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<br />. <br /> <br />. <br /> <br />- 5 - <br /> <br />. <br /> <br />Colorado has established a cabinet level task force and <br />a technical work group to focus on salinity. This is a cowmen- <br />dable first step. Rather than reject the basin states' 1978 <br />implementation plan, the COITmission, task force, and work group <br />should reexamine: <br /> <br />(1) The control strategies in the 1978 plan to see which <br />can be applied effectively in Colorado; <br /> <br />(2) The lengthy list of state and local salinity strate- <br />gies developed by the respected Denver Research Institute and <br />published in J. Gordon Milliken, et al., State and Local Manage- <br />ment Actions to Reduce Colorado RIVer-Salinity (EPA-908/3-77/002, <br />Sept. 1977); <br /> <br />(3) The most cost~effective salinity control strategies-- <br />the "on-farm" approaches--analyzed in detail in Jay C. Anderson, <br />etal., Salinity Management Options for the Colorado River (Utah <br />Water Research Laboratory Report P-78-003, June 1978). <br /> <br />In conclusion, the methods, strategies, and programs <br />exist for controlling salinity. The Commission should not fol- <br />low the opposite approach--as in this proposal--of relegating <br />implementation into the vague, unenforceable "policy" area ,,,here <br />it will languish undescribed, unanalyzed, and unpublished--bear- <br />ing final evidence of Colorado's lack of commitment. Instead, <br />the Commission has before it in this three-year revision an <br />opportunity to do precisely the reverse--to take a leadership <br />role and go beyond the approaches tried to date. <br /> <br />Colorado's salinity may not yet trouble Colorado, al- <br />though it is a serious problem downstream. But it is in Colorado's <br />very strong self-interest to control salinity, to protect its <br />own rights to develop and to continue a viable West Slope economy <br />by working cooperatively with its downstream neighbors. The pres- <br />ent approach thumbs its nose at those neighbors, and if adopted, <br />while outrage may not be immediate, it will unfortunatly be long- <br />remembered. <br /> <br />Respe~funsubr;!..~tted , <br /> <br />/~~l~ <br /> <br />George Iv. Pr ing <br />Regional Conn,", . - <br /> <br />pa~~hil~i: ~ <br /> <br />Regional Counsel <br /> <br />1450 <br />