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<br />oo:n~3 <br /> <br />should be reactive to specific circumstances, rather than an attempt to solve all conceptual <br />problems in one comprehensive bill. <br /> <br />Third, guidelines must establish criteria for regulatory review of the reasonableness of <br /> <br /> <br />agricultural water use. Zach Willey of the Environmental Defense Fund recently informed me <br /> <br /> <br />that EDF petitioned the State Water Resources Control Board in the late-l97Os to establish <br /> <br /> <br />criteria -- EDF had advocated Use of economic principles. The Board igriored the petition and, <br /> <br /> <br />to this day, no water user in California has any guidance on what constitutes unreasonable <br /> <br /> <br />water use. Legislation directing agencies to engage in generic rule-making could start this <br /> <br /> <br />needed process. <br /> <br />Finally, states must decide what legal significance should be attached to trading/transfer <br /> <br /> <br />opportunities. identified in environmental impact statements. I argued above that we should <br /> <br /> <br />avoid creating an .obligation to trade." At the same time, we must assure that EIS don't <br /> <br /> <br />become littered with hypothetical trading alternatives. Our (or at least mine) understanding of <br /> <br />these problems is so primitive that the process should begin with a commission to study the <br /> <br /> <br />severity of this problem and develop alternative solutions. <br /> <br />18 <br />