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. . Trou-t \)f\IIM\l-cl -rrD~ CY'uf\Eje.s ~ ~ l\Orr\Iovd., Su.... ~. DRAFT November 20, 1998 US, Environmental Protection Agency 401 M Street, S.W. Washington, D.C. 20460 Attn: WQS-ANPRM Comment Clerk Water Docket, MC 4101 Re: Water Quality Standards - Advance Notice of Proposed Rule Making Dear EP A: '*1-0 We would like to offer the following comments on behalf of the Colorado Water Conservation Board (CWCB). The CWCB is the agency within Colorado's Executive Branch having responsibility for the protection, conservation, and development of Colorado's water resources. The CWCB is also responsible for appropriation and maintenance of in stream flow water rights in the Colorado. We have a cooperative relationship with the Colorado Water Quality Control Commission (wQCC) and its staff, and generally rely on their technical expertise and programmatic authority for the protection of water quality in Colorado, Accordingly, we want to take this opportunity to supplement the comments provided to you by the WQCC and to underscore certain aspects that are more directly related to the responsibilities of the CWCB, We found your Advance Notice of Proposed Rule.Making (ANPRM) to be very informative concerning the implementation of the Clean Water A WAre uirements and olicies, However, It oes not provide the basis to conclude that so many aspects of the im lementation effort re uire such extensive overhaul. Colorado and other states ave developed extensive regulatory and technica assistance programs consistent with EP A guidelines for the implementation of the CW A, and have invested heavily in the implementation of those programs, Extensive changes to the underlying federal guidelines, as indicated in the ANPRM, will require substantial involvement by state and local agencies (as well as non-government.al i~terests) and s~ould only be proposed in such r:::l- areas and to s ch extent as can be c1earl ustdied by an obvIous need, That jUStl cation ~'.J.. has not been demonstrated and the CWCB questions w et er such need exists. We do f\\€- not accept EPA's suggestion that increase Interest In watershed management and the development of improved technology, by themselves, justify a "comprehensive evaluation for the purpose of strengthening the regulation. " We agree, however, that "the current regulation is not broken" and that a "structured national debate is needed" before proceeding with such an overhaul of the existing policies, criteria and programs. CD tJe\ek.