require the expense of leveling land or the hardships of working around irrigation canals and laterals with modern farm equipment.

8. Farmers Opposed to Project

In the Mira Valley and Scotia regions of the Reclamation district, the farmers are being censused as to whether they want the project. As of February 27, 1972, 12 of each 13 farmers contacted were against the North Loup Project. This 12:1 ratio of farmers opposing the project represented a ratio of 32 quarter-sections versus one quarter section of land. This census is being continued and the results will be presented to the Senate and House Subcommittees. 9. Farmers Opposition Based on Good Management

One major reason the farmers oppose the project is that they already have a more efficient means of providing their water for irrigation through the use of central-pivot systems. They realize through reports from the studies made on ground water supplies, that the majority of lands within the confines of the North Loup project have abundant ground water to supply their needs if they use it wisely.

10. Farmers Land Disrupted

Many farmers oppose the North Loup project because they have invested in their own irrigation system. Some of these individuals will have their lands disrupted by the canals and laterals planned for the project. Many acreages will be essentially worthless after the project. For an example, an irrigation canal is planned that will run diagonally across a rectangular-shaped 56 acre field. This will make twice as many rows to cultivate. There will be many acres lost to turn-around space. More time, effort and fuels will be needed to farm these types of fields.

11. Continue a Free Enterprise-Do Not Suppress Corn Prices

Most farmers in the regions to be effected by the North Loup project, wish to develop their own free enterprise system of raising crops and feeding cattle. They see no justification in spending millions of dollars of government funds to provide water for the few remaining acres that are not already under irrigation. We support the farmers who are providing their own systems and managing

their own farms. If through raising a surplus of corn, they cause corn prices to drop, they will be living within a situation they have created and they will have the opportunity to change farming practices and to adjust management priorities. However, it is very objectionable to provide the opportunities for glutting a market through government subsidization. As an example, through Bureau of Reclamation projects, there may already be at least 500,000 acres more in corn acreage because of irrigation or stream channelization projects. If on these acres, there were produced an average of 100 bushels per acre, there would be perhaps an additional 50 million bushels of corn produced by agriculture. If this dropped the total value of some 4 billion bushels of corn by only $.05 per bushel, there would be a distinct loss of dollars to agriculture. The difference could be: 4,000,000,000 bushels at $1.05, $4,200,000,000; 4,050,000,000 bushels at $1.00, $4,050,000.000; a loss of $150,000,000.

This 150 million dollar difference is a loss not just to the farmers of Nebraska, but to the entire nation. As pork barrel projects proliferate, the farmers will be the citizens in the U.S. to suffer first. The Bureau of Reclamation is one of the greatest offenders in promoting these types of projects that appear at first glance to be profitable, at least to a few farmers. However, National objectives to raise the income and living standards of rural America will only be hindered by such projects as the North Loup Division.

Therefore, as an economic cost to each project there should be added the cost to the entire nation's agricultural economy as a result of using federal funds to glut the corn market. We assume there are not more than 25,000 acres of land in the North Loup Division that remain to be irrigated or indeed are irrigable acres. If these 25,000 acres were to produce an additional 100 bushels per acre, there would be 2,500,000 additional bushels. If these bushels helped to drop the corn price by only $.05 per bushel, this would be a loss of $125,000 per year assessed back against these landowners. On an additional 25,000 acres remaining in the North Loup Division there would be another $125,000 per year loss; a total loss just in the North Loup Division of $250,000 per year. This is assuming only a $.05 drop in corn. In the fall of 1971, there were farmers selling corn for $.80 to $.85 per bushel rather than the minimum of a $1.00 to $1.10 they would have been getting, had the market not been so overloaded.

In summary on this point, there should be added a cost of at least $1,000,000 per year for the effect on the Nebraska market and at least $1.000.000 per year as an effect on the National market; total cost-$2,000,000 per year.

12. Increased Economic Activity Not Substantiated

The Environmental Impact Statement provided by the Bureau of Reclamation claims: "Stabilized and increased agricultural production from the irrigation of 52,600 acres of cropland would provide the impetus for important social and economic opportunities. A study developed by the University of Nebraska indicates $6.68 of economic activity occurs within the state of Nebraska for each dollar of increased value attributable to irrigated crop production . . . an annual impact of $36 million to Nebraska business."

These values of $6.68 do not take into account the points raised thus far, nor do they consider the losses in terms of environmental degradation of water and air or some of the sociological impacts of the dollar exchange they report in their study. Until these values can be updated, using all criteria, they should be disallowed in the cost-benefit evaluation of the North Loup Division. One good example of the bad side effects not considered by the University of Nebraska is the over-production of corn, resulting in a reduction in price as shown under item 9.

13. Recreational Benefits Claimed, Not Substantiated

Recreational benefits are claimed to be increased by 50,000 visitor days of public outdoor recreation annually. These figures are at least double what the actual figure would be. If the reservoir were within 30-40 miles of Omaha or Lincoln, the figures would probably be justified. However, one needs only to visit Sherman Reservoir, Pibel Lake, Milburn Dam, Merritt Reservoir or Box Butte Reservoir to understand the lack of visitors to reservoirs or lakes that are located in excess of one hundred miles from major population centers or away from routes of transportation. Unless guarantees can be made about no withdrawals of water from the reservoirs during the summer months, the value of the recreational grounds cannot be defended. As water is withdrawn, it makes boating, swimming and other recreational activities more difficult and

leaves small pools of water in which occur algal blooms or mosquito breeding ponds.

On the other hand, if water is not withdrawn from the reservoirs, the flow of water downstream in the Calamus, North Loup, Loup and Platte Rivers will be reduced, thus effecting environmental quality and economic stability of agriculture dependent on subirrigated hay meadows.

14. Hunting and Fishing Benefits Reduced

Public hunting and fishing benefits are claimed at an additional 19,070 days annually. These figures are entirely false for the following reasons:

A. Waterfowl hunting is currently better than it will be after the reservoirs are constructed. Waterfowl prefer smaller, more protected water as resting or feeding stops. The Calamus provides open water all year long. There are several small spring-fed ponds occurring near the edge of the Calamus. Furthermore, Gracie Creek provides additional open water near the Calamus. On February 22, 1972, even though most waterfowl were migrating, there were Canada Geese, Mallards, Lesser Scaup and Buffleheads in the River and ponds adjacent to it. This section of the River, the ponds and a portion of Gracie Creek would be inundated by the Reservoir.

B. Mule Deer prefer mixed habitat consisting of grazing lands and shelter in small clumps of scattered trees. This type of habitat exists now in the valley to be inundated. However, it does not exist in nearly as favorable a circumstance in the Sandhills, nor will it exist if the North Loup Project is authorized. There will be reduced numbers of deer available for hunting because of the inundation of thousands of acres of habitat. There will be a loss of at least 8,300 acres of land surface if the reservoirs and canals are completed. There is at least one deer occupying every 50 acres in this type of habitat. There will be a loss of 166 deer per year by simply removing their excellent habitat. The economic loss annually will be approximately 166 times $500 per deer or $83,000 lost annually.

C. In addition to the deer displaced by water, there will be approximately 100 additional deer that will die in the 274 miles of irrigation canals and laterals. This represents an additional loss of $50,000 annually to the State of Nebraska.

D. Other game birds such as pheasants and grouse or mammals such as rabbits and squirrels prefer mixed habitat such as that existing now. By inundating the valleys, there will be a loss of hundreds of pheasants, squirrels and rabbits and many grouse. Their value would represent at least $1.00 per acre for 8,300 acres for a further loss of $8,300 annually to the State of Nebraska.

It is obvious that the Bureau of Reclamation or their consultants do not understand wildlife economics. Their claim of hunting benefits are not only wrong, but quite the opposite is true. There will be overall loss of hunting benefits and an economic and recreational loss to the citizens of Nebraska.

E. Good stream fishing will be destroyed in the Calamus and in Gracie Creek by direct inundation. Through release of reservoir water for irrigation in the summer months and then refilling through the winter and spring months, fish numbers and fish reproduction will be effected. These difficulties have already been encountered in many large reservoirs.

In addition to the direct effects of the impoundment, as there is withdrawal from the rivers to refill reservoirs and as there is high loss of water through evaporation from the surface of the reservoirs and from the irrigation canals and ditches, the Calamus, North Loup, Loup, Platte and Missouri Rivers will be effected. River temperatures and flow rates are very important to maintenance of fish life throughout the entire year.

The Bureau of Reclamation has not sufficiently discussed the effects of drawdown of the reservoir, nor have they decided what amounts of water releases they will guarantee below the reservoir. Until such time as these questions are sufficiently answered, there should be absolutely no dollar value allowed for increased fishing benefits as a result of the North Loup Division. 15. Natural and Human Resources Currently Used Wisely

An "inefficient use of natural and human resources" is claimed by the BOR if the water and related land resources are left in their present state. These sound like the same arguments used by the proponents of the Aswan Dam on the Nile River. The Aswan Dam held back nutrients and essential minerals that had been flowing to the Mediterranean Sea. As a result, the Sardines perished because nutrients were not available to provide food for the small plants and animals which the Sardines fed upon.

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An annual multi-million dollar Sardine fishery was lost and thousands of people are without work.

We have already pointed out many of the faults of the North Loup Project and will show additional severe costs. However, there may be many costs to the people of Nebraska and to our nation that are not readily obvious.

16. Tax Base Losses to Counties

Tax Base losses will occur primarily to Loup and Valley Counties with a smaller loss to Greeley County. This land, property and building tax loss will add a greater burden to those persons owning acreages outside of the project

area.

For Loup County there will be a loss of assessed valuation as follows: Buildings, $40,765; land, $418,883; personal property, $294,765; total $754,413. At an assessment of about $70 per thousand, Loup Co. will lose about $52,000 in taxes per year that other landowners will need to make up.

For Valley County, there will be a loss of at least $171,785 of assessed land value. At an assessment of about $70 per thousand there would be a loss of at least $12,040 per year in taxes to be made up by the remainder of the county residents; total loss of taxes-$70,840 per year (minimum).

17. Long Term Land Values Not Considered

Land values are currently running between $55-$200 per acre in the areas to be inundated by the reservoirs. Areas to be affected by many of the irrigation canals and laterals will be more costly, as they are in farming country. The values are going to be far greater in years to come as our population grows and as the relative value becomes greater for land.

18. Beaver Economic Effects Not Considered

Beaver are numerous in the rivers and streams in the North Loup project area. They will move into irrigation canals and laterals and will plug up such waterways with diggings and small dams. The BOR has not included the cost of upkeep that will be necessary as a result of the Beaver activity. The additional cost will amount to at least $10 per mile per year for the 274 miles. Total cost $2,740 annually.

19. Economic Loss in Cattle Production

The Reservoirs would take out of cattle production, at least 12,555 acres of land altogether. This includes the 6,300 acres of water surface and the recreational and other easements associated with the Reservoirs. These 12,555 acres of land currently provide range and winter feed for at least 1,046 cattle each year. These cattle will produce some 1,025 or more calves that will be sold for feeder stock at around 400 lbs. each. These calves are currently selling for about 45.00/hundred lbs. or $180.00/each. Ten hundred and twenty-five calves would then be selling for about $184,500 each year. A loss over 100 years of at least $18,450,000.

The land to be inundated by the reservoirs is primarily usable only for grazing or hay production. Nebraska needs areas in the state to produce feeder cattle for those wishing to raise corn and feed out these cattle. Further, these ranchers receive no subsidies from the federal government for crop production or for keeping their acres out of production.

In addition to the cattle that can be raised directly on the inundated portion of Calamus Valley and Davis Creek, there are at least an additional 800 calves dependent on the ranch operations that are headquarters on the Calamus. These headquarters are in protected trees for over-wintering cattle and provide water that is not frozen all winter long.

Below the dam on the Calamus and North Loup, there are many thousands of acres of wet hay meadow or alfalfa that are dependent on the water sources from the rivers through subirrigation. Although, we must depend on the Bureau of Reclamation for a final assessment of these acres, we believe that the reduced flow will adversely affect at least 20,000 acres downstream. The losses to be expected will probably range upward from $1,000,000 per year as these acreages also effect over-wintering feed for cattle raised on adjacent uplands.

Ranchers dependent upon hay for over-wintering will need to purchase hay from outside sources as there is always a critical balance between summer pasture and hay meadow or alfalfa in ranching operations.

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