378r 



STATEMENT BY STORRS WATERMAN 



unknown waters. If found necessary additional hearings 

 should be held when such waters are positively identi- 

 fied. 



"Finally, the implementation schedule noted 

 in Table II indicates that secondary treatment will be 

 required of nearly all industry and municipalities. In 

 our opinion this requirement is far in excess of that 

 required to meet the needs of all present and forseeable 

 future uses of most of the waters in question and any 

 reasonable standards promulgated. Further, secondary 

 treatment may not be the appropriate solution to meet 

 such standards that might be exceeded. Until such a 

 need is established as necessary and proper in each 

 specific instance, the installation of such expensive 

 measures would be a misappropfiation of both public and 

 private funds. For these reasons we request a deletion 

 of the columns of Table II entitled "Tentative Future 

 Waste Treatment or Control Needs", and "Schedule of 

 Compliance" . 



"Instead we submit that the implementation 

 and schedule of the promulgated standards be accomplished 

 with the legal tools available to the Pollution Control 

 Commission which are adequate to enforce timely compliance 

 with any reasonable standards adopted. 



