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In its comments on the EIS, the u.s. Environmental Protection Agency seriously questioned the accuracy of the USBR's salinity control claims. The EPA believes that the costs and delays associated with salinity control projects cast serious doubt as to the duration of these "temporary" increases. Even under the most optimistic of salinity control scenarios, 20 years of salinity levels on the order of 100 mg/liter above the 879 mg/liter level could exceed $686,000,000 in damages before the trend toward increases in salinity is reversed. No reliable estimate can be made of the damage that will occur before the tarqet salinity levels are finally achieved. I In order to avoid these environmental and economic costs, EPA has advocated consideration of a salinity offset policy similar to the offset policy that has been used to permit new clean industry in nonattainment areas where air ~ality standards are violated. Under the offset pOlicy, new air pollution sources are permitted only if emissions from existing sources are reduced to compensate for emissions from the new facility and the new facility has pollution controls that result in the lowest achievable emission rate for the pollutant in question. Under a salinity offset policy, increased salt loadinq or concentration by a project such as Animas La Plata would require correspondinq salinity reductions elsewhere in the basin. Thus, a development scheme which adversely impacts water quality would be allowed to proceed only if it were mitiqated by some other activity which would at least nullify these adverse effects. The test for adequacy in mitigation should be that a control project or strategy is being actively and successfully implemented concurrently with the project. The proposed Animas La Plata project fails to meet this test. The USBR appears to have overlooked the salinity impacts of surface mining. Field studies conducted elsewhere in Colorado indicate that surface mining may increase salt yields by nearly two tons per acre per year, an increase of more than soot above the salt yield from undisturbed ground. In view of the approximately 8000 acr.. that would be surface mined in the study area, the cumulative incr.ases in groundwater salinity could be very significant. The EPA concludes that the hiqh costs of providing storage in the Animas La Plata project, the expens. of pumping and treating (possibl. beyond conventional treatment) Animas River water for drinkinq water supply purpos.s, and the present inefficient use of water in Duranqo require a complete analysis of the area's water needs and the opportunities for conservation. Farmington'. excessively high per capita water use also indicat.s the need for ~~ , . I';' '.. t" ~,< to'. \! *'4 ~~ 35