Click the link to read the article on the Western Resource Advocates website (John Berggren):

August 31, 2026

• Communities across the West have been anxiously waiting for a plan to manage the Colorado River. The states that share the river have been unable to reach an agreement over how to manage it, forcing the federal government to move forward without one.
• The U.S. Bureau of Reclamation recently published a management framework for the next 10 years.
• This is not the long-term agreement many had hoped for, but it does leave room for collaborative solutions.

Communities across the West have been anxiously waiting for a plan to manage their water supply from the Colorado River. They watched as the states that share the river talked in circles behind closed doors. They attended conferences where state negotiators repeated the same tired arguments, did not present together, or were entirely absent.

Outside the conference rooms, conditions on the ground were deteriorating. The Colorado River Basin experienced its warmest winter on record. The meager snowpack in the mountains was sucked into parched soils, rivers dwindled, and the Basin’s two major reservoirs hit record lows.

And the situation continues to worsen.

While negotiators were struggling to find consensus, farmers were fallowing fields, raft guides were staring down an uncertain season, neighbors were reporting each other for overwatering, families were discovering that their favorite fishing spots had closed, and municipalities were on the hunt for alternative water supplies.

Three years ago, the U.S Bureau of Reclamation set out to work with the Basin states, Tribes, and stakeholders on a 20-year management plan for the Colorado River. But the states never reached a long-term agreement, forcing the federal government to move forward without one.

On Aug. 21, Reclamation published a framework for managing the river over the next 10 years. While it is not the long-term agreement many had hoped for, it does leave room for collaborative solutions.

What happens next will shape the river for generations.

What Is the Record of Decision?

A Decision-Making Framework

The record of decision lays out a 10-year framework for managing the river.

Under this framework, the Bureau of Reclamation will issue preliminary guidelines every two years for operating the river’s reservoirs and distributing shortages. Those guidelines will inform Reclamation’s annual plan for the river, which will be released every summer. Reclamation can adjust that plan each April depending on the winter’s snowpack and current reservoir levels. It is a tedious process, but one that allows the agency to modify operations as river conditions change.

State officials have raised concerns that the two-year framework will result in never-ending negotiations while making it difficult to plan ahead and finance solutions. These are valid concerns, but there is an off-ramp. If the states collaborate, they could replace the framework with a long-term deal that provides more certainty to their constituents and removes the need for prolonged negotiations.

A Plan for Managing Water Shortages

In addition to the record of decision, Reclamation issued operating guidelines for 2027 and 2028. These guidelines outline Lake Powell and Lake Mead operations and include shortages the Lower Basin offered earlier this year. Under the guidelines, the Lower Basin will reduce its use of the Colorado River by 1.25 million acre-feet in both 2027 and 2028. It will also pursue 700,000 acre-feet in additional conservation by 2028.

The record of decision allows Reclamation to impose even deeper cuts on the Lower Basin — up to 3 million acre-feet per year — if Lake Mead starts to approach the minimum levels needed to produce hydropower and to avoid hitting deadpool.

Reclamation is not mandating cuts in the Upper Basin because its authority to do so is less clear. But that doesn’t mean conservation isn’t urgently needed in the Upper Basin. In the record of decision, Reclamation includes up to 200,000 acre-feet of voluntary conservation each year collectively by Colorado, New Mexico, Utah, and Wyoming.

While this conservation is considered voluntary, it is in the Upper Basin’s best interest to be part of the solution. Flows on the Colorado River have declined by over 30% since 2020.  The river will continue to be on a knife’s edge unless everyone contributes.

By saving water now, the Upper Basin can help keep things from getting worse and reduce the need for emergency releases from upstream reservoirs to prop up Lake Powell. This can help rebuild storage and support the outdoor recreation economy in places like Flaming Gorge in Utah and Blue Mesa in Colorado.

Conservation in the Upper Basin can also help avoid expensive and risky legal battles over the river. The 1922 Colorado River Compact says that the Upper Basin will not cause the flow of the river to be depleted below a certain amount over a 10-year period. The Upper Basin argues that this volume is 75 million acre-feet. The Lower Basin says the amount includes water deliveries for Mexico and is set at 82.5 million acre-feet. We could hit the 82.5 trip wire as soon as this fall, potentially triggering litigation from the Lower Basin. Such a dispute would likely cost taxpayers millions of dollars, take years to resolve, and leave the river’s future in the hands of the U.S. Supreme Court. If the Lower Basin prevails, water users in the Upper Basin could see drastic cuts to their supply and little time to implement solutions or secure funding to ease the pain.

The four Upper Basin states are at various stages of developing programs to pay water users to decrease their consumption. WRA is advocating for long-term programs that prioritize projects that keep rivers healthy.

Is the Latest Plan Enough?

Reclamation’s models show that the reductions planned for the next two years will just barely allow the Basin to scrape by. In the worst-case scenario, the Basin could drain its accessible water savings in Lake Powell. The only water left would be what flows in the river, and that is nowhere near enough to meet current demands.

What’s Next?

Implementing Solutions or Handing the Reins to the Supreme Court

The Basin states have an important decision before them — implement the new guidelines and work toward a long-term deal or take their chances in court.

Nevada was the first to take the plunge. Three days after Reclamation released the record of decision, Nevada filed a lawsuit against the U.S. Department of the Interior and Bureau of Reclamation. The state claims that the plan and the potential cuts to Nevada’s water supply violate federal law and seeks to halt its implementation.

Nevada’s lawsuit underscores the need for a deal that all seven states can agree to, rather than a plan imposed by the federal government. There is still an opportunity to reach such an agreement — the Nevada case does not preclude the seven states from continuing to negotiate or from entering into agreements to stabilize the river.

The states must not let this one case spiral out of control. Litigation between all seven Basin states over the Colorado River Compact would make things much worse.

History shows that multistate water disputes can take at least a decade to be resolved and often have unintended consequences. Arizona v. California, a dispute over Colorado River allocations in the Lower Basin, began in 1952 and was not resolved until 1963. The court settled the disagreement over water allocations and ruled that the Secretary of the Interior has broad authority to act as watermaster in the Lower Basin — giving the federal government greater control over Lower Basin water deliveries. Texas v. New Mexico, a dispute over the Rio Grande, went on for 13 years before reaching a resolution last spring. And a dispute between Kansas and Colorado over the Arkansas River was on-again, off-again for more than a century. The court ruled that Colorado was overusing water and awarded both water and monetary damages to Kansas. And these cases all involved two states — not seven.

The Colorado River does not have decades. Researchers predict that it will only take one more dry winter to drain the Basin’s accessible water savings.

On top of lost time, state litigation over the 1922 Compact would cost millions of dollars — money that is better spent implementing conservation programs, restoring watersheds, and increasing water efficiency. And litigation would leave decisions with the Supreme Court, not the communities that depend on the river and know it best.

Nevada’s lawsuit against the federal government does not change the fact that we have a river to manage. New guidelines are still needed by Oct. 1. The decision-making process must continue and the Basin states must act now to prevent a seven-state legal brawl.

In the coming months WRA will be advocating for:

• Protections for the river: Protecting river health and our communities are two sides of the same coin. The day-to-day operations of the river’s reservoirs affect everything from fish habitat to hydropower production to local water supplies and outdoor recreation. Operating guidelines must consider the full range of impacts and incorporate policies that maximize benefits for both our communities and the environment.
• Transparent decision making: The record of decision includes a plan for issuing new operating guidelines every two years. Those guidelines will affect 35 million people and must not be developed behind closed doors. A clear public process is needed to incorporate input from the Basin states, Tribes, Mexico, water users, communities, scientists, and conservation organizations.
• Sustained federal funding: Federal funding will be critical to implementing the changes that are needed to secure the West’s future, including restoring watershed health and incentivizing water use reductions. The river that supplies water to 1 in 10 Americans is worthy of federal investment.
• Equitable water access and Tribal inclusion: The 30 federally recognized Tribes in the Colorado River Basin have long been excluded from key decisions and denied their fair share of the river’s water. The new guidelines and programs must uphold Tribal water rights and provide clear pathways for Tribal collaboration.
• State collaboration: The states have been talking past each other for the last three years and it’s resulted in a federal management plan that few decision makers are happy with, and one state has already filed a lawsuit on. It is time to try a new approach before things get worse. The states must enlist the help of a professional mediator who can facilitate more productive negotiations. And the states must finalize and sign implementation plans — like the Lower Basin’s proposal to reduce its water use by 1.25 million-acre feet in 2027 and 2028 — as soon as possible.
• Basinwide collaboration: Many of the river’s most successful programs — including those that restored hundreds of miles of fish habitat and put tens of millions of dollars toward water conservation — were the result of collaborations between states, federal agencies, Tribal nations, water users, conservation organizations, and others. The challenges the river faces are growing. We must accelerate our efforts, build new partnerships, launch new programs, increase investment, and expand on successful initiatives.

The record of decision has set the stage, now it is time for the river’s next act.

Click the link to read the report on the University of New Mexico Digital Repository website (Jack Schmidt¹, Anne Castle², Eric Kuhn³, Kathryn Sorensen⁴, Katherine Tara⁵):

September 2, 2026

KEY POINTS

• Reductions in Lower Basin water use during the last four years, including forecast use in 2026, are similar to the initial targets for Lower Basin shortages described in the Final Environmental Impact Statement for Post-2026 Operational Guidelines and Strategies for Lake Powell and Lake Mead (FEIS) and the accompanying Record of Decision (ROD). ⁶ Lower Basin consumptive use in 2023, 2024, and 2025, and forecast for 2026 has been the smallest for the entire 2010-2026 period. These four years of smallest use are between 1.4 and 1.7 million acre feet/year (maf/yr) less than the 7.50 maf/yr amount generally recognized as the Lower Basin’s mainstem allocation.
• Reductions in Lower Basin use have been achieved by large reductions implemented by Central Arizona Project (CAP) contractors and subcontractors, the Imperial Irrigation District (IID), and non-CAP water users in Arizona. The reductions in use in the IID have been in summer water use and have not affected consumptive use in winter when garden crops, such ass lettuce, onions, carrots, and broccoli, are grown.
• There is no historical analogy for implementing Lower Basin shortages of 3 maf/yr that would reduce annual consumptive water use to 4.5 maf/yr. We identified the lowest use in each month between 2010 and 2026 in each Lower Basin state and summed those monthly values, even when those months did not occur in the same year. The annual total of the summed lowest monthly uses yielded a minimum total Lower Basin use of 5.03 maf/yr. Thus, implementation of 3 maf/yr shortages would require reductions in monthly use greater than the sum of the smallest monthly uses during the past 17 years.

INTRODUCTION

This paper is part of a series, The Colorado River Water Supply Crisis in a Few Graphs, whose goal is to provide readers with summary information about the natural water supply, reservoir storage, and consumptive uses and losses in the Basin so that readers can better understand and consider the current water crisis. The long-term fate of the water supply provided by the Colorado River depends on many complex and interconnected factors: the natural flow of the river, the amount of water stored in the Basin’s reservoirs, the consumptive uses of that water, the losses caused by reservoir evaporation, and the losses associated with water flowing through natural channels (i.e., transmission losses).

In 2024, approximately 60% of all uses and losses of Colorado River water in the United States occurred in the Lower Basin (Table 1).⁷ In this paper, we summarize water use in the Lower Basin since 2010, primarily focusing on consumption by the Imperial Irrigation District (IID), the largest user in the entire Colorado River Basin, and on the aggregate consumption by Arizona users not served by the Central Arizona Project (CAP). We focus on these agricultural users, because agriculture makes up approximately 60% of consumptive uses in the Lower Basin,⁸ and the agricultural sector will play a significant role in future reductions in water use in the Lower Basin.

This paper provides historical context in which to consider the magnitude of recent reductions in Lower Basin water use by comparing current water use with typical rates of use since 2010. We also provide historical context for the shortage goals described in the recently released ROD and Operating Guidelines for 2027 and 2028. ¹⁰ The ROD lists a potential maximum Lower Basin reduction of 3.0 maf/yr but also includes language that seems to allow for even greater reductions, after consultation, in extraordinary circumstances.

We analyze the Lower Basin water use data summarized by the Bureau of Reclamation in annual decree accounting reports formally titled Colorado River Accounting and Water Use Report: Arizona, California, and Nevada.¹¹ These reports are issued each May and summarize monthly water use by every Lower Basin user. Reclamation also provides monthly provisional data on the current year’s water use, and the agency provides forecasts of annual use for the current year.¹² Similarly extensive and precise data describing Upper Basin use are not readily available.

Lake Mead and Lake Powell are the largest reservoirs in the United States and essentially are one gigantic reservoir separated into two parts by the Grand Canyon.¹³ Inflow to this gigantic reservoir primarily is snowmelt from the Rocky Mountains, and a significant amount of that runoff is put to beneficial use by Upper Basin users before it reaches Lake Powell. A small amount of additional inflow occurs within the Grand Canyon, and there are occasional inflows to Lake Mead from the Virgin River. Southern Nevada Water Authority directly withdraws water from Lake Mead, and other Lower Basin users divert stream flow after it is released from Lake Mead.

RECENT LOWER BASIN WATER USE

In 2025, total consumptive use in the three Lower Basin states was 5.755 maf, the smallest annual total use since at least 2010 (Fig. 1) and 17% less than the average for 2010-2025.¹⁴ This small amount resulted from the lowest annual use in California (3.647 maf) since at least 2010 and the second lowest annual use since 2010 in Arizona (1.911 maf). Lower Basin use in 2026, 5.961 maf, is forecast to be slightly more than in 2025.¹⁵

Water use in California since 2023, including forecast use in 2026, has been 13% less than between 2010 and 2022.¹⁶ Decreased use in California in those years has been primarily due to reductions in use by IID (Fig. 2). IID’s consumptive use of 2.187 maf in 2025 was the lowest since 2010 and forecast use in 2026 of 2.242 maf is also very low. Average use by IID between 2023 and 2026 will be 12% less than average use between 2010 and 2022.¹⁷ Annual consumptive use by the Metropolitan Water District of Southern California (MWD) between 2023 and 2026 will be 13% less than between 2010 and 2022, although the savings are not as great because MWD uses less water than does IID.¹⁸

The proportionate reductions in water use in Arizona have been much larger than in California. Average statewide water use between 2023 and 2026 will be 25% less than between 2010 and 2022.¹⁹ CAP has reduced its uses by 40% between those two time periods, while non-CAP users have reduced consumption by 6%. The smallest use by Arizona was 1.890 maf in 2023 (Fig. 3). Use in 2025 by non-CAP customers, 1.004 maf, was the lowest since at least 2010. Non-CAP use has exceeded CAP use since 2022.

LOWER BASIN AGRICULTURAL WATER USE

Imperial Irrigation District

IID is the largest individual user of mainstem Colorado River water in the Colorado River Basin, exceeding use by any state in the Basin except California itself. Much of California’s ongoing reductions in use are due to decreased use by IID resulting from various compensated agreements. Future reductions by IID have the potential to significantly affect the Basin’s effort to balance consumptive use with declining supply.

In comparison to typical annual use since 2010, IID’s use in 2024 and 2025, as well as forecast use in 2026, has been notably reduced, as represented in a box-and-whisker plot (Fig. 4).²⁰ The box in Figure 4 encloses 50% of the years since 2010, and the length of this box is called the Inter Quartile Range (IQR), bounded by the 25th and 75th percentile of the 17 years of data, including forecast use in 2026. The line through the middle of the box is the median value for this period. Lines extending up and down from the box (i.e., whiskers) extend from the box to values within an acceptable range. Values that are greater than 1.5 times the IQR above the 75th percentile or below the 25th percentile are beyond the acceptable range and are outliers and individually plotted. Thus, 2024, 2025, and forecast use in 2026 are outliers, indicating that use in those years has been significantly less that typical use during the entire period since 2010.

The largest proportion of irrigated land in IID is devoted to field crop production, the largest proportion of which is devoted to alfalfa (Fig. 5).²¹ The area devoted to alfalfa production changes little from year to year and during the year and was approximately 150,000 acres in 2025.²² In 2025, other significant field crops were Bermuda grass and kleingrass, whose average irrigated area was 80,000 and 20,000 acres, respectively. The area devoted to garden crop production changes greatly throughout the year and is largest between November and March. Little land area is devoted to garden crop production in the heat of summer. The most significant garden crops are lettuce, onions, carrots, and broccoli.

Water use by IID is typically lowest between November and February when garden crops are grown (Fig. 6). Water use increases greatly in March and remains high through October when field crops are the primary focus of production (see Appendix).

Reductions in consumption during the past few years have been accomplished primarily by reduced water use between June and September when alfalfa and grass hay are the primary crops. These reductions are reflected in Figure 5 where red dots are the average monthly water use since 2024. Red dots plot below the grey boxes of the IQR in June, July, August, and September, demonstrating that recent water use in these months has been significantly less than typical since 2010. In contrast, recent water use between December and May has been within or slightly less than the IQR.

Agricultural use of mainstem Colorado River water in Arizona

We estimated agricultural use of mainstem Colorado River water in Arizona by subtracting the total diverted by the CAP from the total use in Arizona. This remainder includes all the agricultural uses along the Colorado River as well as a small amount used by the City of Yuma, other towns along the river, and military bases.²³

The monthly pattern of water use is similar to the monthly pattern by the IID. The smallest uses are between November and February (Fig. 7). Consumptive use increases in March and is highest between April and August.

Reductions in water use by these Arizona growers have been more modest than by IID. Recent average use has been somewhat less than the typical range between April and July and has been within the typical range in other months, except for November when there was significant precipitation near Yuma in 2025.

Management and Policy Implications

Consumptive water use of mainstem water in the Lower Basin has been less than 7.5 maf/yr in every year but one since 2010. Since 2023 including forecast use in 2026, this reduction ranged between 1.4 and 1.7 maf/yr. The Lower Basin states have reduced water use comparable to the initial targets for Lower Basin shortages described in the recently released ROD²⁴ and Operating Guidelines for 2027 and 2028.²⁵ Thus, the good news is that the initial shortage goals of the FEIS have been achieved in recent years.

These savings have been achieved by large reductions in use by the CAP (Fig. 3) and by reduced agricultural water use in summer by IID (Fig. 6) and non-CAP water users in Arizona (Fig. 7). These reductions in agricultural water use have not resulted in changes of the amount of water consumed in winter when garden crops are grown.

The ROD allows for potentially large Lower Basin shortages of up to 3 maf/yr and potentially more in the event that Basin runoff continues to be low and reservoir live storage drops to critical levels. We placed these potential shortages in perspective by summing the smallest monthly use in each Lower Basin state since 2010 even though these months of smallest use did not occur in the same year. In some cases, the smallest water use was not due to significant water conservation but to unusually rainy conditions when demand for supplemental irrigation water was low, such as in November 2025. In other words, there is no historical experience with implementing the annual sum of these smallest monthly uses, because the smallest monthly uses did not occur in the same year.

Nevertheless, summing the lowest monthly use in each state provides perspective to the magnitude of the proposed 3 maf/yr shortages. The summed value of smallest monthly uses yields a potential minimum annual Lower Basin use of 5.03 maf/yr for the three Lower Basin states (Table 2). Although many of the months of smallest use occurred between 2022 and 2026, some were unique months of very low use in the 2010s. There is no historical analogy for imposition of the largest Lower Basin shortages envisioned by the recently released ROD and 2027-28 Operating Guidelines. [ed. emphasis mine]

CONCLUSION

The analyses summarized in this paper demonstrate that agricultural water use that supports winter garden crop production has not changed despite recent reductions in annual water use by IID or by non-CAP water users in Arizona. To date, water use by IID and by non-CAP water users in Arizona has been reduced in summer when garden crops are not grown. In times of acute water shortage, it is likely that continued and additional water savings can be achieved by reductions in irrigation of field crops in summer, without causing shortages to garden crop irrigation in the winter.

It is notable, however, that summing the lowest monthly water use in each state since 2010 results in a theoretical reduction from the Lower Basin allocation of 7.5 maf/yr of approximately 2.5 maf/yr, less than the maximum potential Lower Basin shortage envisioned in the recently released ROD. Our calculation of a theoretical shortage is based on summing the smallest use in each month between 2010 and 2026, and these months are not all in the same year. In some cases, the lowest use resulted from unusually large precipitation that reduced irrigation demand, rather than explicit conservation efforts.

The Priority Shortage Allocation Model utilized in the FEIS distributes shortages among the Lower Basin states in a much different manner than the way shortages have been achieved in the past.26 Tabulating the historical minimum monthly uses demonstrates that achieving the 3 maf/yr reductions described in the FEIS and ROD would be very difficult and is without historical precedent. Implementation of such large shortages would likely require new management policies, including compensated fallowing, permanent retirement of irrigated acreage and corresponding water rights, and unprecedented investment in increased irrigation efficiency.

We recognize that our theoretical comparison of minimum monthly uses since 2010 in no way captures the economic dislocation and secondary impacts that might result from implementing such shortages now. A full economic analysis of the impacts of the largest potential Lower Basin reductions described in the FEIS and the ROD is critical for understanding the consequences of significant reductions in water use in the Lower Basin. That type of analysis is beyond our expertise. Nevertheless, we recognize the importance of such an analysis, and we recognize the real-world distress that such large reductions of use might cause.

¹ Center for Colorado River Studies, Utah State University, former Chief, Grand Canyon Monitoring and Research Center.

² Getches-Wilkinson Center, Univ. of Colorado Law School, former US Commissioner, Upper Colorado River Commission, former Assistant Secretary for Water and Science, US Dept. of the Interior.

³ Retired General Manager, Colorado River Water Conservation District.

⁴ Kyl Center for Water Policy, Arizona State University, former Director, Phoenix Water Services.

⁵ Staff Attorney, Utton Transboundary Resources Center, University of New Mexico.

⁶ FEIS is available at https://www.usbr.gov/ColoradoRiverBasin/post2026/final-eis/index.html. ROD is available at https://www.usbr.gov/ColoradoRiverBasin/post2026/decision-doc/P26_RecordofDecision_Final.pdf.

⁷ All annual data in this paper are calendar year. 2024 is the most recent year that consumptive uses and losses data are available for the entire Basin.

⁸ Richter et al., 2024, New water accounting reveals why the Colorado River no longer reaches the sea. Communications Earth & Environment 5:134. available at https://www.nature.com/articles/s43247-024-01291

⁹ Upper Basin state uses in Table 1 do not include state reservoir evaporation. Total major and minor state reservoir evaporation is listed separately in Table 1. Colorado River Storage Project (CRSP) reservoir evaporation is evaporation from Blue Mesa, Morrow Point, Flaming Gorge, and Lake Powell reservoirs. Source of Upper Basin data: J. Prairie, Upper Colorado Basin Research and Modeling Group Chief, Bureau of Reclamation. Source of Lower Basin state uses: Reclamation. 2025. Water use report: Arizona, California, Nevada, calendar year 2024. Source of mainstem reservoir evaporation (Mead, Mohave, Havasu) data: S. Tighi, Hydrologist, Reclamation, Lower Colorado Region. Evaporation at Senator Wash and diversion dams estimated at 28,000 af.

¹⁰ Department of the Interior, August 2026, Operating Guidelines: Colorado River Guidelines for Coordinated Operations of Lake Powell and Lake Mead, Operating Years 2027 and 2028 (2027-28 Operating Guidelines), available at https://www.usbr.gov/ColoradoRiverBasin/post2026/decision-doc/2027-2028OperatingGuidelines_Final.pdf. We note that these Operating Guidelines provide for 1.25 maf/yr of shortage, allocated among the Lower Basin states as previously proposed: 760,000 af/yr in Arizona, 440,000 af/yr in California, and 50,000 af/yr in Nevada, The distribution of shortages greater than 1.25 maf/yr is not specified but would presumably be subject to consultation. See 2027-28 Operating Guidelines at 5.3.A. The ROD allows for the development of different methods of shortage allocation. See ROD at 5.

¹¹ Colorado River Water Accounting and Water Use Report: Arizona, California, and Nevada, available at https://www.usbr.gov/lc/region/g4000/wtracct.html.

¹² Lower Colorado River Water Accounting – Actual Water Use and Official Water Use Forecast, both available at https://www.usbr.gov/lc/region/g4000/wtracct.html. Throughout this paper, we refer to the forecast for 2026 that was made on September 1, 2026. The forecast is frequently revised.

¹³ There is no significant water use in the Grand Canyon.

¹⁴ Average Lower Basin consumptive use between 2010 and 2025 was 6.880 maf/yr.

¹⁵ Reclamation, Lower Colorado River Basin, available at https://www.usbr.gov/lc/region/g4000/hourly/forecast.pdf.

¹⁶ Average use between 2010 and 2022 was 4.326 maf/yr. Average use between 2023 and (forecasted) 2026 will be 3.764 maf/yr.

¹⁷ Average use between 2010 and 2022 was 2.600 maf/yr. Average use between 2023 and (forecasted) 2026 will be 2.290 maf/yr.

¹⁸ Average use between 2010 and 2022 was 925,000 af/yr. Average use between 2023 and (forecasted) 2026 will be 804,000 af/yr.

¹⁹ Average use between 2010 and 2022 was 2.590 maf/yr. Average use between 2023 and (forecasted) 2026 will be 1.930 maf/yr.

²⁰ IID used 2.187 maf in 2025, 2.312 maf in 2024, and is forecast to use 2.242 maf in 2026. Median use between 2010 and 2026 was 2.546 and use in 50% of the years of that period was between 2.481 and 2.558 maf/yr.

²¹ Imperial Irrigation District, 2025, written communication, Monthly crop acreage summary, 2011-2025.

²² Total net area of crops in 2025 was approximately 350,000 acres.

²³ Forecast use in 2026 for Bullhead City, Lake Havasu City, Parker, Yuma, U.S. Army Yuma Proving Grounds, and the U.S. Marine Corps Air Station Yuma is 35,000 af.

²⁴ Department of the Interior, August 2026, Record of Decision, Decision Framework for Colorado River Guidelines: Coordinated Operations of Lake Powell and Lake Mead (2027-2036), available at https://www.usbr.gov/ColoradoRiverBasin/post2026/decision-doc/P26_RecordofDecision_Final.pdf.

²⁵ Department of the Interior, August 2026, Operating Guidelines: Colorado River Guidelines for Coordinated Operations of Lake Powell and Lake Mead, Operating Years 2027 and 2028 (2027-28 Operating Guidelines), available at https://www.usbr.gov/ColoradoRiverBasin/post2026/decision-doc/2027-2028OperatingGuidelines_Final.pdf. We note that these Operating Guidelines provide for 1.25 maf of shortage in each year, allocated among the Lower Basin states as previously proposed: 760,000 af in Arizona, 440,000 af in California, and 50,000 af in Nevada. The distribution of shortage greater than 1.25 maf/yr is not specified but would presumably be the subject of consultation. See 2027-28 Operating Guidelines at 5.3.A. The ROD allows for the development of different methods of shortage allocation. See ROD at 5.

²⁶ See FEIS Appendix C, Shortage Allocation Model and Alternative Distribution Model Documentation, at C.4.2. However, the ROD specifies that other methods of shortage allocation may be developed. ROD at 5.

Click the link to read the article on the Grist website (Austin Corona):

August 28, 2026

Nevada officials have long presented themselves as a voice for compromise and conservation in debates over the Colorado River. The Las Vegas area, home to two-thirds of the state’s population and most of its economy, has become a model of urban water conservation. As the river has declined from overuse and a decades-long drought exacerbated by climate change, southern Nevada water planners built extensive water reuse facilities and implemented tight restrictions on new turf and fountains, dropping the region’s per capita water use by 58 percent in roughly 20 years. Meanwhile, in interstate negotiations over the management of the Colorado River, state representatives have positioned themselves as bridge-builders, sometimes referring to themselves as the “middle basin” between the river’s divided upper and lower basin states. 

When the federal government’s new management plan for the river was announced earlier this month, most observers thought Arizona, which stands to take the largest immediate cuts, would launch the first lawsuit over the plan’s implications for its water supplies. So it came as a surprise to many Colorado River experts when Nevada became the first to sue the federal government over the plan this week.

“I expected that there would be litigation, but it was surprising to me that Nevada fired the first shot,” said Anne Castle, former chair of the Upper Colorado River Commission.

Nevada’s lawsuit comes after more than two years of negotiations among the seven Colorado River states and the federal government over how to reduce water use on the declining river. The states failed to reach a long-term agreement before the river’s current management procedures expire in October, leaving the Interior Department to impose its own plan. The federal government’s plan largely relies on cuts to water use among the Lower Basin states — Arizona, Nevada, and California — to prop up water levels in the river’s largest reservoirs. Those reservoirs have been draining so quickly that the dwindling water depth could threaten hydropower and dam operations within months without intervention. 

Nevada argues that the federal government’s plan illegally forces it to take too much of those cuts. In a worst-case scenario, the plan could allow for a 71 percent cut to the Las Vegas area’s water supply, the state argued, calling it an unacceptable risk to the state’s largest population center and economic hub. Nevada believes this outcome results from a misreading of the law and also claims the government didn’t consider important alternatives to such drastic cuts.

This worst-case scenario, which experts say is an interpretation of the plan’s implications by Nevada, would become possible if reservoir levels continue to drop and if Nevada couldn’t reach an agreement with Arizona and California to help it absorb more of those cuts. Those three states already have such an agreement, which is incorporated into the federal plan and meant to last through 2028, at which point the plan allows the states to update the operations with a new agreement. Without an agreement, the federal government will implement cuts based on preexisting water rights and agreements, cutting the most from Arizona and leaning increasingly on Nevada and California as potential shortages increase. The plan was created through a decision-making process required under the National Environmental Policy Act, or NEPA, which mandates that federal agencies gather public input and consider environmental and socioeconomic impacts of major decisions.

Click the link to read the article on the InkStain website (Karl Flessa):

August 20, 2026

In the classic Monty Python sketch, a customer returns to the pet shop where, just 30 minutes ago, he purchased a parrot.  He complains that the parrot is dead.  The shopkeeper tries to convince the customer the parrot is only resting or is stunned. 

In the ensuing argument, the customer uses no fewer than eighteen euphemisms: “This parrot is definitely deceased…demised…passed on…no more…ceased to be…expired…gone to meet his maker…a stiff…bereft of life…rests in peace…pushing up the daisies…metabolic processes are now history…off the twig…kicked the bucket…shuffled off his mortal coil…run down the curtain…joined the bleedin’ choir invisible.”

Indeed, the parrot was nailed to its perch, already dead when the customer bought it.

The Compact and its subsequent agreements are as dead as that parrot.

• The Compact is dead because it is founded on a false premise: a river that can produce the prescribed amount of water.
• The Compact is dead because it is unjust: neither the Tribes nor nature participate in negotiations.
• The Compact is dead because it doesn’t work.  The Basin States are locked in battle; the Federal government tinkers and dithers.

In the longer version of the sketch, the shopkeeper goes to the back in search of a live replacement, returning to report “…we’re right out of parrots.”

So are we. 

We need a new Compact. 

Proposals are not lacking: proportional allocations, Tribal standing, a whole-basin approach, adjustments based on actual flows, a basin authority, nature’s fair share, interstate trading… .

What’s lacking is the courage to change. [ed. emphasis mine]

The Compact is a dead parrot.

Click the link to read the article on The Land Desk website (Jonathan P. Thompson):

August 25, 2026

THE NEWS: The U.S. Interior Department on Friday handed down the operating guidelines for the Colorado River for the next two years, while also finalizing the 10-year decision framework that will guide these plans. And on Monday, Nevada filed a lawsuit challenging both the framework and operating plan, saying that potential shortages required by the plan could cause “cause devastating environmental, socioeconomic, and health and human safety impacts to southern Nevada and its citizens.”

THE CONTEXT: Interior, i.e. the Bureau of Reclamation, did two things. The first was to hand down a record of decision on the framework that will guide operating plans for the next decade, which I wrote about here, so I’ll skip the details this time.

Feds release Colorado River plan, and no one’s very happy about it — Jonathan P. Thompson

They also released a more specific plan for the 2027 and 2028 operating years. In the new plan, the feds affirm their commitment to “defending” minimum power pool in Lake Powell, or a reservoir surface elevation of 3,490 feet. When the water falls below this level, water can no longer be released via the penstocks and hydropower turbines, so it must all go through the lower river outlet works, which weren’t designed for sustained use.

Notably, Reclamation plans to do this by “initially seeking to maintain a minimum elevation of 3,510 feet. This provides an operational buffer and provides additional flexibility in recognition of the operational risks associated with sustained operations below elevation 3,490 feet … .”

The current elevation is 3,518 feet, meaning it could reach that upper buffer zone of 3,510 feet in October if current levels of decline continue.

To prevent it from falling any further, Reclamation would cut back releases from Glen Canyon Dam, which in turn would cut flows through the Grand Canyon and into Lake Mead, which would pull down Mead’s levels and trigger mandatory cuts for the Lower Basin users. Under the new operating plan so far, these cuts aren’t as onerous as many feared, and actually match up with what the Lower Basin had proposed to do voluntarily. The deets:

• The Lower Basin would receive 6.25 million acre-feet from the Colorado River, or 1.25 MAF below the Colorado River Compact’s allotment of 7.5 MAF.
• Arizona would receive 2.04 MAF; California 3.96 MAF; and Nevada 250,000 AF.
• This means Arizona would take a 760,000 AF cut; Nevada a 50,000 AF cut; and California a 440,000 AF cut.

Arizona takes the largest cut by percentage and volume because the Central Arizona Project, which delivers most of the state’s Colorado River water, has junior water rights to other big users on the river.

But if reservoir levels continue to drop, then Reclamation could impose further cuts on the Lower Basin, potentially slashing Nevada’s water deliveries by as much as 213,556 acre-feet, or about 71% of its total entitlement of 300,000 acre-feet. This would be truly disastrous for the Las Vegas metro area, which relies on the Colorado River for about 90% of its water. And it’s not like there are a bunch of alfalfa fields the city could “buy and dry” for the water rights.

The Southern Nevada Water Authority has managed to cut overall water consumptionover the last three decades, even as the population has soared, through system-wide efficiencies, incentives, tearing up ornamental grass, water recycling, and extra fees for water gluttons. Las Vegas still has room to conserve, but as Western water scholar John Fleck put it, there “is an absurdity to a plan that would require Las Vegas to cut 71%. That’s existential.”

Even more astonishing than the fact that the federal government is considering virtually drying up one of the Southwest’s major metropolises is their justification for doing so: To protect Glen Canyon Dam and keep it producing hydropower, even at greatly diminished levels, and — though it’s not stated — to keep lake-based recreation somewhat viable.

Glen Canyon Dam hydropower: What’s it good for? — Jonathan P. Thompson

You have to remember that when the feds vow to defend the 3,500-foot level at Lake Powell, and when they refuse to even consider re-engineering Glen Canyon Dam to allow for releases at lower levels, either by rebuilding the outlet tubes or tunneling a bypass around the dam, they are also saying they are going to trap more than 4 million acre-feet of water behind the dam that could otherwise flow downstream into the Grand Canyon and Lake Mead. That’s enough water to fill Nevada’s entire allotment for more than 13 years that, instead, will be sitting in the reservoir and slowly evaporating. 

Nevada’s lawsuit — which is against the federal government, not the Upper Basin states — alleges that the feds’ plan violates the Law of the River. It slams the plan for not explicitly calling for releasing more water from Upper Basin reservoirs to prop up Powell, does not require Upper Basin states to make any cuts, and fails to consider a long-term alternative or engineered solution alternative to address Glen Canyon’s infrastructure limitations. The plan also does not account for its potential impacts on hydropower production at Hoover Dam, which drops off steeply as reservoir levels decline (meaning that preserving power output at Glen Canyon could lead to a net reduction in combined output from the two dams).

Save the Colorado, a river advocacy group, came out in support of Nevada’s lawsuit in a written statement. “Las Vegas has one of the best water conservation programs in the entire U.S.,” said Gary Wockner, the group’s executive director. “Penalizing Las Vegas for water use is like penalizing an obese person who lost a lot of weight taking GLP1s.”

A Colorado River glossary and primer — Jonathan P. Thompson

🌵 Public Lands 🌲

Rough Times at the national parks these days. In Bryce Canyon, a sudden thunderstorm left visitors stranded on trails and requiring rescue, with two of them transported to a hospital for hypothermia. It also unleashed some serious flash flooding. In Zion National Park, a rockslide narrowly missed a shuttle bus and forced the closure of a portion of the Zion Canyon Scenic Drive. And in Canyonlands, officials were searching for a missing individual in Horseshoe Canyon, a remote area north of the park’s Maze district. Temperatures in the area were in the 90s. In Death Valley, a French tourist died after his car got stuck in the mud on a remote road in 116° F heat.

The video below shows flooding near Tropic, Utah, downstream from Bryce Canyon National Park. Source: Garfield County Sheriff.

In May, I wrote about how climate change and aridification and a shrinking Lake Powell were coming for the Bullfrog Marina, on the northwest side of the reservoir. The water was simply getting too low for the marina to remain viable, so they were planning on moving it across the reservoir to Halls Crossing Marina. 

At the time, it was not yet clear how lower water levels and the marina’s removal might affect visitation to the remote area. Now preliminary numbers are in:

• 67,277: Total recreation visitors to the Bullfrog District of Glen Canyon National Recreation Area, January through July 2025
• 44,206: Total recreation visitors to the Bullfrog District, January through July 2026.

That’s a decrease of over 23,000 visits, or a 34% drop. Even more dramatic is the drop in overnight stays in July, from over 47,000 in 2025 to just 17,000 in 2026. Then did folks make the long drive over to Halls Crossing, instead? It appears that some of them may have once the marina was moved, but overall this year visitation is also down on the northeast side of the reservoir.

• 18,023: Total recreation visitors to the Halls Crossing District of Glen Canyon National Recreation Area, January through July 2025. 
• 15,099: Total recreation visitors to the Halls Crossing District, January through July 2026.

That’s a decrease of 2,944 visits, or a 19% drop. This may not all be related directly to the dropping lake levels. Horseshoe Bend, which is in Glen Canyon National Recreation Area but downstream from the reservoir, has also seen a significant drop off in visitors this spring and summer. In a future dispatch I’ll take a closer look at tourism numbers in general to get a better sense of how widespread the declines are.

Climate change comes for a Lake Powell marina — Jonathan P. Thompson

And now for the images showing Bullfrog with the marina, and without. The first image is from August 2024, when the reservoir’s surface elevation was at about 3,580 feet. The marina was still there, and the boat ramps still made it all the way to the water. The second image is from August 2026, with a surface level of just over 3,518 feet. Look closely and you’ll see the marina is gone, and the ramps are high and dry.

Click the link to read the article on the Sibley’s Rivers website (George Sibley):

August 25, 2026

You may remember my mention in early February of a research paper from scientists at the United Nation University Institute of Water, Environment and Health, titled Global Water Bankruptcy: Living Beyond our Hydrological Means in the Post-Crisis Era. The report begins:

‘Amid chronic groundwater depletion, water overallocation, land and soil degradation, deforestation, and pollution, all compounded by global heating, a UN report today declared the dawn of an era of global water bankruptcy, inviting world leaders to facilitate honest, science-based adaptation to a new reality.’

Our Colorado River made their list of exemplary global ‘hot spots’ for bankruptcy, with the observation that ‘the Colorado River and its reservoirs have become symbols of over-promised water.’

You’ve seen the word ‘crisis’ used frequently this year in the countless morbid articles about the Colorado River. But the UNU Institute director Kaveh Madani argued that we are now ‘post-crisis’: the term ‘crisis’ implies a deviation from the normal, a disruption to be dealt with in order to get back to normal, but there is now, Madani says, no going back to what passed for ‘normal’ in the last century. [ed. emphasis mine]

The study indicates that we have drained too many aquifers, resulting in subsidence that destroys the aquifers for the rest of the geological age; we have lost high-storage wetlands to gullying and lowered water tables; we have spread too much surface water out to dry under an atmosphere heating up incrementally with every additional gallon of fossil fuel we burn; desertification spreads in our wake; et cetera, et cetera. As a result:

The report makes the case for a fundamental shift in the global water agenda—from repeatedly reacting to emergencies to “bankruptcy management.” That means confronting overshoot with transparent water accounting, enforceable limits, and protection of the water-related natural capital that produces and stores water—aquifers, wetlands, soils, rivers, and glaciers—while ensuring transitions are explicitly equity-oriented and protect vulnerable communities and livelihoods.

There is in this research paper the kind of lovely naivete that one finds in most of the analyses of Big Issues today (climate change, systemic racism, corporate personhood versus people, etc.); there is an underlying conviction that when the facts are all laid out, we will rationally accept that, yes, we are indeed in a bankrupt situation. And so we will all sit down together, like rational beings would, and work out ways to resolve the ‘reality deficit’ between what has been promised and what can be delivered.

This ignores the fact that, when we are first confronted with evidence of something so big in its threat to our way of life, that its correction might require creating a whole new way of life, our first response is to say, ‘this can’t be so.’ There has to be a mistake. And a long winding road leads on, into and through a morass of denial, anger, blames cast, responsibilities denied, hopeful negotiations and underlying despair – the whole medieval pilgrim’s Slough of Despond that must be negotiated before we might actually sit down together and work out some way of resolving the ‘reality deficit.’

There is, however, a kind of honesty in coming around to realizing – and acknowledging – that a system might be bankrupt. Bankruptcy is not necessarily the end song of what has become bankrupt, although it can be (Chapter 7 bankruptcy).  It can instead be a time of operational or financial reorganization, aa time for acknowledging circumstances, conditions and misconceptions not originally taken into account that, accounted for, might enable a measure of eventual recovery and even success.

The seven Colorado River Basin states, still stuck in the zomboid Colorado River Compact, are not there yet, but the Bureau of Reclamation might be getting there. On the viable assumption that the seven states will not come up with a last-minute plan before the end of September and expiration of the Interim and Interim Interim Guidelines, they are preparing to institute a temporary plan that will maintain functionality in the river storage and delivery system, with (they hope) no embarrassing ‘dead pool’ episodes – which basically means getting and keeping as much water as possible in the two big reservoirs, Mead and Powell, and that can only happen at considerable cost to users below the big reservoirs.

The Bureau plan will not be carved in stone for forever like the Colorado River Compact; the Bureau will basically be planning operations for two-year periods, through the coming decade; every two years, the parties of interest will reconvene to review and revise the operating plan as circumstances require. This ‘adaptive’ approach makes sense in a bankruptcy situation in which the future is mostly unknown. [ed. emphasis mine]

The plan really has no surprises for anyone who remembers the 2022 bolt of reality that caused Bureau Commissioner Camille Touton to tell the water leaders in the seven states to immediately plan to voluntarily cut 2-4 million acre-feet (maf) of water use – basically a quarter of river use at that time – or the Interior Department would do it for them. That – in the centennial year of the Compact – is probably a good marker for the Bureau’s acknowledgement that we were beyond crisis, and slipping into bankruptcy.

That 2022 siren call was met by the Lower Basin states agreeing to finally take the Lower Basin system losses (evaporation, etc.) and their half of the Mexican obligation out of their river-use shares rather than out of Mead storage until the 2027 water year – provided they would be paid to do so. The absence of ‘surplus flows’ to take care of those losses – ~1.25 maf – from the coming online of the Central Arizona Project was a principal source of the draining of the big reservoirs, the so-called ‘structural deficit,’ 30 maf of storage gifted to the Lower Basin.

(A side note on this: The Upper Basin states, since a 1970 Law-of-the-River agreement, have been regularly sending downstream their 750,000 acre-feet for the Mexican obligation and absorbing as part of their whatever’s-left-over share of the river the ~400,000 acre-feet of Upper Basin system losses. The four states have never asked for or been paid for doing that.)

But that 1.25 maf of voluntary shortages was only a large fraction of the 2-4 maf of cuts the Bureau said needed to happen. So the Bureau’s original 2027-28 plan announcement in late July included cuts of up to 40 percent for the states below Mead Reservoir (Arizona, California and Nevada) – roughly equivalent to the 2022 request for 2-4 maf in cuts. The three downriver states countered that with an offer to permanently do the same 1.25 maf cut (with payment) for 2027-28 they were doing for 2025-26, with intimations of lawsuits if the Bureau pushed too far beyond that.

Arizona has led the countercharge from the states below Mead Reservoir – being the state with the most to lose, since the junior status of the Central Arizona Project means it would be practically shut down by 40 percent cuts in usage.

A letter to the Interior Department from Tom Buschatzky, Arizona’s Director of Water Resources, castigated the Bureau plan for making no mention of the Colorado River Compact and the Law of the River (LOTR). The letter insisted that Article III(c) and (d) of the Compact be executed to the letter as stated in the LOTR 1970 agreement: that a minimum of 8.23 maf be released from Powell Reservoir every year – the Compact commitment of 7.5 maf per year on average passing Lee Ferry, plus the Upper Basin’s share of the Mexican obligation (750,000 af/year).

In their August 21 announcement of the more detailed plan for 2027-28, the Bureau backed down from the 40 percent number, and now wants a 20 percent reduction in use for the two years – more in line with the Lower Basin’s willingness to continue taking care of its own system losses and Mexican share, but requiring some additional cuts – and avoided discussion of the Compact issue raised. It will, however, probably be pushing for more cuts in the 2028 discussions for the 2029-30 plan renewal; the Bureau still feels that it needs at least 3 maf in permanent cuts to begin any hope of turning the current near-bankruptcy around, and bringing demand in line with at least current supply.

The Bureau would also like the seven states to be reviewing, revising and executing the two-year plans consensually by 2036, rather than imposing it on them. But Arizona, according to the Buschatzky letter, wants a ‘longer, more comprehensive’ plan from the states, consistent with the LOTR, and ‘does not accept a framework that gives the federal government the discretion to select from a wide range of alternatives—including catastrophic cuts to the Lower Basin—every two years for the next decade.’

‘Bankruptcy management’ would seem to argue that the Colorado River Compact should be on the table along with everything else – including the nonexistence of the 18 maf river for which the Compact was written. A detailed analysis of the current situation by the ‘River Elders’ – the Kuhn-Schmidt-Castle group – suggested that ‘Basin water users must focus on solutions to the fundamental, wet-water math problem, rather than legal arguments over paper water.’ [ed. emphasis mine]

Nonetheless, Buschatzke’s letter states that ‘Arizona reserves the right to seek the resolution of its Compact rights in an appropriate judicial forum.’ The states are not yet willing to acknowledge the bankruptcy of the Compact – a Humpty-Dumpty that not all the patches and bandaids of the Law of the River can put back together for an ever-shrinking 21^st century Colorado River.

That, more or less, is where the river system’s future sits as of August 21. There will – thanks to the Bureau – be a plan for moving carefully into the future, a two-year step at  time. A big question is how hard the Bureau will begin to push for the 3-4 maf in permanent cuts by users necessary to stop the march into real dead-pool bankruptcy of the system – leading to another big question: whether the Compact nostalgitarians will push the system into dead-pool bankruptcy by suing the Bureau/Interior Department over paper water, tying things up in court for another several years.

Ah, the lovely Slough of Despond. There with Henry: ‘All day the sun has shone on the surface of some savage swamp, where the single spruce stands hung with usnea lichens, and small hawks circulate above, and the chickadee lisps among the evergreens, and the partridge and rabbit skulk beneath; but now a more dismal and fitting day dawns, and a different race of creatures awakes to express the meaning of Nature there….’ Bankruptcy, the Apocalypse – only the end for those who fail to see that something else is always struggling for a chance to be born; don’t put a period where God (or Nature) would put a comma (Gracie Allen). As Henry also observed, ‘The light which puts out our eyes is darkness to us. Only that day dawns to which we are awake….’

Next post, I want to go back to the ‘desert river’ concept to think a little outside the (Compact) box.

Click the link to read the release on the ADWR website:

August 21, 2026

After more than three years of difficult negotiations over post-2026 Colorado River Operations guidelines, Arizona and the Lower Basin states have created a level of stability for the Colorado River system with the adoption of the 2027-2028 operating guidelines in the Record of Decision. While the framework for years 3-10 continues to be of concern, we applaud the Department of the Interior for clarifying the decision-making process for operations beyond 2028.  That outcome allows for continued negotiations for years 3-10 while preserving our ability to protect Arizona’s legal rights to Colorado River water. 

We will continue to work with our partners in Arizona, the Lower Basin and Interior, to finalize the agreements necessary to implement the Lower Basin Plan. With the Record of Decision, the 2027-2028 Operating Guidelines and the supporting agreements in place, we can focus on a longer-term, equitable, basin-wide outcome that includes shared sacrifices along with our Upper Basin partners in an effort to avoid protracted litigation. The actions in the Lower Basin in recent decades to protect the system have demonstrated how much we can accomplish when we all join together as part of the solution. – Tom Buschatzke, Director of the Arizona Department of Water Resources

Click the link to read the article on the Las Vegas Review Journal website (Alan Halaly). Here’s an excerpt:

August 24, 2026

Nevada officials filed a federal lawsuit challenging the Trump administration’s order for cuts in water use Monday, marking a major escalation of tensions between the seven states that share the Colorado River. The complaint, filed in the U.S. District Court of Nevada, asserts that the U.S. Bureau of Reclamation’s operating plan unlawfully authorizes the federal government to reduce the state’s allocation of the river by up to 71 percent annually sometime over the next 10 years. Such a cut would slash the state’s share of 300,000 acre-feet down to 86,444 acre-feet. Nevada’s use, after cashing in water recycling credits with its state-of-the-art system, came in at 198,000 acre-feet last year.

“There are four states upstream of us that are facing zero mandatory reductions,” said John Entsminger, general manager of the Southern Nevada Water Authority, in a Monday interview. “That is not going to balance the system. This is a system-wide problem. It requires system-wide solutions.”

Lawyers for the Colorado River Commission of Nevada, the water authority and the state as a whole requested an injunction to halt implementation until federal documents can reflect the toll water cuts would have on Southern Nevada’s $180 billion economy.

“This shortfall will cause devastating environmental, socioeconomic, and health and human safety impacts to southern Nevada and its citizens,” attorneys wrote. “Federal Defendants failed to consider such impacts in any meaningful way.”

While 2027 and 2028 will see allocation cuts that the Lower Basin states of Nevada, California and Arizona have already agreed to, the years 2029 to 2036 could bring much harsher reductions. Entsminger said he felt it was important for Nevada to have its own representation on the issue, but he added he would be surprised if California and Arizona don’t sign on to the lawsuit, considering officials remain aligned in their positions. No mandatory cuts will be imposed on the Upper Basin states of Colorado, Utah, New Mexico and Wyoming. Entsminger submitted a letter to all six Colorado River basin states Monday, saying the state’s decision to sue wasn’t made lightly but that “hiding from reasonable legal interpretations in order to defer hard political decisions helps no one over the long term and further endangers our shared resource.”