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<br />WQS-ANPRM Comment Clerk <br />November 21, 1998 <br />Page 2 <br /> <br />exists. We do not accept EPA's suggestion that increased interest in watershed <br /> <br /> <br />management and the development of improved technology, by themselves, justify a <br /> <br /> <br />"comprehensive evaluation for the purpose of strengthening the regulation." We agree, <br /> <br /> <br />however, that "the current regulation is not broken" and that a "structured national debate <br /> <br /> <br />is needed" before proceeding with such an overhaul of the existing policies, criteria and <br /> <br />. <br /> <br />programs. <br /> <br />We are also concerned about EPA's suggested new water quality criteria and their <br />potential implications for non-point sources of pollution (e.g., irrigation return flows). In <br />Colorado and many other western states, approximately 80% of the available water <br />supply is used for irrigation of crops and other agricultural purposes. Without strong <br />evidence that agricultural activities are causing significant barriers to the successful <br />implementation of the CW A and an evaluation of the potential economic impact to rural <br />communities, EP A should strengthen the voluntary, incentive-based nature of existing <br />non-point source control programs such as those promoted under Section 319. <br /> <br />The CWCB is involved in many watershed-based organizations, both within <br />Colorado and at the interstate level. The utility of such organizations has been <br />demonstrated in the protection of environmental values (e.g., the Colorado River Salinity <br />Control Forum and the Platte River Recovery Agreement) the protection of water <br />supplies (e.g., interstate compacts and groups like the seven states and ten tribes of the <br />Colorado River Basin that have formed to address issues surrounding the Colorado River <br />Compact) and the protection of our communities against flood risks (e.g., the Roaring <br />Fork and Fryingpan multi-objective management project steering committee). These <br />organizations tend to include diverse interests and sometimes address more diverse <br />objectives, but they also require greater "relationship maintenance" as a result. <br />Therefore, they seem to be most effective when the principally affected interests within a <br />watershed organize themselves as a function of "grassroots" determination to solve their <br />own problems. EPA's interest in establishing new or broader organizations is causing <br />concern that EP A seeks to influence the priorities or the balance of powers within or <br /> <br />. <br /> <br />. <br />