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<br />.....,.,.,,' .. <br /> <br />,. <br />~ <br /> <br />.r". <br /> <br />. <br /> <br />. <br /> <br />of view. It is the position of the City that the Water Quality Control <br />Commission should playa lead role in the preparation of this document, <br />for it is the Commission that ultimately adopts this document as policy <br />or a regulation for the State of Colorado. The allowance of the <br />Salinity Control Forums document to be prepared outside of the realm of <br />public scrutiny could result in a document that commits the State to <br />certain actions that would adversely affect the ability of that State to <br />use the compact allocated waters. Therefore, we urge the. co.nui1ission to. I hl <br />play the lead role in the preparation of the next Salinity Forums ~ <br />Report. <br /> <br />The Forum's Report dated 1978, forecasted an increase in salinity levels <br />of the Colorado River, when in fact, a decrease occurred. This is rather <br />significant in terms of the viability of the forecasting model used to <br />forecast salinity levels. In the 1981 Forums Report, we are told that <br />these problems are solved and that the mass balance has reduced the <br />amounts of salts on the order of 3/4 of a ton. It is the position of <br />the City that the salinity forecasting model has not been validated and <br />that the Water Quality Control Commission should view this model as @ <br />unproven. Approval of the model by the Water Quality Control Commission' ~ <br />should be postponed until sufficient records of actual salinity levels ~ <br />in the future bear out the prediction of the model. Many projects and <br />millions of dollars could be saved if this model were to be verified <br />before any planning is done using the model as a basis. <br /> <br />Colorado Springs perceives a potential conflict between the State water <br />laws and ~208 Plans developed to protect the salinity levels in the <br />Colorado River. That conflict revolves around the inability of various <br />governmental and private persons to utilize, to the highest.and best <br />use, their water rights. When mitigation of salinity results in the <br />decrease in consumptive use of water rights in the Upper Basin States, a <br />taking of property or inverse condemnation may occur. Therefore, ~208 <br />Plans should remain consistent with State water laws and those portions <br />of the Plans inconsistent be rendered unenforceable. In addition, it <br />was noted that the ErA Region VIII has expended ~208 Planning Funds for <br />a portion of the Salinity Control Forum's Executive Director. We would ~ <br />urge that the Com~ission note that this is an improper allocation of ~ <br />~208 monies, when in fact, those ~208 funds could be applied to.:waste- <br />water planning and result in a more beneficial use of those funds. <br /> <br />In conclusion, we would urge that the Water Quality Control Commission <br />playa major role in the development of the next Salinity Control <br />Forum's document. <br /> <br />Respectfully submitted, <br /> <br />J&~ES G. COLVIN II. <br />City Attorney <br />Reg. No. 004751 <br /> <br />1489 <br /> <br />-4- <br /> <br />4/23/82h <br />