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<br />w <br />.... <br />o <br />w <br /> <br />questionable. However, as stated in 3 above, the <br />legislation could provide such authority and money <br />to implement it." <br /> <br />Utah Power and Light Companz <br /> <br />The Company's comments may be summarized as follows: <br />1) New upstream users should not be required to compensate <br />for salinity resulting from natural sources and existing <br />uses; 2) undue emphasis has been placed on industrial dis- <br />charges, which have a negligible impact on salinity, while <br />efforts to reduce irrigation of saline soils have been <br />large ignored; and 3) the Company suggests that further <br />efforts must be directed toward determination of the best <br />and most economical method of reducing downstream salinity, <br />and that industrial users should not be required to clean <br />up discharges while agricultural users are not required to <br />do so. <br /> <br />To attain the plan's objective of maintaining the <br />numeric salinity criteria, while the basin states continue <br />to develop their compact-apportioned waters, requires the <br />implementation of all practicable salinity control measures. <br />The plan includes six salinity control units which will <br />control natural sources and eight which are directed, totally <br />or in part, at agricultural sources. In addition, the Soil <br />Conservation Service is proposing on-farm practices which <br />will further reduce salt loading from irrigation sources. <br /> <br />The effects of the Company's present and proposed <br />consumptive use of water on salinity are not negligible. <br />The Company's consumptive use of 20,000-40,000 acre-feet, <br />if that part of the amount diverted which is not consumed <br />is returned to the stream, would be equivalent to adding <br />20-40,000 tons of salt per year to the supply remaining in <br />the river, resulting in a salinity increase of 2-4 mg/l at <br />Imperial Dam. <br /> <br />The Forum's policy for industrial discharges requires <br />no-salt return whenever practicable. If a permittee can <br />demonstrate that no salt return is not practicable, a permit <br />can be issued with less stringent requirements. The Forum <br />believes that its policy, which has been adopted by the <br />states and approved by EPA, contains sufficient flexibility <br />to handle site-specific situations. <br /> <br />Maintenance of the numeric criteria by practicable <br />and cost-effective methods has always been the Forum's <br />objective. The Forum's recommendation for deferral of two <br />authorized salinity control units because of their low cost- <br />effectiveness is an indication of this objective. <br /> <br />9 <br />