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<br />. <br /> <br />. <br /> <br />Thus, we view the cooperative venture of the <br />Forum States and EPA to be based on the proposition <br />that project by' project salinity offsets are not re- <br />quired for water projects, the purpose of the overall <br />plan being to allow the development of water projects <br />in the upper Basin States to proceed without such <br />constraints; otherwise the, ,Grand Valley and Paradox <br />controls ought to be credited to Colorado projects <br />rather than being part of the overall effort. <br /> <br />We urge the Commission, the State of Colorado <br />and the Forum to continue to examine the need for and <br />basis of salinity water quality, standards and implemen- <br />tation program. The Forum's August 1978 document, at <br />page 22, states that the ,salinity ,load in the River <br />was initially overestimated and that new studies a~e <br />warranted. Section'203 of the 1974 Salinity Control <br />Act calls for such studies (see p. 43, Forum, August <br />1978 document). <br /> <br />We understand the notice of hearings for these <br />proceedings to state that the Forum 1978 products will <br />be adopted as a policy and not as' a rule"consistent <br />with C.R.S. 1973, 24-4-103(1), and thus will not be <br />binding as a,rule upon those ~egulated by the Com- <br />mission. <br /> <br />There are' .matterS. in' 'ch:e' 7\.ilgnst:.:l97 r.' ,?'urum docu~' <br />ment which should 'be corrected. whether the document is given <br />"policy approval" or is adopted as a rule: in particular, <br /> <br />-15- <br /> <br />1457 <br />