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<br />00107'. <br /> <br />2. A second reason, also urged early on by EP A, is that national uniform effluent <br /> <br />.limitations are inappropriate to irrigation, which is subject to local geographical variations. <br /> <br />3. Irrigation return flows typically have percolated into the ground and reappeared on <br /> <br />the surface elsewhere, following tile or natural drainage. Some argue that the resulting <br /> <br />commingled waters are not the surface waters that are the concern of the CWA <br /> <br />4. Western irrigation economies are dependent upon a system of federal subsidies and <br /> <br /> <br />lack the financial resources and incentives to address water pollution problems.41 Most. <br /> <br />importantly, since the cost of water is held at artificially low levels by the subsidy system, there <br /> <br />is thus no incentive to save. As the NRC Irrigation Report so aptly stated: <br /> <br />The economic and legal factors determining water use in the West have created an inunense irony. <br />Water is in many ways the most valuable commodity in the arid West and the basis of much of its <br />wealth. Yet because it is sold at artificially low prices, farmers often treat water as if it were a free <br />commodity.42 <br /> <br />5. A lack of coordinated planning is often a feature of agricultural regions; Within a <br /> <br />single county there may be city and county government, numerous irrigation districts, not to <br /> <br />mention flood control, rural water, and conservation districts. In addition, several federal <br /> <br />(BuRec, Fish & Wildlife, EPA, ASCS, and SCS) and state (water rights, water quality) agencies <br />may have jurisdiction.43 <br /> <br />41 NRC Irrigation Report at 55-56. <br /> <br />42 Id. at 104-05. <br /> <br /> <br />43 It!. at 105. <br /> <br />36 <br />