SanJuanDoloresSanMiguelComments02

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.. Finally, M&I demand is based upon per capita use. Given that new homes are using less water indoors with more efficient water using fixtures and outdoors by putting in less tun, will you reduce the per capita usage below historical levels which are biased by older homes? Coal-Bed Methane Production Water At several meetings, it has been suggested that produced water from coal-bed methane wells could help satisfy water demands. But in the next thirty years, methane production is supposed to peak and be well into decline. To base our future supply needst or even our current needs, on a clearly finite resource would be pure folly. In addition, much of the water produce by coal-bed methane production has very high levels of total dissolved solids that make it unsuitable for any use. Some of the produced water has low enough TDS for some uses, but not others. The quality may be good enough irrigation, but may not good enough for aquatic life There is concern that gas companies could circumvent the Clean Water Act by providing their produced water to farmers for irrigation. The gas companies need a discharge permit to convey water directly to a stream, but may not need a permit to give it to a farmer for irrigation. Some of that irrigation water will eventually return to surlace waters of the state and; of course, be unregulated. These return flows will likely have high IDS because the supplied water has high IDS and will further increase salinity in the Colorado River Basin. SWSI Objectives There are two objectives that I would like to see added to the set already developed. One, "Preserve and improve water qualitv". Water quality affects all water uses and as such it should be an explicitly listed so that it isn't forgotten~ The second objective is "Balance costs versus benefitst'. This has different meaning than the currently listed objective of "Promote cost-effectiveness". For example, a group of irrigators may want to expand a reservoir to supply water during drought years+ "Promote cost-effectiveness" could mean what is the most cost-effective way to satisfy those inigators' wants" Suppose that the most cost-effective way of providing a drought supply costs $10 million" "Balance costs versus benefits" takes the next step of comparing if the benefits are actually worth $10 million4 If the benefits are only worth $4 million, the first objective of "promote cost-effectiveness" may be met, yet the second objective of "balance costs versus benefits'" would not be met. The objecti ve of "balance costs versus benefits" is a check to determine if we are actually receiving a return on our investment that is equal to or greater than our actual investment.