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<br />. <br /> <br />. <br /> <br />criteria, is inconsistent with the recommended salinity standards deve- <br /> <br /> <br />loped by the Salinity Control Forum, and previous EPA requirements. A <br /> <br /> <br />more correct statement is: <br /> <br />"The salinity problem shall be treated as a basin- <br />wide problem that needs to be solved in order to <br />maintain lower main stem salinity at or below 1972 <br />levels While the basin states continue to develop <br />their compact-apport i oned waters." <br /> <br />The major difference evidenced by the Commission's proposal to in- <br /> <br />clude this provision as part of the criteria is that development acti- <br /> <br />vities could dictate a lowering of water quality if that became "best <br /> <br />practicable," whereas the statement recommended above serves an entirely <br /> <br />different purpose of explaining that the states are committed to solving <br /> <br />the salinity problem while developing their compact-apportioned waters. <br /> <br />Thus stated, it is clear that the specific criteria (1972 salinity levels) . <br /> <br /> <br />are to be maintained through basinwide efforts while development proceeds. <br /> <br />. Because both of the above narrative statements have historically been <br /> <br /> <br />conditioned by the Forum's plan of implementation, EPA believes that they <br /> <br /> <br />must appear in the same context as presented by the Forum plan. <br /> <br />B. Comments on 3.9.5 <br /> <br /> <br />EPA strongly endorses the proposal for regulatory implementation <br /> <br />of salinity control measures through sections 208 and 402 of the Clean <br /> <br />Water Act. Since much of the salinity in the basin is derived from non- <br /> <br /> <br />point sources, implementation of Best Management Practices (BMP's) through <br /> <br /> <br />the water quality management process offers considerable potential for <br /> <br />addressing non-point source pollution. Adherence to the Forum's NPDES <br /> <br /> <br />policy is important for controlling point sources and will play an even <br /> <br />greater role in the future in managing salinity in the basin. While these <br /> <br />-4- <br />