WSPC04017

• File Number: 8272.500.10
• Description: Colorado River Basin-Water Quality-Salinity-Organizations and Entities-CO Dept of Public Health-WQCC
• State: CO
• Basin: Colorado Mainstem
• Water Division: 5
• Date: 3/14/1980
• Title: Colorado River Salinity-Water Quality Control Commission-1978 Standards-Standards and Implementation Policy Hearings-Comments of the Environmental Defense Fund
• Water Supply Pro - Doc Type: Report/Study

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COMHENTS
OF
THE ENVIRON~ffiNTAL DEFENSE FUND
ON
THE PROPOSED "COLORADO RIVER
SALINITY STANDARDS OR CRITERIA"
AND "PLAN OF IMPLEMENTATION"
BE FO RE
THE COLORADO WATER QUALITY CONTROL COMBISSIOH

"'i,Trr~ 011'\' iTY

MAR 1. 11980
CO:,. ,\u~. vv.."..",).5H)N

Barch 14, 1980

The State of Colorado has a disappointing record of re-
sistance to effective control of salinity--the most serious
water quality problem in the Colorado River Basin. Only that
resistance, not pollution control, would be furthered by regula-
tion changes currently being considered for adoption.

The Colorado Water Quality Control Commission has before
it "Proposed Colorado River Salinity Standards or Criteria" and
"Plan of Implementation--Salinity Standard for Colorado River
Basin" dated December 27, 1979. These documents represent a
giant step backward from even the weak controls Colorado is com-
mitted to today, and they propose no substitute, only a larger
void.

The Corrmission is not being asked to adopt something new,
better or more effective than its 1976 salinity water quality
standards and implementation plan. Instead, it has before it
two proposals which (1) merely affirm water quality yriteria for
salinity at points some 1,000 miles outside Colorado's borders,
while (2) "repeal[ing]" all regulatory force and effect of
Colorado's implementation plan for preserving those levels.

It is only an exercise in cosmetics to say that, while
being repealed, Colorado's implementation strategy is being kept
as a "policy statement." Nothing of substance is being offered
to replace it. Throwing the implementation baby out with the
bath water, in this fashion, violates not only the law. It
rejects the "basinwide approach" and interstate cooperation care-
fully built up over ~~e last 0 years.

Environmental Defense Fund, 1657 Pennsylvania Street, Denver. CO 80203 [phone]
OFFICES IN, NEW YORK, NY (NATIONAL HEADQUARTERS); WASHINGTON, DC; BERKELEY, CA; DENVER. CO

1454

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