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toI:a N o ...:1 that salinity may go above 1,000 mg/L at Imperial Dam (and) , , . the mean of882 mg/L is above the nwneric criteria level of 879 mgIL. This is because there is not currentlv enough salinity control to offset water development." (emphasis added) These figures provide the basis and impetus for the lID's request for an accelerated Program implementation schedule. The Review also notes that, based on available data, "the measured salinity will not exceed the nwneric criteria during the next three years". The lID disagrees with this conclusion. The Program allows for temporary increases due to the completion of additional water development projects provided "appropriate control measures" are planned, even if they are not implemented at the time of development. However, the District does not feel that appropriate funding and/or scheduling currently exists to implement these controls. The potential impact of the Program's failure to achieve targeted goals in a timely manner is staggering. Damages to the Lower Basin will exceed an estimated $1 billion by 2015 if further salinity control measures are not implemented, The damages to the IID and its agricultural community are briefly documented in the Review, and are primarily a result of lower crop yields, increased irrigation management costs, and additional drainage requirements, as well as increased water use required to maintain a salt balance. Also touched upon, and of perhaps even more significance, are the problems that our irrigation district faces as a result of increasingly strict regulatory restrictions on our drain water quality. As the salinity of our inflow waters increase, we also experience a subsequent decrease in drain water quality and ultimately a degradation in the waters of the Salton Sea drainage basin, While no recent studies have been conducted to pinpoint the true magnitude of the damages resulting from the River's increased salinity, the use of data from previous years (1976-1985) would indicate an annual loss on the order of$700 million (one-third of which is thought to be agriculturally-based). Due to the age of this data, there also appears to be an urgent need to update this infonnation for the 1986 to 1995 time period in order to develop a more accurate and current estimate of the potential economic impacts resulting from increased salinity levels. As noted in this Review, federal funding has been reduced in recent years (since 1994). Combined with the Program's transition to a basin-wide planning approach, it appears to the lID that the Program is not only off- course, but slowing to a pace that will cause irrevocable hann and economic damage to the lID, its water users, and its surrounding communities. The lID is thankful that the Colorado River Basin's hydrology has been favorable since the Program has gotten off-track, but this can only mitigate the effects of salinity for so long. It is with great regard to the Forum's past efforts and accomplishments that the lID requests the acceleration of planned salinity control projects and the update of the 1988 Bureau of Reclamation report analyzing the estimated economic impacts of Colorado River salinity. We are well a\\-'llCe of the fWlding restrictions and difficulties that most public agencies are facing in the current economy, and sincerely appreciate all of the Forum's achievements to date. It is however, in our consumer's best interest to actively promote and encourage the timely attainment of the Forum's targeted salinity goals. Once again, let us thank you for the opportunity to comment on the 1996 Review and voice both our support and concern for the existing Program, Sincerely, !!/;C~ General Manager 10 S:\TlNAIMISCISALTRVWI.LET Page 20f2 ..