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<br />. <br /> <br />November 21,1998 DRAFT <br /> <br />U.S. Environmental Protection Agency <br />401 M Street, SoW. <br />Washington, D.C. 20460 <br /> <br />Attn: WQS-ANPRM Comment Clerk <br />Water Docket, MC 4101 <br /> <br />Re: Water Quality Standards - Advance Notice of Proposed Rule Making <br /> <br />. <br /> <br />Dear EP A: <br />We would like to offer the following comments on behalf of the Colorado Water <br />Conservation Board (CWCB). The CWCB is the agency within Colorado's Executive <br />Branch having responsibility for the protection, conservation, and development of <br />Colorado's water resources. The CWCB is also responsible for appropriation and <br />maintenance ofinstream flow water rights in the Colorado. We have a cooperative <br />relationship with the Colorado Water Quality Control Commission (WQCC) and its staff, <br />and generally rely on their technical expertise and programmatic authority for the <br />protection of water quality in Colorado. Accordingly, we want to take this opportunity to <br />supplement the comments provided to you by the WQCC and to underscore certain <br />aspects that are more directly related to the responsibilities of the CWCB. <br /> <br />. <br /> <br />We found your Advance Notice of Proposed Rule Making (ANPRM) to be very <br />informative concerning the implementation of the Clean Water Act (CW A) requirements <br />and policies. However, it does not provide the basis to conclude that so many aspects of <br />the implementation effort require such extensive overhaul. Colorado and other states <br />have developed extensive regulatory and technical assistance programs consistent with <br />EP A guidelines for the implementation of the CW A, and have invested heavily in the <br />implementation of those programs. Extensive changes to the underlying federal <br />guidelines, as indicated in the ANPRM, will require substantial involvement by state and <br />local agencies (as well as non-govemmental interests) and should only be proposed in <br />such areas and to such extent as can be clearly justified by an obvious need. That <br />justification has not been demonstrated and the CWCB questions whether such need <br />