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Show 110 These figures demonstrate that whatever period is selected, the flows of such period have not been repeated in a later comparable period. There is no basis for assuming that flows of any of these periods will be repeated in a comparable period in the future. Lastly, Lower Basin supply is affected by Upper Basin uses. Increased Upper Basin uses will diminish the Lower Basin supply except as the Upper Basin is limited by Article III of the Compact. Yet no one can say with certainty what increase may occur in Upper Basin uses or at what time. In support of her prediction of future mainstream supply in the Lower Basin, California relies on two studies which were received in evidence. One, by Thomas M. Stetson, a California witness, concluded that future Lower Basin mainstream supply will be 6,175,000 acre-feet per annum.38" The other, by John R. Erickson, an Arizona witness, predicted a future supply of 6,100,000 acre-feet per annum.39 The apparent concurrence of the Arizona and California witnesses is deceptive, however. Far from supporting California's position, these studies demonstrate that predictions of future supply are necessarily based on so many significant but unknowable factors that they cannot be accurate enough to be helpful in this case. Both the Erickson and the Stetson studies are based on a number of assumptions which the witnesses made, either on the instruction of counsel or for some other reason, without any attempt to justify the assumptions and, indeed, without ever stating that they agreed with the assumptions. While each one of these assumptions has a significant effect on the ultimate supply prediction in each s8aCalif. Ex. 2216-A; Tr. 21836 (Stetson). 39Tr. 18913-15 (Erickson). |
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Original Report: State of Arizona, complainant v. State of California, Palo Verde Irrigation District, Imperial Irrigation District, Coachella Valley County Water District, Metropolitan Water District of Southern California, City of Los Angeles, California, City of San Diego, California, and County of San Diego, California |