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<br />Amendment" to the Reclamation Act, this policy holds <br />that whenever a state water rights commission or state <br />court is engaged in a "general stream adjudication," a <br />proceeding in which all the water rights claims in a <br />given watershed are adjudicated simultaneously, the <br />water rights of any federal property in that watershed <br />must be determined in that forum (Burton 1989:161). <br />The McCarran Amendment and related court rulings, <br />however, does not mean that Winters rights are quanti- <br />fied according to state law, but only that the extent of <br />the federal reserved water rights can be determined in <br />state courts (Checchio and Colby 1993:15). <br />Nevertheless, the Supreme Court, in 1976, maintained <br />that the McCarren Amendment applied to Native <br />American reservations, as well, in its Akins decision. In <br />1983, when the Navajos and San Carlos Apaches tried <br />to get the Supreme Court to reconsider or at least nar- <br />row the Akins ruling, the Court thoroughly rejected the <br />Native Americans' arguments and reaffirmed its earlier <br />decision (Burton 1989:161). <br /> <br />In a 1963 decision, the U.S. Supreme Court, in <br />Arizona YS California, reaffirmed the Winters doctrine <br />and established "practicably irrigable acreage" (PIA) <br />as a standard for quantifying reserved water rights on <br />a reservation set aside with the intent that its inhabi- <br />tants pursue agriculture. This litigation was prompted <br />by Arizona's need for a determination of its share of <br />water from the Colorado River in order to obtain fed- <br />eral appropriations for the Central Arizona Project. <br />The United States intervened to assert, among other <br />things, the reserved water rights for five Native <br />American tribes, who had traditionally been farmers, <br />and their respective reservations located on the lower <br />portion of the Colorado River (Burton 1989:162). <br />This was the first time the Supreme Court had set <br />forth generalized criteria for the quantification of <br />reserved Indian water rights. <br /> <br />Under the PIA standard for quantification, tribes are <br />legally entitled to the amount of water needed to irri- <br />gate all practicably irrigable acreage within their reser- <br />vation boundaries. This standard compels tribes to <br />devote enormous resources to analyze the costs and <br />benefits of new tribal irrigation development and <br />detracts attention from a broader evaluation of the <br />many potential beneficial uses of tribal water. <br />Moreover, tribal land subjugation for agricultural pur- <br />poses may disrupt wildlife habitat, archaeological sites, <br />air and water quality, and other reservation resources <br />(Checchio and Colby 1993:13). Further, the PIA stan- <br />dard does not encourage tribes to examine other water <br />uses that may yield higher economic returns, provide <br />better employment opportunities, or are more compat- <br />ible with tribal values and protection of the reservation <br />environment. <br /> <br />The Arizona v. California resulted in the quantification <br />of the water rights of five lower basin tribes (Colorado <br />River, Chemehuevi, Ft. Mojave, Quechan, and Cocopah <br />Indian tribes). Four other tribes (Southern Ute, Ute <br />Mountain Ute, Jicarilla Apache, and Northern Ute) <br />have had their water rights, to the mainstem Colorado <br />River, recognized through settlements enacted by <br />Congress and one tribe, the Navajo Nation, possess <br />statutory right to Colorado River water for the Navajo <br />Indian Irrigation Project (Checchio and Colby <br />1993:25). These ten tribes formed the Colorado River <br />Basin Tribes Partnership in 1992. This Partnership <br />attempts to protect and develop tribal water resources, <br />advance tribal influence over the numerous aspects of <br />river management that affect tribal interests, and stim- <br />ulate dialogue 'With states, federal agencies, and non- <br />Native American water users on matters of concern to <br />tribes. Moreover, the Partnership has observed that the <br />economic benefits associated with the Colorado River <br />are not going to the tribes in proportions consistent <br /> <br />27 <br />