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Furthermore, the legislature has declared it to be the public policy of Colorado to ...conserve state waters and to protect, maintain, and improve, where necessary and reasonable, the quality thereof for public water supplies, for protection and propagation of wildlife and aquatic life, for domestic, argricultural, indus- trial, and recreational uses, and for other beneficial uses, taking into con- sideration the requirements of such uses; to provide that no pollutant be released into any state waters without first re- ceiving the treatment or other corrective action necessary to reasonably protect th legitimate and beneficial uses of such waters; to provide for the prevention, abatement, and control of new or existing water pollution; and to cooperate with other states and the federal government in carrying out these objectives. Section 25-8-102(2), Senate Bill 10 (emphasis added). It is inconsistent with this policy to issue a permit which authorizes the discharge of pollutants which are unquestionably harmful to the public health in amounts greater than that allowed by the established water quality standards, without any monitcring requirement sufficient to show that the effluent limitations necessary to achieve those standards will be met. The lack of monitoring by the permittee, combined with routine insFection practices by the state which preclude obtaining sufficient data to enforce 30-day limitations, constitute a policy which exposes the public to an unreasonable risk of harm and deprives the public of any meaningful means of ensuring their own protection. In sum, such a policy effectively repeals the Act and the regula- tions and renders the permit an unenforceable nullity. In order to provide adequate protection for the public from discharges such as the one at issue here which represent a serious threat to the long-term health and safety of the public, the Division must require monitoring which is adequate to determine whether Cotter's discharge will consistently comply with the applicable effluent limitations. In this case, EDF respectfully requests that the following sampling and analysis requirements be adopted in lieu of those set out on page 4 of the draft permit. Single "grab" samples should be collected. every eight hours for 5-day periods. These samples should be properly protected to preserve the integrity of each pollutant of concern. The 15 samples collected during -4-