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<br />expected to cease, the provlSlon would more nearly comport with the Forum <br />recommendation. How~r, as the note to section 3.9~ explains, the term <br />"standards" as used in the proposed technical change equates to "criteria," <br />not to the criteria and plan of implementation as that term is used by the <br />Forum. Since the Forum's "standards" include both numeric criteria and the <br /> <br />plan of implementation this provision would not have the same meaning un- <br /> <br />less the Commission also were to adopt the Forum's plan of implementation. <br /> <br />EPA would not recommend adoption of the Department's proposed change <br /> <br />to section 3.9.2 since the Commission's proposal aptly describes the basin- <br /> <br />wide context in which the salinity standards were developed by the states <br /> <br />actin9 througn the Forum. <br /> <br />Thank you for the opportunity to present these comments. <br /> <br />1417 <br /> <br />-7- <br />