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<br />. <br /> <br />~ <br /> <br />. <br /> <br />. <br /> <br />remains undeveloped in the upper basin states, and that this <br />water must be left free for future beneficial use by the states <br />under the provisions of the compacts and state laws. It is <br />important, therefore, for the state to follow this lead and not <br />place an onerous burden upon the water users of the River, <br />while implementing salinity control in the State of Colorado. <br />The Forum report and the Commission's proposed implementation <br />Section 3.9.5 continues to recognize the basin wide approach. <br />We believe it is proper for the primary control mechanism to be <br />the federally funded salinity control projects approved by <br />Congress in Title II of the 1974 Act. <br /> <br />In addition to the federally funded salinity control <br />projects, the Forum report and the proposed Colorado <br />implementation section incorporate the use of the NPDES point <br />source program, the 208 Water Quality Management Plans, and the <br />use of brackish and/or saline waters for industrial purposes. <br />The proposed plan of implementation sets forth a policy <br />requiring NPDES permits to limit discharges so that they <br />contain no salt where .practicable." The qualifier <br />"practicable" may not be sufficient to make clear that the <br />no-salt return policy will be implemented in a manner which <br />will not impede or impair water rights or be inconsistent with <br />the overall Colorado water policy of conservation and the <br />maximum utilization for beneficial use, or result in an <br /> <br />1480 <br /> <br />-3- <br />