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<br /> <br />. <br /> <br />. <br /> <br /> <br />Occidental Oil Shale, Inc. <br />March 14, 1980 <br /> <br />(2) Occidental supports the concept of giving <br /> <br />pOlicy approval only to the Proposed 1978 Revision of the <br /> <br />Plan for Implementation adopted by the Forum. Occidental <br /> <br />believes that the Commission's Proposed Colorado River <br /> <br />Salin~ty Standards or Criteria of December 27, 1979, in <br /> <br />combination with the Commission's Regulation 3.10.0, entitled <br /> <br />"Implementation of the Colorado River Salinity Standards <br /> <br />Through the NPDES Program," is a sufficient regulatory <br /> <br />program for the purpose of controlling point sources of <br /> <br />TDS. <br /> <br />In addition, the Forum Proposed 1978 Revision is <br /> <br />already partially out of date, as well as being somewhat <br /> <br />generalized and not directed specifically to Colorado's unique <br /> <br />situation. <br /> <br />(3) As noted in its letter requesting designation <br /> <br />as a party to these hearings, Occidental endorses the <br /> <br />Commission's clear articulation of the principle that "this <br /> <br />standard shall not impair Colorado's ability to utilize its <br /> <br />compact-apportioned waters." Occidental also suggests that <br /> <br />it would be desirable and appropriate to include in the <br /> <br />standard, pursuant to C.R.S. 25-8-506, the concept that the <br /> <br />standard may not interfere with the operation of Colorado's <br /> <br />water laws and/or with vested water rights acquired and used <br /> <br />pursuant to those laws. Occidental suggests that the <br /> <br />following language be inserted following the word "Basin" <br /> <br />in line 1 on page 3 of the proposed regulation: <br /> <br />Furthermore, this standard shall not supersede <br />or interfere with the operation of Colorado's <br />water law and/or with vested water rights <br />acquired or used pursuant to that law, and <br />shall be implemented in a manner consistent <br />with Colorado's policy of maximizing the <br />beneficial use of the waters of the state. <br /> <br />1414 <br /> <br />-2- <br /> <br />7~_,_ """"",,~~~',_7';':_~,;"~~-,,~~_ _.~.,..,.-:, ,~- - ,- <br />