AZ vs. CA:25 California Exhibits, Vol. XXV; Nos. 7501-7859

page 7

A reservoir one-fifth as large would lose all of it a eapa-eity by allting within fifty years. Such a eapaeity even if it eould be retained would be inadequate to regulate rive.- flows. In a typioal low flow period suoh as occurred in 1900 - 1904, even with a large storage eapaeity provided in other reservoirs upstream, the accumulation of defienoy in runoff, below the average, reaches over 20,000,000 acre feet. In order to carry agriculture through such a period, this amount of storage must be pro-Tided. The email cost mentioned for a small reservoir is unobtainable. (15) That the eon tract for delivery of 1,060,000 acre feet to the Metropolitan District together with present uses of 6,600,000 acre feet exhaust the Lower Basin allotment. (Art. XXXII) Present uses in Lower Basin total 4,400,000 acre feet leaving 3,100,000 aore feet for additional use out of the initial allotment. Furthermore, there is an undetermined amount unallotted. The contract Is made subjeot to the Colorado River Compact, and the United States has not guaranteed the indicated delivery. The Bill of Complaint fails to give recognition to the most important feature of the Boulder Canyon projeot, which is flood control for the protection of lands in Nevada, Arizona, and California, in-oluding material areas owned by the United States. This feature is the primary Justification of the project. The state denies the right of the United States to construct a dam or dams in that part of the Colorado River where such a dam must be built to be effeetive for purposes of flood control, claiming that it plans to utilise such damsites for purposes of enhancing property values within the State.