These solutions include reductions specific to each downstream state, based on the legal priorities each user has regarding water allocations. Critics say the move primarily benefits California, which maintains more than 3 million acre feet of Colorado River water rights on farmland across Southern California.

An alternative proposed by the Landfill Authority would provide for reductions in Colorado River water rights based on the percentage of water used by cities, farms, tribes and other groups downstream. A third option calls for no action to curb water use beyond existing guidelines in the 2019 Downstream Drought Contingency Plan.

Reclamation officials say the “do nothing” option could ultimately result in a “dead pool” at Glen Canyon and the Hoover Dam, where water levels are too low to generate electricity or water to downstream communities. It is said that it will be unable to supply.

This draft proposal, and whatever action the U.S. Reclamation Service approves later this year, could reduce water use on the Colorado River by more than 2 million acre-feet annually across the lower reaches of the state by 2024. , followed by even greater reductions in stages until 2027.

The county’s proposed comments were compiled by Phoenix-based law firm Clark Hill. According to Clark Hill officials, the agency’s draft proposal is itself flawed, and what environmental impact the proposed alternative will have on communities wholly dependent on the Fourth Priority Colorado River water rights. There is a lack of discussion about whether it is possible.

“The Colorado River is the lifeblood of communities in Mojave County,” Clark Hill officials said. “Many of these Mojave County communities hold concessions on the Colorado River and are completely (or almost completely) dependent on the 4th priority water rights for their survival.”

And while other Colorado River rightsholders may have alternative water sources, some Mojave County communities can only rely on the river. Mojave County’s fourth-largest water contractors, according to county records, include Lake Havasu City, Bullhead City, EPCOR, Mojave County Water Authority, Mojave Valley Irrigation and Drainage District. Nearly all of these companies already pump some of their water from wells, but all of them rely on water from the Colorado River, Clark Hill said. There are no other sources of surface water in Mojave County.

“If we don’t provide priority 4 water to these communities, they will literally dry up,” Clark Hill officials said. “Protection of the river, these communities, and these water users is Mojave County’s primary concern.”

There is no “ideal” solution in the agency’s draft proposals, according to Clark Hill, and the agency may not be able to achieve equitable and sustainable outcomes for river communities unless the draft is revised.

“The first alternative would be particularly onerous and unsustainable for communities in Arizona, especially Mojave County,” said Clark Hill. “Under that alternative, Arizona’s fourth priority rightsholders would absorb most of the savings.”

Clark Hill said the second option, which bases reductions on percentages of use by specific communities in the Colorado River Basin, would yield more equitable and sustainable outcomes for river communities.

But landfill authorities still fail to consider the environmental impact of scarcity in communities that could deprive them of their only source of water for municipal use, according to comments proposed by the law firm.

“[Reclamation]has failed to objectively evaluate all reasonable alternatives needed because it evaluates alternatives that substantially meet the objectives and needs of this project as set forth by Reclamation.” Because it looks like you haven’t.”

According to Clark Hill, the Office’s draft proposal remains inadequate and further consideration needs to be given to the environmental impact of the agency’s decisions.

The Mojave County Board of Supervisors will vote on whether to approve Clark Hill’s comments to the Bureau of Reclamation at its next board meeting Monday in Kingman.

Public comments on the agency’s report may also be submitted by email to CRinterimops@usbr.gov or by phone at 602-609-6739.

To email comments, please write to Reclamation, 2007 Interim guideline SEIS Project Manager, Upper Colorado River Basin Regional, 125 South State Street, Suite 8100, Salt Lake City, UT 84138.

The Landfill Service is accepting public comments on the issue until May 30.