Click the link to read the report on the Getches-Wilkinson Center website (Eric Kuhn,*ย Anne Castle,โ ย Jack Schmidt,โกย Kathryn Sorensen,ยงย Katherine Tara**). Here’s the Introduction:
October 6, 2026
SUMMARY OF KEY POINTS
- In 1956, Congress authorized the Upper Initial UnitsโFlaming Gorge Reservoir, Navajo Reservoir, and the Aspinall Unit (UIUs)โfor a variety of water use purposes in the Upper Colorado River Basin, including compliance with the 1922 Colorado River Compact (1922 Compact). The historical record is clear that the primary reason these reservoirs exist is to satisfy the math of the 1922 Compact and the obligations it imposed on the Upper Division States regarding flows at Lee Ferry.
- The size and operation of the UIUs was based on the math of the river as we understood it from the 1930s through the mid-1950s (natural flows, projected uses, and the drought of record). This math no longer works. Total water use in the Colorado River Basin has consistently exceeded the available supply since 2000. Until this fundamental problem is solved, releasing water from the UIUs only delays necessary permanent reductions in water use and provides some degree of temporary management flexibility.
- The 1948 Upper Basin Compact contemplates delivery of a required quantity of water at Lee Ferry. Article V gives the Upper Colorado River Commission (UCRC) the authority to allocate the capacity of the UIUs between providing water for use within the Upper Division States and providing water for common benefit purposes (delivering water to Lee Ferry). The policy has always been that 100% of the capacity of Navajo Reservoir is allocated for water use in New Mexico and 100% of the capacities of Blue Mesa and Flaming Gorge Reservoirs is allocated for common benefit purposes.
- There is no doubt that Flaming Gorge and Blue Mesa Reservoirs exist to meet a portion of the obligation of the Upper Division States under Article III of the 1922 Compact. As of October 1, 2026, the ten-year Lee Ferry flow will be about 81.2 million acre-feet (MAF), and under the Lower Division Statesโ interpretation of the 1922 Compact, the Upper Division States may be in a compact deficit by 800,000 acre-feet (or more).
- Yet over 2.0 MAF of water remains in active storage in Flaming Gorge Reservoir; more than enough water to erase the deficit and put the Upper Division states back in compact compliance as interpreted by the Lower Basin, if only for the short term.
- The Upper Division States assert that they are in full compliance with the 1922 Compact.ยน Thus, in their view, delivering additional UIU water to Lee Ferry now would be a waste of stored water that they may need in the future. They question why yet another reservoir should be further drawn down when the Basin has not solved the fundamental problem of demand exceeding supply.
- The stored water available in Flaming Gorge Reservoir has increased in importance to the entire basin. The Lower Division states view it as a source of water that can be delivered at Lee Ferry to supplement the releases from Lake Powell and thereby fulfill the obligations of the Upper Division States under the 1922 Compact. The Bureau of Reclamation is using Flaming Gorge as a source of water to protect critical infrastructure at Glen Canyon Dam, including hydropower generation. The Upper Division States view Flaming Gorge as a source of water for their current and future benefit; the water stored there could be used to comply with an adverse decision by a court or Special Master.
- There remain unresolved issues concerning the use of water stored in the UIUs, with seemingly conflicting provisions in the 1948 Upper Basin Compact and the 1970 Long-Range Operating Criteria that currently govern the operation of these reservoirs. These issues could govern future releases from the UIUs but have not been explicitly addressed in the Post-2026 Record of Decision or the 2027-2028 Operating Rules.
- The math of the 1922 Compact and its Lee Ferry flow provision, together with the directives of the Long-Range Operating Criteria, can no longer be reconciled with todayโs hydrology and long-term average basin-wide consumptive use. The Basin States can argue about compliance with various conflicting provisions, but the fundamental problem is that the rules were designed for a different river. We need new operating rules that reflect the river we have today. The choice in finding these new rules is likely to be between a compromise that is painful to all parties or a zero-sum Supreme Court decision that determines who gets what little water there is and who does not.
INTRODUCTIONยฒ
The 1956 Colorado River Storage Project Act (1956 CRSPA)ยณ authorized construction of Glen Canyon Dam, which created Lake Powell, and three additional major upstream storage projects; Flaming Gorge Dam and Reservoir, Navajo Dam and Reservoir, and the Curecanti Unit (Blue Mesa, Morrow Point, and Crystal Dams and Reservoirs, now called the Aspinall Unit). The 1956 CRSPA was designed as a broad authorization for Upper Basin water development within the bounds of the 1922 Compact. The legislation authorized construction of storage dams, powerplants,โด numerous irrigation projects, and trans-basin diversions. Among the purposes of 1956 CRSPA were โregulating the flow of the Colorado River, storing water for beneficial consumptive use, making it possible for the States of the Upper Basin to utilize, consistently with provisions of the Colorado River Compact, the apportionments made to and among them in the Colorado River Compact and the Upper Colorado River Basin Compact, respectively . . ..โโต Flaming Gorge, Navajo, and the Aspinall Unitโถ are collectively referred to as the โUpper Initial Unitsโ (hereafter, UIUs). The three UIUsโ total live storage capacity is 6.15 million acre-feet (MAF), of which 5.10 MAF is โactiveโ storage.โท On October 1, 2026, the total live storage in the three reservoir systems was 3.47 MAF. The Appendix contains a detailed description of each of the UIUs, with information on capacity, operations, and contract obligations.
For over 60 years, the three UIUs have been storing system water and producing hydroelectric power. These reservoirs, however, previously played a relatively small role in the operation of federal reservoirs of the Colorado River Basin (Basin) as a whole. The focus of the Basinโs competing interests has primarily been on operation of Glen Canyon Dam and Hoover Dam that form Lake Powell and Lake Mead, respectively. These two reservoirs are the largest in the United States and presently store approximately 66% of all the water in the 12 federal reservoirs reported in Reclamationโs 24-Month Studies. During the debate and development of major policy actions for the Colorado River, such as the 1970 Coordinated Long-Range Operating Criteria,โธ 2001 Interim Surplus Guidelines,โน and the 2007 Interim Guidelines,ยนโฐ the operations of the UIUs were barely mentioned. However, as storage in Lake Powell and Lake Mead has declined, the importance of the UIUs has increased.
The Bureau of Reclamation (Reclamation) operates each of the three UIUs under separate Records of Decision (ROD). Each is operated in a manner that balances many competing interests such as: storage for 1922 Compact compliance, the delivery of stored water for Upper Basin consumptive uses, the delivery of water in fulfillment of Tribal water right settlement obligations, flood control, hydropower generation, on-reservoir recreation, downstream river recreation, sport fisheries in the reservoir and in the stream below the reservoir, and the flow needs of threatened and endangered fishes. Reclamation operates the UIUs in a transparent manner, and each has a local constituency that is closely involved in how their project is operated.
The UIU obscurity honeymoon ended in 2019 when the Upper Division States proposed what became the Drought Response Operations Agreement (DROA) as a component of their 2019 Drought Contingency Plan.ยนยน Arguably, under federal law, the Secretary of the Interior (Secretary) has broad authority to unilaterally move water from the UIUs downstream to Lake Powell. However, Reclamation took a more collaborative approach in the DROA: it was an inter-governmental agreement among the US (through Reclamation) and the states of Colorado, New Mexico, Utah, and Wyoming. DROA authorized releases from the UIUs to the extent necessary to achieve the stated operational objective of minimizing the risk of Lake Powell falling below a target elevation of 3525 ft, and thereby:
- helping to ensure the Upper Division States will continue fulfilling their interstate water compact obligations while exercising their rights to develop and utilize the Upper Basinโs Compact apportionment,
- maintaining the ability to generate hydropower at Glen Canyon Dam, and
- minimizing adverse effects on resources and infrastructure in the Upper Basin.ยนยฒ
DROA is subject to numerous constraints, including:
- Water available in the UIU reservoirs,
- Protection of authorized purposes of each CRSP unit (water supply, endangered species, recreation, hydropower, etc.),
- Consultation with the Upper Division States and the Upper Colorado River Commission, and
- Operating criteria established in the agreement and the associated Records of Decision.
In 2021, a total of 181,000 acre-feet of DROA releases were planned pursuant to the Secretaryโs emergency authority: 125,000 acre-feet from Flaming Gorge, 36,000 acre-feet from Blue Mesa, and 20,000 acre-feet from Navajo. Due to dry conditions, the 20,000 acre-feet release from Navajo Reservoir was cancelled, resulting in a total release of 161,000 acre-feet.ยนยณ DROA was implemented again in 2022 pursuant to consultation and agreement with the Upper Division Statesโapproximately 463,000 acre-feet of water from Flaming Gorge Reservoir were released. Both releases were intended to help maintain an operational target elevation of 3525 ft in Lake Powell.ยนโด The DROA water released from Flaming Gorge Reservoir and Blue Mesa Reservoir in 2021 and 2022 was completely recovered after the moderately wet winter of 2023.ยนโต DROA includes specific provisions addressing storage recovery after a DROA release is made. DROA expires contemporaneously with the 2007 Guidelines, but operations to recover storage releases made before Oct. 1, 2026, continue for as long as necessary.ยนโถ
In response to the near-record low 2026 runoff and the unprecedented low reservoir levels in Lake Mead and Lake Powell, DROA releases were again implemented to supplement Lake Powell levels, and this time with even greater urgency and impact. To help maintain the elevation of Lake Powell above 3500 ft, on April 23, 2026, Reclamation began making additional DROA releases from Flaming Gorge Reservoir.ยนโท According to the September 2026 24-Month Study, the planned release from Flaming Gorge will total one million acre-feet between April 2026 and April 2027, but Reclamation retains the flexibility to adjust the timing and amount based on actual hydrologic conditions. Citing contractual obligations and unusually low storage, there are no planned DROA releases scheduled for 2026 from either Blue Mesa Reservoir or Navajo Reservoir.ยนโธ
As annual Colorado River Basin runoff in the 21st century is consistently lower than in the 20th century and the โRatchet Effectโ is evident in reservoir storage basin-wide, disputes over the operation of the UIUs between the Upper Division States and Lower Division States have increased and indeed now are nearly as critical and strident as the disputes over water deliveries from Lake Powell to Lake Mead.ยนโน The Lower Division Statesโ May 1, 2026, Proposal for Short-Term Operations of the Colorado River included proposed operating criteria for the UIUs that would expand their role in maintaining Lake Powell elevations and effectively subordinate the refilling of the UIUs until there is sufficient water in Lake Powell to support the delivery of 8.23 MAF per year.ยฒโฐ The stated intent is โto share the benefit of improved hydrology between both basins.โยฒยน On May 13th, 2026, the director of the Arizona Department of Water Resources told the Arizona Re-Consultation Committee that under Arizonaโs interpretation of the Law of the River, the 1956 CRSPA specifically subordinates the delivery of contract water from the UIUs and the refilling of those reservoirs to water deliveries to the Lower Basin and Mexico under the 1922 Compact.ยฒยฒ
The Upper Division States believe the operation of the UIUs proposed by the Lower Division States is outside the scope of the Post-2026 NEPA process and cannot be incorporated into the Record of Decision as part of the 2027โ2028 operations plan.ยฒยณ Further, some UCRC commissioners pointed out that under the 1956 CRSPA, there are multiple purposes of the UIUs including supporting consumptive uses within the Upper Basin.ยฒโด At the 2026 Getches-Wilkinson Center Conference on the Colorado River, then-Acting Reclamation Commissioner Scott Cameron noted that Reclamation would aggressively operate the UIUs under their RODs to help manage Lake Powell levels, but added that the Secretary has, and will use, if necessary, emergency authorities to operate the UIUs outside the bounds of their RODs.ยฒโต
The Record of Decision (ROD) released on August 21, 2026, for the “Decision Framework for Colorado River Guidelines: Coordinated Operations of Lake Powell and Lake Mead (2027โ2036)” addressed the operation of the UIUs in a general manner. The ROD states:
โIn carrying out the Decision Framework, the Department will continue to coordinate the operation of Lake Powell, Lake Mead, and the Colorado River Storage Project (CRSP) Upper Initial Units โ specific reservoirs above Lake Powell โ pursuant to Section 602 of the Colorado River Basin Project Act of 1968 (CRBPA). Consistent with each facilityโs existing ROD, the CRSP Upper Initial Units remain an operational tool available to the Secretary, when necessary, to release additional water to increase the elevation at Lake Powell to protect critical Federal infrastructure.โยฒโถ
While the Decision Framework Operational Sideboards of the ROD include the โPotential for maximum use of CRSP Upper Initial Units within their respective RODs to release additional water if needed to protect critical infrastructure,โ they also allow for greater releases than described in their respective RODs:
“The Decision Framework establishes consultation thresholds associated with critical reservoir elevations. When projected reservoir conditions approach or fall below the consultation thresholds identified in the operational sideboards, the Secretary will coordinate and consult with the Basin States, Basin Tribes and other affected parties, as appropriate, regarding additional operational actions that may be appropriate to reduce risks to critical Federal infrastructure and maintain system reliability.ยฒโท”
Further, โSuch consultations may include consideration of additional reductions in water use, adjustments to coordinated reservoir operations of Lake Powell and Lake Mead, use of the CRSP Upper Initial Units, or other operational actions.โยฒโธ
Notably, the Decision Framework does not mention using the UIUs for making deliveries of water to Lee Ferry when there is insufficient water in Lake Powell for compliance with the 1922 Colorado River Compact (1922 Compact).
UIU storage recovery timing and amounts are not specified in the 2027-2028 Operating Guidelines,ยฒโน but Interiorโs response to the Lower Basinโs May 1st proposal stated that it:
“intends to refill the UIUs as soon as practicable to ensure water remains available for any additional infrastructure protection releases, while avoiding further risk to critical infrastructure during recovery operations. Based on prior operational experience, recovery operations were initiated once Lake Powell was no longer projected to continue declining. Reclamation would apply a similar approach for future UIU recovery operations and would consider actual hydrology and Basin-wide conditions before initiating recovery actions.ยณโฐ”
What is clear is that the water stored in the UIUs is an increasingly important resource coveted by the Upper Division States, the Lower Division States, Basin Tribes,ยณยน and Reclamation. It is also clear that each of these entities has a different perspective on the priorities under which the UIUs will be operated in the future. But it is important to recognize that while the water released by the UIUs in 2021, 2022, and 2026 provided critical benefits, especially for maintaining Lake Powell above target thresholds, DROA-like releases are not a solution to the Basinโs fundamental problem โ systematic use of more than the available water supply. The operation of the UIUs may buy time and provide additional flexibility for reservoir system management, but it does not create any new water.
The debate over the future use of the UIUs has also exposed and amplified several long-standing disputes over the interpretation of the key provisions of the Law of the River,ยณยฒ and ambiguities in the major federal legislation that authorized the construction and operation of the riverโs major federal reservoirs. A primary disputed issue facing the Colorado River Basin today is how much water must flow at Lee Ferry to satisfy the Upper Division Statesโ 1922 Compact obligations. As stated above, delivering water to Lee Ferry was a core purpose for both Lake Powell and the three UIUs.ยณยณ
On August 24, 2026, the state of Nevada, the Colorado River Commission of Nevada, and the Southern Nevada Water Authority filed a complaint for declaratory action and injunctive relief requesting a declaration that the ROD, Final Environmental Impact Statement, and 2027-2028 Guidelines are in violation of the Administrative Procedure Act, the National Environmental Policy Act (NEPA), and the Law of the River.ยณโด The complaint requests an injunction halting the implementation of the ROD and Operating Guidelines. Among other arguments, the plaintiffs claim that the Secretary failed to consider the exercise of authority to operate the UIUs in compliance with the Law of the River and NEPA.
The ROD states that the UIUs will be the subject of a new DROA agreement (referred to as a โframeworkโ) that is currently being negotiated among Reclamation and the Upper Division States. This proposed agreement, drafts of which have not been released to the public, has already received criticism from the State of Arizona. If finalized, it could also be the subject of future litigation.ยณโต In the remainder of the paper, we explore the history of the UIUs from their conception to the present day to provide context and rationale for future operations.

*ย Retired General Manager, Colorado River Water Conservation District.
โ ย Senior Fellow, Getches-Wilkinson Center, University of Colorado Law School; former US Commissioner, Upper Colorado River Commission; former Assistant Secretary for Water and Science, US Dept. of the Interior.
โกย Center for Colorado River Studies, Utah State University; former Chief, Grand Canyon Monitoring and Research Center.
ยงย Director of Research, Kyl Center for Water Policy, Arizona State University; former Director, Phoenix Water Services.
**ย Staff Attorney, Utton Transboundary Resources Center, University of New Mexico.
1 The position of the Lower Division States is that the Upper Division States must not deplete the ten-year flow at Lee Ferry below 75 MAF PLUS deliver half of the annual treaty delivery to Mexico. The normal treaty delivery is 1.5 MAF, so the total ten-year delivery obligation could be 82.5 MAF. In recent years, under Minutes 323 and 330, the annual delivery has been less, but because these Minutes also create water that Mexico can store โ calculating how much delivery the Upper Division States must share is not a simple matter. In any event, however, it appears that 81.2 MAF is less than the required 10-year flow pursuant to the Lower Division Statesโ legal position.
1 The Upper Division States do not agree that their obligation to Mexico under Article III(c) of the 1922 Compact is half of the annual delivery to Mexico under the 1944 Treaty every year. For more information, see Eric Kuhn, et. al, The 1922 Compact is Now the Obvious Elephant in the Negotiating Room, Oct. 6, 2025, https://www.colorado.edu/center/gwc/media/707.
2 This paper describes the authorization of the UIUs, the events leading up to that authorization, and some of the debate that resulted in the compromises in the 1956 Colorado River Storage Project Act (1956 CRSPA). The authors recognize that there are several detailed histories of CRSPA that address different aspects of its origins and come from a different perspective. Among these are: MARC REISNER. CADILLAC DESERT: THE AMERICAN WEST AND ITS DISAPPEARING WATER (1986, Viking Press); M. HARVEY, A SYMBOL OF WILDERNESS: ECHO PARK AND THE AMERICAN CONSERVATION MOVEMENT (Univ. N.M. Press 1994, 2nd Ed. Univ. of W.A. Press, 2000). Recognizing the value and insights of these previous works, this paper seeks to place the UIUs and their origins within the context of todayโs hydrology and disputes.
3 P.L. 84-485, 70 Statute 105, 43 U.S.C. ยง 620 et seq.
4 The provision of hydroelectric power and resulting revenues prompted the label โcash register damโ to refer to projects in which the hydropower receipts finance other project construction. Long-Term Drought and Glen Canyon Dam: Potential Effects on Water Deliveries and Hydropower, Congressional Rsch. Serv., Apr. 4, 2023, at 4.
5 1956 CRSPA Preamble.
6 The three reservoirs in the Aspinall Unit are Blue Mesa, Morrow Point, and Crystal. Only Blue Mesa is operated for river regulation and storage. Future references to storage in the UIUs include Blue Mesa, Flaming Gorge and Navajo Reservoirs, but not Morrow Point and Crystal Reservoirs. A number of additional reservoirs were authorized by the 1956 CRSPA (and subsequent federal legislation) as components of participating projects. All of these reservoirs have specific project functions. Several of these reservoirs store a significant amount of water. Strawberry Reservoir, a component of the Central Utah Project, McPhee Reservoir, a component of the Dolores Project, and Fontanelle Reservoir, a component of the Seedskadee Project are three prominent examples.
7 The data sources for this paper are primarily the Hydrologic Database (HDB) and the 24-Month Studies, both maintained or prepared by the U.S. Bureau of Reclamation. We use โlive storageโ to mean the amount of storage reported in the HDB or alternately, the 24-Month studies. The standard terminology for reservoirs is that live storage is the amount that can be physically withdrawn or released downstream. Active storage is the amount above the power plant penstocks (or primary outlet works for Navajo Reservoir). Inactive storage is the amount between the power plant inlets, and the low-level outlet works. Below the low-level outlet is the โdead pool.โ In theory, live storage = active plus inactive storage. In practice, however, each reservoir has a different design and different management issues. It is possible that some live storage may not be accessible for downstream delivery and use. The figures provided for live and active storage in the UIUs do not include Crystal and Morrow Point reservoirs.
8 For more information on the 1970 Long Range Operating Criteria, see https://www.usbr.gov/lc/region/pao/pdfiles/opcriter2005FRN.pdf.
9 The Colorado River Interim Surplus Criteria were adopted in 2001, but were superseded by the 2007 Interim Guidelines, see https://www.usbr.gov/lc/region/g4000/surplus/pdf/Attachments/Attachment_I.pdf.
10 U.S. Bureau of Reclamation, Colorado River Interim Guidelines for Lower Basin Shortages and the Coordinated Operations for Lake Powell and Lake Mead, December 2007, https://www.usbr.gov/lc/region/programs/strategies/RecordofDecision.pdf.
11ย U.S. Bureau of Reclamation, 2019 Drought Response Operations Agreement, https://www.usbr.gov/ColoradoRiverBasin/dcp/droa.html.
12ย DROA, Sec. I.A.
13ย Upper Colorado River Commission (UCRC) Seventy-Third Annual Report (2022), pages 16-17.
14 UCRC Seventy-Fourth Annual Report (2023), page 15. With the DROA releases, Lake Powell reached a low of 3519.92 ft. (MSL), in early April 2023.
15 UCRC Seventy-Fifth Annual Report (2024), page 15. With an estimated natural flow of 17.3 MAF, 2023 was the third wettest year since 2000. We refer to it as a moderately wet year based on comparisons with the 20th Century record. With a natural flow of 17.3 MAF, it is about the same as the ten-year average from 1980-1989 โ 17.2 MAF. USBR natural flow database, https://www.usbr.gov/lc/region/g4000/NaturalFlow/index.html.
16 DROA, Sec. II.A.6.
17 U.S. Bureau of Reclamation, 2026 Drought Response Operations Plan, https://www.usbr.gov/ColoradoRiverBasin/documents/dcp/DROA/2026/uc-2026droughtresponseoperationsplan-attachmentsa-h-508-20260423.pdf. Two measures were put in place to maintain the elevation of Lake Powell above 3500 ft. The 1.0 MAF of DROA releases and a reduction of the Water Year 2026 annual release from Glen Canyon Dam from 7.5 MAF to 6.0 MAF.
18 Id.
19 For an explanation of the Ratchet Effect, see Schmidt et al., The Colorado River Water Supply Crisis in a Few Graphs: Part 1 at 8 (June 2026), https://www.colorado.edu/center/gwc/2026/06/18/colorado-river-water-supply-crisis-few-graphs-part-1.
20 Lower Division Statesโ Proposal for Short-Term Operations of the Colorado River, May 1, 2026, https://www.azwater.gov/sites/default/files/2026-05/2026.05.01%20LB2YearPlanFINAL.pdf.
21 Memo from John Entsminger to Andrea Travnicek, Subject: Lower Division Statesโ Proposal for 2026โ2028 Colorado River Operations, Dated May 1, 2026.
22 AWDR presentation at the ARC Meeting May13, 2026, slide #9, https://www.azwater.gov/sites/default/files/2026-05/2026.05.13%20ARC%20Meeting%20%2313%20FINAL_0.pdf.
23 Letter from UCRC Executive Director Cullom to Acting Commissioner Cullom, dated June 1, 2026, http://www.ucrcommission.com/wp-content/uploads/2026/06/UDS-response-to-BOR-response-to-LB-concept-June-1-2026.pdf.
24 Comments of the individual UCRC commissioners at the April 26, 2026, special meeting of the UCRC where it reluctantly approved the DROA plan.
25 Scott Cameron, Bureau of Reclamation presentation, 2026 GWC Conference, https://www.colorado.edu/center/gwc/2026/06/04/june-4-5-2026-conference-colorado-river.
26ย U.S. Bureau of Reclamation, Record of Decision, Framework for Colorado River Guidelines: Coordinated Operations of Lake Powell and Lake Mead (2027-2036) August 2026, https://www.usbr.gov/ColoradoRiverBasin/post2026/decision-doc/P26_RecordofDecision_Final.pdf.
27ย ROD at 30.
28ย ROD at 27, 30.
29 U.S. Bureau of Reclamation, 2027-2028 Operating Guidelines, https://www.usbr.gov/ColoradoRiverBasin/post2026/decision-doc/2027-2028OperatingGuidelines_Final.pdf.
30 Department Response to Lower Division Statesโ Proposal for 2027-2028 Colorado River Operations, May 28, 2026.
31 The Ute Mountain Ute Tribe, Southern Ute Indian Tribe, Jicarilla Apache Nation, and Navajo Nation each have significant and unique interests in the operation of Navajo Reservoir. The Ute Indian Tribe of the Uintah and Ouray Reservation has asserted claims to water stored in Flaming Gorge Reservoir.
32 The Law of the River is a complex set of agreements, treaties, court decisions, and regulations that govern the allocation and use of water resources in the Colorado River Basin. A Colorado River Overview: Education, Facts & Statistics, https://coloradoriver.com/statistics-facts/.
33 1956 CRSPA, supra note 3.
ยณโด Nevada v. Burgum, et al, U.S. District Court, District of Nevada, Case 2:26-cv-02665, filed 08/24/2026. See also, https://mavensnotebook.com/2026/08/25/courthouse-news-nevada-files-suit-over-colorado-river-plan/; https://www.gov.nv.gov/press-releases/nevada-files-lawsuit-against-department-of-the-interior-over-colorado-river-operations-record-of-decision.
ยณโต The term โframeworkโ to describe the new DROA was used by the UCRC at its Sept. 15, 2026, Special Meeting. The comments by Tom Buschatzke were made at the August 24, 2026, meeting of the Arizona Reconsultation Committee.


















































































































































































































