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We are also concerned about EPA's suggested new water quality criteria and their potential implications for non-point sources of pollution (e,g" irrigation return flows), In Colorado and many other western states, approximately 80% of the available water su I is used for irrigation of cro s and other agricultural purposes.IWithout strong evidence t at agricu tura activities are causing sigm lcant arners to the successful implementation of the CW A and an evaluation of the potential economic impact to rural communities, EP A should strengthen the voluntary, incentive-based nature of existing non-point source control ro rams such as those promoted under Section 319. The CWCB is involved in many watershed-based organizations, both within Colorado and at the interstate level. The utility of such organizations has been demonstrated in the protection of environmental values (e,g" the Colorado River Salinity Control Forum and the Platte River Recovery Agreement) the protection of water supplies (e,g., interstate compacts and groups like the seven states and ten tribes of the Colorado River Basin that have formed to address issues surrounding the Colorado River Compact) and the protection of our communities against flood risks (e.g., the Roaring Fork and Fryingpan multi-objective management project steering committee), These organizations tend to include diverse interests and sometimes address more diverse objectives, but they also require greater "relationship maintenance" as a result, Therefore, they seem to be most effective when the principally affected interests within a watershed organize themselves as a function of" rassroots" determination to solve their own problems. EPA's interest in ,establishing new or broader organizations IS causing concern that EPA, seeks to influence the riorities or the balance of owers within or among existing or anizations, Since the participants in those existing organizations have ta en considerable initiative and made significant investment in their relationships and implementation plans, EP A should avoid the promotion of competing or overlapping organizations, EPA's ANPRM does not appear to recognize the Prior ApproprIation Doctrin or ~';1e.. the existing system of water rights t at ave een established in many western states as the fundamental basis for allocation and protection of our limited water supplies, In some Instances, such as the suggested development of various "physical criteria" (including sediment quality, flow and wildlife criteria), the ANPRM doesn't even appear to acknowledge the role of state laws and property rights in the allocation of western water resources, It would be helpful ifEPA would explicitly acknowledge this role and the potential relationship such criteria may have to existing and future water supplies, Ifflow crIteria, for example, are develope without regar or e 0 VIOUS epen ence of many xisting communities on water storage and diversion facilities and the obvious effects such acilities can have on lakes and streams, the implementation mechanisms (e,g" TMDLs) , ould have adverse consequences throu hout many western states Also, EP A has prevIous y proposed t e suggestion that "biologlca CrIteria" s ould be developed based upon concerns that the necessary data and science that Colorado found inade uate. A status report, including the views of state and federal wildlife agencies, on the development of that data and the related scientific methods would be very helpful. We WQS-ANPRM Comment Clerk November 20, 1998 Page 2 . ~ Q) k.WfOe. G) ~r\"\e.. @ ~e:\e G) ~e.