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<br />(1923), and (2) to avoid polluting the water used by a downstream state. Missouri v. <br /> <br /> <br />Illinois, 200 U.S. 496 (1906). Although the Court later concluded that the federal Clean <br /> <br /> <br />Water Act has fully occupied the field of interstate water pollution,23 it seems likely that <br /> <br /> <br />the Court will consider the impact of upstream state actions on the quality of water <br /> <br />downstream in an equitable apportionment case. <br /> <br />Decrees in equitable apportionment cases do not provide for arbitration of any <br /> <br />disputes that may arise under the decree, so that a dissatisfied state is forced to bring an <br /> <br />action in the Supreme Court to enforce the decree in accordance with its views. See <br /> <br />Nebraska v. Wyoming, 515 U.S. 1 (1995). <br /> <br />C. Congressional Apportionments <br /> <br />Only two interstate water disputes have been resolved directly by federal <br /> <br />legislation: the allocation of the mainstream of the Lower Colorado River by the <br /> <br />Boulder Canyon Project Act of 1928, discussed in Section III, and of the Truckee and <br /> <br />Carson Rivers between California and Nevada. 104 Stat. 3289. Congress can later <br /> <br />amend such legislation or even a decree interpreting it, as it has done on the Lower <br /> <br />Colorado River. The Truckee .. Carson legislation presumably can be enforced in a <br /> <br />federal district court. <br /> <br />23 Milwaukee v. lllinois, 451 U.S. 304 (1981); Arkansas v. Oklahoma, 503 U.S. 91 (1992). <br /> <br />18 <br />