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<br />0018:,,7 <br /> <br />. <br /> <br />. <br /> <br />is presently of significant importance. I shall try to list <br /> <br /> <br />the issues of paramount significance in the proposed findings <br /> <br /> <br />of fact, conclusions of law, and briefs submitted to the Special <br /> <br />Master between April 1 and June 30, 1959. <br /> <br />l. Does the Colorado River Compact apply to lower <br />basin tributaries? Arizona now says that the Compact has no <br />application to lower basin tributaries, that all III(a) water <br />and all III(b) water is found flowing in the main stream from <br />the upper basin at Lee Ferry.!! As a consequence of writing <br />the lower basin tributaries completely out of lower basin <br />accountability, water which the Mexican Treaty guarantees <br />Mexico under III(C) of the Compact is in addition to the <br />75,000,000 acre-feet per 10 years required to be delivered by <br />Article III(d).SI Presumably, although Arizona has not expressly <br />said so, the I1I(C) water from the upper states is also in <br />addition to the 1II(b) water. <br /> <br />!! Arizona Findings 99, lOO. <br /> <br />Y "The purpose [of Article III(d)] could not have been <br />for use in Mexico, because any rights of Mexico are to be <br />satisfied in accordance with the provisions of Article III(c), <br />and the responsibility of the Upper Basin to deliver water for <br />the Mexican Treaty obligation is 'in addition to that provided <br />in paragraph (d).' Therefore, the only perceivable aim of the <br />delivery of water required in sub-paragraph (d) was to guarantee <br />to the Lower Basin a supply of water." Arizona Opening Brief, <br />'p. 28. <br /> <br />29. <br />