presently driven by the economics of disposal and treatment costs and regulations rather than consideration of its possible beneficial use.

Given that produced water can be treated to any water quality with current technologies, but at varying costs, future regulation of CBM produced water management should consider the age of the CBM produced water. Careful management of non-renewable “fossil” water should be considered a priority. Management of a water resource that is indeed irreplaceable may benefit from considering opportunities to put it to best use or to store it in aquifers for future use, rather than to dispose of it. Current regulations and water law do not provide incentives to CBM operating companies (or other stakeholders) to put produced water to beneficial use or offer many options to consider other than to dispose of nonrenewable CBM produced water. Although a number of recent court reviews of CBM production activities do signal some recognition of the fact that water resources naturally traverse state, legal, and geological boundaries, these reviews have not provided clarification about effective produced water management and instead exemplify state-specific approaches.

CLOSING REMARKS

The coupled demands for domestic energy and clean water resources require the environmentally and economically sound management of produced water from CBM activities. The most important aspect of this issue is the science surrounding the use or disposal of CBM produced water. Multiple potential users and uses of limited water resources, a concern by the public for protection of these limited resources, the complexities of hydrogeological systems, and the renewability or nonrenewability of water resources require increasingly sophisticated approaches to understanding CBM produced water and produced water management. These approaches require a basis in scientifically grounded studies and consistent monitoring, and should allow for a greater range of economically and environmentally viable options for CBM produced water management in the future.



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