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<br />a coherent fashion the full range of options for salinity control. <br /> <br />W I recognize that the standards contain built-in provisions for <br />W <br />~ their own violation, but it is important, nonetheless, to flag the <br />N <br /> <br />open-ended interpretation the report gives to violations which <br /> <br />result from development proceeding at a pace control measures <br /> <br />cannot match. It states that "[s]hould water development projects <br /> <br />be completed before control measures are brought on-line, temporary <br /> <br />increases above the criteria could result and these increases will <br /> <br /> <br />be deemed in conformance with the standard."~/ Unfortunately, no <br /> <br />attention is given to defining "temporary" or specifying the mag- <br /> <br />nitude of the "increases." Is one year temporary or is five years <br /> <br /> <br />considered a reasonable and allowable lag? Is an acceptable in- <br /> <br />crease 10 percent above the standard or is any increase to be <br /> <br />ignored no matter what its magnitude may be? By failing to give <br /> <br />any indication of how it intends to interpret the conditions which <br /> <br /> <br />give license to violations, the Forum's report demonstrates a <br /> <br /> <br />cavalier attitude toward ilie standards and responsibility of its <br /> <br />members for meeting them. <br /> <br />My second concern is with the absence of any cost or <br /> <br />damage data. In not presenting costs of control projects or <br /> <br />salinity damage estimates, the report fails to provide a basis <br /> <br />for comparing control options. More importantly, it does not re- <br /> <br />veal the fact that almost all of the salinity control projects <br /> <br />which are part and parcel of the water quality standards have <br />costs which greatly. exceed benefits, if benefits are measured as <br /> <br />~/ Proposed Report on the 1981 Review, p. v. <br /> <br />23 <br /> <br />t~ <br />