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~O"5"'3 o 1 ;) 2002] THE LAST GREEN lAGOON 919 Prior to the BCPA, state law governed water allocations, even when Bureau of Reclamation reOR) irrigation projects were involved.84 The BCPA, however, provided'that "[n]o person shall have or be entitled to have the use for any purpose of the water. . . except by contract [with the Secretroy]."85 The BCPA authorized the Secretroy to enter into permanent water delivery contracts with users in the Lower Basin, up to the limit of each state's apportionment.86 The BCPA also authorized the Secretroy to contract for the delivery of surplus water or the unused apportionments of other states. 87 However, the broad control given to the Secretary by the BCPA made it unclear whether state law still controlled water allocation on the Lower Colorado.88 As a result, the Lower Basin states continued to dispute the allocation of the river and never entered into the compact authorized by the BCPA.89 Ongoing conflict between Arizona and California over their respective shares of the river eventually led to the U.S. Supreme Court's monumental 1963 decision in Arizona v. California. 90 In Arizona v.California, the Court held that the BCPA subjected the mainstream Colorado River below Lee's Feny to federal control, largely preempting state control over water allocation.91 With the exception of pre-1929 water rights recognized under state law, the Court enjoined future deliveries of Lower Basin water by any means other than a federal water delivery contract.92 Although the BCPA did not explicitly limit the states to the allotments authorized, the Court, quite remarkably, determined that Congress "intended to and did create its own comprehensive scheme for the apportionment among California, Arizona, and Nevada of the Lower Basin's' share of the Colorado 84. Reclamation Act of 1902, 32 Stat. 388, 390 (1902) (codified as amended at 43 U.S.C. ~ 383 (1986)). Section 8 of the Reclamation Act of 1902 required BOR to comply with state law in the appropriation of water for federal projects. Id 85. BCPA, supra note 81, !!l5. 86. BCPA, supra note 81, !!l1O. Typically. the contracting bodies are entities like irrigation districts (IDs), such as the Imperial Irrigation District (nD). or water utilities. such as the Metropolitan Water District (MWD), In turn, individual users get their water by contract with these larger entities. See Benson, supra note 80, at 366, 384-85. 87. See McClurg, supra note 12, at 6. 88. BCPA, supra note 81, !!l 14. BCPA gives the Secretary broad powers to regulate the river, sign contracts, etc. Since inconsistent state law is superceded by federal law, these broad powers made it unclear if state control would be inconsistent with the Secretary's authority. 89. See Arizona v. California, 373 U.S. 546, 562 (1963). 90. rd. 91. See id. at 587. 92. See id. at 588.