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<br /> <br />. <br /> <br /> <br />. <br /> <br />Occidental Oil Shale, Inc. <br />March 14, 1980 <br /> <br />(4) Occidental believes that in adopting the <br /> <br />Forum 1978 Proposed Plan of Implementation, even as policy <br /> <br />only, the Commission should continue to give specific recog- <br /> <br />nition to the following factors as they affect the implement- <br /> <br />ation of the salinity standard within the State of Colorado: <br /> <br />(a) It is universally recognized that industrial <br /> <br />point source discharges are a very small part <br /> <br />of the total salinity load on the Colorado <br /> <br />River. Colorado's implementation program <br /> <br />should take into account the respective con- <br /> <br />tributions to the TDS of various types of <br /> <br />point source and non-point source discharges. <br /> <br />(b) At a time when our nation's energy problems <br /> <br />are increasingly severe, it will be important <br /> <br />to make appropriate trade-offs between <br /> <br />efficient and economical development of <br /> <br />domestic sources of energy, and control of <br /> <br />salt discharges made necessary by that develop- <br /> <br />ment. In specific response to the Commission's <br /> <br />request for comments on the fiscal impacts of <br /> <br />its proposed regulation, it should be noted <br /> <br />that the "practicability" of eliminating or <br /> <br />reducing salt discharges from energy develop- <br /> <br />ments depends largely on economic, as well as <br /> <br />technical, factors. Occidental believes that <br /> <br />a "no-salt return" requirement is not capable <br /> <br />of being met by water users in a reasonably <br /> <br />economical manner, within the limits of existing <br /> <br />or reasonably foreseeable technology, without un- <br /> <br />reasonable waste of water. Therefore, it will <br /> <br />be important for the viability of Colorado's <br /> <br />energy resource industry to continue Colorado's <br /> <br />-3- <br /> <br />1413 <br /> <br />~ ~ ,.,....._ _1'!.~~~""; .......;:----.:.. F'"',....~ ,_:=:-~ <br />