New Scholarship on Winters Rights

Jesse H. Alderman has posted his paper, “Winters and Water Conservation: A Proposal to Halt ‘Water Laundering’ in Tribal Negotiated Settlements in Favor of Monetary Compensation,” on SSRN. The final version of the paper appears in the Virginia Environmental Law Journal. Here is the abstract:

In the century since the U.S. Supreme Court, in Winters v. United States, granted Indian tribes reserved water rights, few tribes have received the promised delivery of water, while at the same time, the Department of Interior — the same agency tasked with a fiduciary duty to hold all tribal assets in trust — constructed massive, multibillion-dollar water projects without cognizance of senior Indian rights. The water transformed much of the West from arid desert to a green expanse of farmland and steel-and-mirrored urban centers with populations rivaling cities in the water-rich East. However, the pace of development has placed unsustainable strain on the groundwater aquifers and surface waters of the parched Interior West, all while untold millions of acre-feet of water are still owed to Indian tribes under Winters. As state courts and the U.S. Supreme Court have proven hostile to Indians, tribes have increasingly settled their Winters claims through negotiation with states, cities, and other junior appropriators. The benefits of these negotiated settlements have proven illusory. While tribes turn their “paper rights” into “wet water,” they are often shortchanged, and bound by agreement to market water to competing municipal economies off-reservation. The linchpin of most negotiated settlements is federal investment in otherwise politically unpalatable water delivery projects, made possible by the purported necessity of settling senior Indian claims. This form of exchange might critically be called “water laundering.” This Article argues that negotiated settlements are bad public and environmental policy. As an alternative to those negotiated settlements, this Article proposes that tribes should instead seek financial compensation for their inchoate Winters rights by suing the federal government for a century of abject breach of its fiduciary duty to hold water in trust for the benefit of tribes. This suit should be modeled on the recent Cobell class action litigation, where Congress ratified a $3.4 billion settlement with the Departments of Interior and Treasury for similar mismanagement of Indian allotment lands. A class action approach would allow the tribes to receive the maximum financial value, and vindicate rights long neglected by the federal fiduciary, all while averting further overconsumption of the West’s perilously scarce water resources.

A Historic Assertion of Water Rights by the Klamath Tribes

An excerpt from the Oregonian

In March, after 38 years of work, the state found that the tribes’ water rights dated to “time immemorial,” making them by far the most senior. That means the tribes will get water to protect fish in traditional fishing grounds, including two species of suckers on the endangered species list.

Farmers irrigating through the federal government’s 1905 Klamath Reclamation Project, covering roughly 200,000 acres that draw from the lake, will also get water, though they’ll face restrictions, too.

But “off-project” irrigators on about 150,000 acres above the lake generally have junior water rights to reclamation-project irrigators. They’ll have to tap wells if they can or see their water supplies reduced or shut off.

The AP story is here.

The administrative law decision and other materials can be found here.

Agua Caliente Sues for Water Adjudication

Here is the complaint in Agua Caliente Band of Cahuilla Indians v. Coachella Valley Water District (C.D. Cal.):

Complaint for Declaratory and Injunctive Relief (conformed)

Montana SCT Materials on Failed Challenge to Flathead Reservation Water Compact

Here are the briefs and opinion in Western Montana Water Users Assn. v. Mission Irrigation District (Mont.):

Opinion

Appellant Brief

Appellee Brief

CSKT Amicus Brief

Montana Reserved Water Rights Compact Commission Amicus

Montana Water Resources Assn Amicus

Reply Brief

News coverage here, via North Dakota Supreme Court site.

NYTs on “Water War” on Flathead Reservation

Here.

Chickasaw and Choctaw Nations SCT Amicus Brief in Tarrant Regional Water District v. Hermann

Here:

Chickasaw and Choctaw Amicus in 11-889

The SCOTUSblog page on this case is here.

 

North Dakota Law Review Article on Missouri River Basin Compact

Jeffrey T. Matson has published “Interstate Water Compact Version 3.0: Missouri River Basin Compact Drafters Should Consider an Inter-Sovereign Approach to Accommodate Federal and Tribal Interests in Water Resources” in the North Dakota Law Review.

The abstract:

In the aftermath of the historic 2011 Missouri River flood, Missouri River Basin (MRB) state representatives and governors criticize the U.S. Army Corps of Engineers (Corps) for operating the Missouri River Mainstem Reservoir System (System) in support of the multiple, often conflicting, purposes outlined in the Flood Control Act of 1944. These officials envision entering into an interstate compact to divest the Corps of some of its operational authority and to broaden their role in managing water resources. Similarly, MRB tribal leaders argue that the Corps fails to operate its System in a manner that respects the interrelated issues of Indian reserved water rights and tribal sovereignty. As States and Tribes contemplate a rebalancing of power in the MRB, it is essential that any water resources management solution provide a forum in which affected States, Tribes, and the Federal government might work together in pursuit of interconnected interests. Accordingly, it is time for stakeholders to think beyond the dualistic “federal-interstate” compact arrangement and seriously consider a pluralistic “federal-interstate-tribal” approach – even if Indian reserved water rights are not yet quantified. Although such a tripartite approach is a departure from traditional compacting practice, the great weight of Indian reserved water rights warrants tribal representation on any commission charged with implementing a twenty-first century MRB water resources compact. Further, it would be unrealistic to expect a federal commissioner to represent tribal interests until such time as rights are quantified, given the Federal government’s conflict of interest in operating the System for other consumptive users. This Article concludes that the Federal government’s interests in flood protection, navigation, and national security, and the Tribes’ interests in protecting reserved water rights and tribal sovereignty, warrant an inter-sovereign approach whereby power is shared equally among signatories to this compact.

Havasupai Tribe, Conservation Groups Challenge Uranium Mine Threatening Grand Canyon

The complaint can be seen here.  The Center for Biological Diversity’s News Release can be seen here.

A snippet of the complaint:

After initial approval of the Canyon Mine, the Forest Service formally designated Red Butte and surrounding areas as a Traditional Cultural Property. This designation means Red Butte is eligible for inclusion in the National Register of Historic Places and meets the definition of a “historic property” under the National Historic Preservation Act (NHPA). The Forest Service also recognized that Red Butte is a sacred site to the Havasupai Tribe. The Forest Service’s 1986 approvals did not analyze the Canyon Mine’s potential effects to Red Butte as a historic property under the NHPA. The Forest Service recently commenced consultation with the Havasupai Tribe concerning the Canyon Mine’s impacts to Red Butte, and claims that it intends to continue consultation. The Forest Service is refusing to undertake and complete a NHPA Section 106 Process relating to adverse impacts to the Red Butte TCP, including consulting with the Tribe for the purposes of developing a Memorandum of Agreement, prior to allowing Canyon Mine to restart mining operations, as required under NHPA and its regulations, 16 U.S.C. § 470f, 36 C.F.R § 800.13(b)(1).

Washington Supreme Court Decides Water Rights Case Involving Yakama Indian Nation

Here is the opinion in Dept. of Ecology v. Acquavella:

Wash SCT Opinion

And the briefs are here:

Leonard Masten on why PacifiCorp should remove its Klamath River Dams

Here.