Forty-One Days

The Bureau of Reclamation published its final Colorado River operating guidelines on August 21, 2026. Arizona's Colorado River delivery for 2027 and 2028 is fixed at 2.04 million acre-feet, which is 760,000 acre-feet under its full apportionment. California gives up 440,000. Nevada gives up 50,000. The Lower Basin total runs to about 1.25 million acre-feet. An acre-foot is a foot of water standing on an acre of ground, roughly 326,000 gallons; 1.25 million of them would supply about four million households for a year.

That is the federal number, and as federal numbers go it's a good one — published, precise, defensible. It is also no use whatever to somebody deciding what to plant. Nobody irrigates seven states. There is no line on the order form that says "Lower Basin."

The Record of Decision hands the job of dividing Arizona's share to Arizona: to the state, to the Central Arizona Project, and to the accumulated pile of contracts, priority dates, and federal reserved rights that decides who gets water and in what order. As of August 21, the public record on that division consisted of one preliminary CAP model, some careful language from two cities, and a deadline.

The deadline is October 1, when every CAP customer must submit its water order for the coming year. That left forty-one days. No table had been published showing what any single district, city, tribe, or farmer will actually receive in 2027.

Who loses first

The Central Arizona Project is a 336-mile canal that hauls Colorado River water from Lake Havasu across the desert to Phoenix, Tucson, and the farm districts in between. Its customers aren't individual growers or homeowners. They're cities, tribes, and irrigation districts holding contracts at different priority levels, and when supply drops, the low-priority contracts lose water before the high-priority ones lose any. It works like seniority on a job site, with one difference: the bottom crew is cut to nothing before the crew above it loses an hour.

CAP's 2025 briefing modeled what a 760,000 acre-foot Arizona cut would do to that arrangement. The Agricultural Settlement Pool and the non-Indian agricultural supply — the bottom — go to zero. Municipal and industrial contractors lose about 20 percent. Tribal contractors lose about 16.

CAP stamped that work "preliminary" and "for illustrative purposes only." Look at it, in other words, but don't order water off it.

At a May 13 public meeting, a Pinal County farmer named Brian Wong asked the question the illustration left open. Would CAP absorb the whole 760,000 acre-feet, and what percentage does each priority pool actually take? CAP General Manager Brenda Burman gave him the illustrative figures — about 20 percent for municipal and industrial, about 17 for tribal — and said they were a model, not a commitment.

At Wong's end of the canal that is the only question there is. Washington has settled how much water Arizona loses. Arizona has not settled, or at least hasn't said out loud, how the loss spreads across the people who use it. The priority structure is public and has been for years. The numbers to put into it are not.

Three calendars

Phoenix adopted its fiscal 2026–27 budget on June 17. Tucson adopted its own on June 9. Both budgets cover the first six months of calendar 2027, and both were passed more than two months before Interior finalized the rules governing the water supply for that period.

Rates ran on the same clock. Tucson's water-rate adjustments were approved May 19 and took effect July 6. CAP approved its 2027–32 rate schedule on June 4, working from an assumed 2027 delivery of 825,000 acre-feet at $326 an acre-foot. Buried in that schedule is a detail worth knowing: CAP charges its fixed operation-and-maintenance costs on scheduled water whether or not the water shows up. Drop deliveries to 500,000 acre-feet and the fixed cost per unit climbs to $392. The canal costs what the canal costs. Less water through it doesn't produce a smaller bill, only a bigger bill per acre-foot for whoever's still buying.

The farm calendar is tighter than either. University of Arizona planting guidance puts the optimum window for spring wheat and barley in the low desert at December 15 through January 15, and land preparation and water planning come before that. Across the line in California's Imperial Valley, alfalfa planting generally starts in October, before Arizona's ordering deadline has even passed.

So the federal decision lands on August 21, the water orders are due October 1, the budgets were locked in June, and the seed goes into the ground three to five months out. Nobody drew these calendars up together and none of them waits on the rest.

What the cities are telling their customers

Max Wilson, water-resources management adviser for the City of Phoenix, described the position last December:

He said Phoenix needed its cut number before October, when the city files its CAP order.

On August 21 the city issued a notice saying the federal decision would not cause an immediate service interruption or mandatory restrictions. Phoenix was still evaluating the amount, timing, and duration of its reduction. Water banked underground in earlier years would serve as a "critical bridge" while replacement supplies get developed.

Brandy Kelso, who runs Phoenix Water Services, said in late July that worsening conditions could push the city into Stage 2 of its drought plan by the end of 2026 — expanded conservation programs, possibly a drought surcharge.

John Kmiec at Tucson Water said his technical staff was reviewing the framework's operational, legal, and planning implications, and noted that the federal document contained no Tucson number. The utility still has to work through CAP and the Arizona Department of Water Resources before it knows what to plan around.

Translated out of the official register, what Phoenix told its customers on August 21 was: nothing changes yet, we're calculating, we have reserves, we'll let you know. That is probably all true. It is also what a city says when the federal decision has arrived forty-one days ahead of its water order and it still doesn't have its own number. Wilson's December sentence holds up better than anything issued since. Many plans, none of them perfected.

The strongest right on the river

The Colorado River Indian Tribes hold a Supreme Court–decreed right to divert up to 719,248 acre-feet a year, with priority dates reaching back to 1865. That is not a CAP contract. It is a present perfected right, the most senior category of entitlement on the river — older than the Colorado River Compact, older than Arizona statehood, and confirmed by the Court.

The Record of Decision states that the operating framework does not alter present perfected or federal reserved rights. In a government-to-government consultation, Reclamation told CRIT that no outside entity can reallocate the tribe's water and that any reduction on CRIT's part would have to be voluntary. Chairwoman Amelia Flores had pushed for that, asking Reclamation to strike a draft alternative that would have treated an 1865 right the same as a junior CAP contract and cut both pro rata. The final decision went her way.

The legal protection is real. The consultation record also shows tribal officials raising what legal protection doesn't reach: aging federal irrigation works, disputes over water accounting, crop-mix planning, and whether the tribe can physically put its full entitlement to use. Councilwoman Raeanne Patch asked for help building a crop-mix plan and said CRIT wanted to avoid more fallowing. Councilman Tommy Drennan asked Reclamation to account accurately for canal deliveries and return flows.

Reclamation promised legal and technical assistance, and conditioned some of the planning support on reliable water accounting — which is itself one of the things nobody has yet. The tribe needs the accounting to plan. Reclamation wants the accounting before it helps plan. The right is safe from reallocation; whether the infrastructure, the accounting, and the planning help exist to let CRIT use all of it is a separate question, and the Record of Decision doesn't touch it.

CRIT's position is unusual because of that 1865 date. Several other tribal nations hold CAP-delivered entitlements at lower legal priority, and CAP's preliminary model put those tribal contractors at a 16 to 17 percent reduction with none of the protection CRIT secured. No public response from those tribal water departments turned up in the reviewed record.

What "voluntary" looks like at the delivery gate

The federal guidelines call for 700,000 acre-feet of additional conservation through voluntary agreements over 2027–28. The Lower Basin states' May proposal tentatively split it three ways: 300,000 for Arizona, 300,000 for California, 100,000 for Nevada, contingent on funding and on further agreements. No finalized 2027 list of participants, compensation rates, or Arizona solicitations was in the public record when the decision came down.

California's Imperial Irrigation District has been running a version of this for a while, and its 2026 Deficit Irrigation Program shows what the word means once it reaches a field.

A grower with at least twenty acres of eligible alfalfa picks a 45- or 60-day window between June and September and doesn't irrigate the crop. IID locks the delivery gate and disables electronic water ordering. If several fields share a gate, the grower installs a physical barrier, photographs it, and takes an IID inspection. The conserved volume is figured from historical use. Payment is $334 an acre-foot. The 2026 solicitation ran from late February to late March, and when it came in oversubscribed the district prorated eligible acreage.

IID general manager Jamie Asbury expanded the district's 2026 conservation capacity in May by as much as 100,000 acre-feet, mostly through deficit irrigation and on-farm efficiency deals. Whether those contracts get credited against the new federal 700,000 acre-foot target, or whether new terms and new solicitations will be required, isn't established in the public record.

Nobody is ordering anyone to fallow, so "voluntary" is an accurate word. It just doesn't describe much of what happens after a farmer signs. What happens is a locked valve, a shut-off ordering system, a photographed barrier, an inspection, and a check that arrives after the dry period ends, on dates and at a price somebody in an office had to choose.

What remains

The 2027–28 operating rules are final. The state-level numbers are fixed. The priority structure has been public for years. The list of what isn't settled runs longer.

There is no permanent interstate agreement covering allocations past 2028. Arizona's legislature hasn't scheduled the special session needed to approve the Lower Basin implementation arrangement. CAP hasn't published final 2027 customer allocations. The 700,000 acre-feet of voluntary conservation has a target and no contracts. CRIT's right is protected on paper and unresolved on the ground. And the hydrology — how much water will actually be sitting in Lake Mead and Lake Powell — is unknown, the spread of projections too wide to plan against any single one of them.

What Washington decided on August 21 is how much water Arizona loses. Forty-one days later, Arizona's water users have to order water they can't yet count on. Brian Wong's May question is still open. Somewhere between the announcement and the deadline, a number has to appear that's specific enough to plant around, budget for, set a rate on, and write on a form.

It hasn't appeared. The wheat goes in the ground in December.