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<br />ffif <br />DISTRICT <br /> <br />ij"J <br />~... <br /> <br />MPfR Al RR bAI ~~ ~ ~IR [I <br /> <br />OPERATING HEADQUARTERS. P. Q. BOX 937 . IMPERIAL. CALIFORNIA 92251 <br /> <br />September 3, 1996 <br /> <br />~ <br />N <br />o <br />OJ <br /> <br />Mr. Jack A. Barnett <br />Executive Director <br />Colorado River Basin Salinity Control Forum <br />106 West 500 South, Suite 101 <br />Bountiful, Utah 84010 <br /> <br />Subject: Comments-1996 Review of Water Quality Standards for Salinity, Colorado River System <br /> <br />u. n~ ..:\.t C. k- -- <br />Dear ~dIIlett: <br /> <br />, <br />The Imperial Irrigation District (llD) has examined the 1996 Review of Water Quality Standards for Salinity, <br />Colorado River System (Review), dated June 1996, and appreciates being given the opportunity to comment on <br />this document. As the most southerly user of Colorado River waters within the United States, the IID is a <br />primary beneficiary of Colorado River salinity control measures and sincerely supports the efforts of the <br />Colorado River Basin Salinity Control Forum (Forum). The liD concurs with the general recommendations set <br />forth in this Review, and supports the salinity control measures the Forum has advocated to achieve current and <br />future standards. At this time, the IID also continues to endorse the existing numeric Colorado River salinity <br />criteria and encourages the attainment of these target levels. <br /> <br />However, as the largest and most downstream user of Colorado River waters in both California and the Lower <br />Basin, it is imperative to the IID that the salinity control programs noted in this Review not only be implemented, <br />but placed on an accelerated schedule as well. The IID and its agricultural users continue to be damaged due to <br />the increasing salinity of the Colorado River, both by economic losses and the requirement to use more water to <br />sustain an acceptable salt balance. if the current scheduling of planned projects is not expedited, the likelihood of <br />tailing to meet targeted salinity standards becomes not only a danger, but a reality. According to this Review, <br />when existing observed salinity levels arc adjusted to reflect the full impact of the current level of water <br />development within the basin (long-tenn mean water supply), these adjusted salinity concentrations exceed the <br />Forum's numeric criteria at all three measurement stations. Of particular concern to the IID are the salinity levels <br />at Imperial Dam (llD's point of diversion), but we obviously have a vested interest in water quality at the two <br />upstream stations as well. <br /> <br />While the goal of the Colorado River Basin Salinity Control Program (Program) is ultimately a 1.48 million ton <br />reduction in the salt loading of the Colorado River, the IID does not feel that the pace of the current schedule is <br />adequate to obtain this objective. In fuct, based on the analysis outlined in this Review, the 1995 Program <br />"backlog" involves controls that would reduce Colorado River salinity by more than 418,000 tons. This is in <br />addition to future controls designed to lower the Rivcr's salt load by 437,000 tons over the next twenty years. <br />Thus, according to the Review, this translates to a need for "45,000 tons of new salinity control measures. ,each <br />year, , . (until) 2015." Given the currcnt status and recent funding trends of the Program, the IID does not feel <br />that adequate efforts are being put forth to inlplemcnt additional salinity control projects. The tables that provide <br />exceedance evaluation analyses for the three measurement stations in the Review further illustrate tlus point. The <br />text in Appendix C notes that, with only tile existing salinity controls in place, "there is a (sic) 18 percent chance <br /> <br />9 <br /> <br />&\TtNAIMISCISALTRVWI.LET <br /> <br />Page J of2 <br />