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<br />. <br /> <br />. <br /> <br />. <br /> <br />programs are key elements in contro 11 i ng sa li n ity, we bel i eve that the <br /> <br /> <br />more comprehensive implementation program developed by the Forum will be <br /> <br /> <br />essential to maintenance of the numeric criteria. <br /> <br />As an additional comment on this section, we believe that the intro- <br /> <br />ductory reference to the "proposed plan of implementation" should be <br /> <br />clarified to indicate what plan is referenced. The proposed policy state- <br /> <br />ment does not purport to adopt the Forum's plan of implementation, but <br /> <br />rather only certain specific aspects therof. As stated before, EPA be- <br /> <br />lieves that the basinwide approach requires uniformity among the basin <br /> <br />states in adopting the Forum's plan of implementation. <br /> <br />C. Comments on the Proposed Policy Statement <br /> <br />To date, the plan of implementation developed, revised, and <br /> <br /> <br />approved by the Forum is the only existing comprehensive plan for imple- <br /> <br />menting the water quality standards for salinity for the Colorado River <br /> <br />Basin. The forum has recommended this plan for adoption by each of the <br /> <br />basin states. The Commission's proposal, while referring to this plan, <br /> <br />does not consider it for adoption, even as a policy. Indeed, it is <br /> <br />referred to as the plan "in the other basin states." Salinity control <br /> <br />cannot be left "to the other basin states" which have agreed to pursue <br /> <br />th is effort, <br /> <br /> <br />Successful implementation of the current downstream salinity criteria <br /> <br />must be accomplished through the mechanisms established under Federal, <br /> <br />State, and local law. The Forum's plan outlines actions to be undertaken <br /> <br />by each basin state which further the goal of salinity control. A repre- <br /> <br />sentative listing of these actions is attached. These and other actions <br /> <br />are not included in the Commission's proposal for policy approval. <br /> <br />-5- <br /> <br />1418 <br />