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'u1 18 02 02:53p <br />Honorable T.A. Fatalan. <br />Page 3 <br />FQbruary 4, 1998 <br />ENSURE THAT OBTAINING THE RIGHT TO BENEFICIALLY USE PRODUCED WATER <br />IS NOT A LOOPHOLE FOR IMPROPER DISPOSAL. <br />To my knowledge this is the first time that an application has been made for the <br />right to use produced water and if the water is suitable for its intended use, then the <br />COGCC would be In favor of granting the right. However, this will set a precedent <br />and I would expect that similar applications will be made by other individuals for the <br />right to use produced water elsewhere in the northern San Juan Basin and in other <br />areas of the state. Some procedure should be established to ensure that water <br />rights are only granted for water suitable for the intended use end not a loophole <br />that can be used to ge-t around proper disposal requirements, and thus avoid the <br />associated costs. <br />I appreciate your consideration of my comments. if you or your staff would like to <br />discuss there matters further, then please call me at 303-894-2100 extension 121 <br />or Debbie Baldwin, hydregeaiogist, at extension 11 1. <br />Sincerely, <br />Colorado Oil and Gas Conservation Commission <br />Richard T. Griebiing, Director <br />cc: H. Simpson, State Engineer <br />A. Davis,, Assistant Attorney General <br />C. McNeill, Assistant Attorney General <br />J. Anesi, Attomey for K. Baird <br />F.12 <br />ti.d dgS:ZT ED 00 ReW <br />