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I I I I I I I I I I I I I I I I I I I ~~:~?7 In recent years. there has been growing awareness that secondary treatment of municipal sewage effluent may not provide adequate quality water for unrestricted agricultural uses. In the only case specifically considering agricultural water quality requirements to date, the Water Court for Water Division I (adjudicating all South Platte decrees) determined that secondary treatment of municipal sewage effluent did nol provide adequate quality water to permit an exchange against downstream municipal and agricultural users. Colorado is far from a leader in establishing agricultural water quality standards. Of the numerous states which have specifically considered municipal wastewater re-use for unrestricted crop inigation, the "California Standards" (California Administrative Code, Chapter 4, Title 22, Div. 4, Environmental Health) have been generally accepted. The California Code provisions specify treatment processes, as well as final discharge standards. For example, Section 60303 of the Wastewater Reclamation Criteria for root crop and spray inigation requirements provides: "Reclaimed water used for the spray inigation of food crops [and inigation of root crops] shall be at all times an adequately disinfected, oxidized, coagulated, clarified, filtered wastewater. The wastewater shall be considered disinfected, if at some location in the treatment process, the median number of coliform organisms d~es not exceed 2.2 per 100 milliliters and the number of coliform organisms does not exceed 23 per 100 milliliters in more than one sample within any 30 day period." The Colorado Department of Health has adopted the same standard for direct re-use of municipal effluent for crop inigation. However, the Colorado Water Quality Control Commission, has not yet applied this standard to regulated sewage discharges on the basis that such discharges are "indirect" rather than "direct" sewage re-use, The adequacy of municipal 15