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<br />" I <br />~! <br /> <br />.~ <br />.' <br /> <br />. <br /> <br />. <br /> <br />f/q <br />10<;0 c <br />(,Nc?c )~ <br />yl' <br /> <br />WRITTEN COMMENTS ON BEHALF OF <br /> <br />CHEVRON SHALE OIL COMPANY <br /> <br />REGARDING PROPOSED SALINITY STANDARDS FOR <br />THE COLORADO RIVER BASIN <br /> <br />March 14, 1980 <br /> <br />The Commission is presently considering the adoption <br />of salinity standards, as proposed in its public notice <br />of December 28; 1979, pursuant to Section 303(c) of the <br />Federal.Water Pollution Control Act, as amended, and the <br />statutory authority given the Commission in C.R.S. 1973, <br />25-8-101,.et seq., as amended, and in particular Section <br />25-8-202(2), 25-8-203, 25-8-204 and 25-8-207 (1) (c), as <br />amended. Section 303(c) of the Federal Act requires the <br />state to hold public hearings at least once each three year <br />period for the purpose of reviewing applicable water quality <br />standards and as appropriate modifying and adopting stan- <br />dards. . Section 25-8-204 (C.R. S.) authorizes the Commission <br />to set either narrative or numeric water quality standards. <br />The District Court for the District of Columbia has ruled <br />that the Clean Water Act (Federal Water Pollution Control <br />Act) should be interpreted to allow narrative standards <br />as well as numeric standards. EDF v. Costle, F.S. <br />_, 13 ERC 1869 (1979) - - - <br /> <br />In light of the statutory directives, the Commission <br />should continue the approach taken by the Forum in 1975 <br />and by the Water Quality Control Commission in 1976 to adopt <br />narrative standards for salinity, with no numeric salinity <br />standards set for the Colorado River or any other stream <br />segment within the state of Colorado. This narrative ap- <br />proach recognizes that any water quality problem caused <br />by salinity is apparent only in the Lower Basin states and <br />not within the state of Colorado and is consistent with <br />the Forum-developed basin-wide approach for controlling <br />salinity in the Colorado River. This basin-wide approach <br />insures that individual water users and specific new water <br />development projects will not bear a disproportionate burden <br />in meeting the salinity standards at Hoover Dam, Parker <br />Dam and Imperial Dam. Chevron cannot support any salinity <br />standard or plan of implementation which does not recognize <br />and allow for the continued devefopment of the Compact al- <br />located waters. The Commission should keep foremost in <br />its decision making process the protection of Colorado's <br />compact allocated waters and insure that the rights of Colorado <br />water users are not infringed upon. <br /> <br />1448 <br />