ML20042A465

Summons & Complaint Against Secretary of Interior Jg Watt for Declaratory Judgment & Mandamus Re Salt River Project

ML20042A465
Person / Time
Site:	Palo Verde
Issue date:	03/19/1982
From:	Pamela Shea MARKS, SHEA & WILKS, SALT RIVER PIMA-MARICOPA INDIAN COMMUNITY
To:	U.S. DISTRICT COURT, DISTRICT OF COLUMBIA
Shared Package
ML20042A462	List: ML20042A465
References
82-0145, 82-145, NUDOCS 8203230458
Download: ML20042A465 (13)

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11uitch States District Gaitri .

FOR THE District of Gahttubia CIVIL ACTION FILE No. ~b SALT RIVER PIMA-MARICOPA INDIAN COMMUNITY, c/o Herschel Andrews, President 10005 East Osborn Road Scottsdale, Arizona 85256

( C.C 2 ) 949-7234 l>laintiff SU3DIONS V.

UNITED STATES OF AMERICA and JA!!ES G. WATT, SECRETARY OF THE INTERIOR C Street, between 18th and 19th Street.s, N.W.

Washington, D. C. 20240 Defendants To the ataste named Defendant s :

You are hereby summoned and rotuireil to serve upon John J. McMackin, Esq.*

of Williams and Jensen plaintitl's attorncy . whow address 1101 Connect.icut Avenue N.W. , Washington, D.C. 20036 an answer to the complaint which is herewith served upon you, within 60 days after service of this the United States Attorney i.ummons upon Jtx4 exclusisc of the day of service. If you fail to do so, judgment by default will bc l taken against you for the relief demanded in the complaint.

JAMES F. DAVEY ~

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I Date: [Sealof Court)

NOTE:-This e.mm... Is iss ed pers. net t. note 4 .t the redersi unies et civil precedure.

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8203230458 020319 PDR ADOCK 05000529 05 G PDR l

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UNITED STATES DISTRICT COURT e w FOR THE DISTRICT OF COLUMBIA SALT RIVER PIMA-MARICOPA INDIAN )

COMMUNITY, )

c/o Herschel Andrews, President )

10005 East Osborn Road ) .

Scottsdale, Arizona 85256 )

(602) 949-7234 )

J

)

i Plaintiff, )

vs. Civil Action No. b[

}

UNITED STATLS OF AMERICA and )

JAILS G. WATT, SECT 4ETARY OF THE )

INTLIIOR, )

C Street, La wcen lath .and 19th )

Streets, ii . W . )

Washington, D. C. 20240 )

)

Defendants. )

)

COMPLAINT (For Declaratory Judgment and Mandamus)

1. JURISDICTION. The plaintiff is a community of American Indians organized under Section 16 of the Indian hcorganization Act of June 18, 1934, 48 Stat. 987, 25 U.S.D.

$476. The defendant James G. Watt is Secretary of the Interior and this action is brought against him in his official capacity. This Court's jurisdiction is conferred by 28 U.S.C. SS1331(a), 1361 and 1362. The United States of America is joined as a defendant pursuant to the consent conferred by 28 U.S.C. 5702.

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2. liATURE OF THE ACTION. This is a claim for review of Interior Department actions undertaken in the administra-tion of the Salt River Project, a federal reclamation project, which violate acts of Congress and the United States Constitution, j and for specific relief agaihst the Secretary of the Interior with respect to stich actions. The Acts of Congress which are 1

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being violated are: the Reclamation Act of June 17, 1902, 12 Stat. 3d8, 43 U.S.C. $$ 391 et seq.; the Warren Act of Feb- / v ruary 21, 1911, 36 Stat. 925, 43 U.S.C. 53523-523; the Act of May 18, 1916, 39 Stat. 130; and the Reclamation Project Act of August 4, 1939, 53 Stat. 1187, 43 U.S.C. 55485 et seg. The Constitutional provision which is being violated is.

- the due process clause of the Fifth Amendment.

3. THE PLAINTIFF'S STANDING. The plaintiff's reserva-tion is located along the Salt River in Maricopa County, Arizona, cast of the City of Scottsdale and north of the City of Tempe. It was reserved f rom the public lands of the United States by the Executive Order of President Rutherford D. Hayes, dated June 14, 1879. With the reservation of lands River there was also reserved water from the adjoining Salt sufficient to cultivate the practicably irrigable acreage.

The Plaintiff's lands enjoy other specific water rights under federal law. The Secretary of the Interior has since 1910 asserted total dominion and control over the distribution of the water of the Salt River through the administration of the Salt River Project. In administering the Project the Secretary of the Interior causes direct and substantial injury to the plaintiff by refusing to recognize its federal water rights and by making deliveries of water to others in violation of federal law.

4. DESCRIPTION OF THE SALT RIVER PROJECT. The Salt River Project is a comprehensive water storage and distribution system constructed and owned by the United States pursuant to the Reclamation Act of 1902 as amended. The source of the system's water is a 13,000 square mile mountainous area which drains into the Salt River and tributaries. Water is stored behind four dams on the Salt River and two on the

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• O sam, t:# h verde River which have an aggreeste- capacity of 2,063,943 acre fcut. This water is distributed within the 360 square , ,

mile Salt River Valley through the Project's canal system. .

Water is fed into the canals from the Granite Reef Diversion Dam situated in the eastern part of the plaintiff's reservation.

In a typical year the Project delivers in the Salt River ,

Valley, net of losses from seepage and evaporation, about one million acre feet of which more than 754 is for agriculture and lawn care and less than 25% is delivered to cities (Phoenix, Scottsdale and others) for municipal and industrial uses. The Salt River Project is also the largest power utility in Arizona. The four Salt River dams have hydroelectric facilities; the Project operates four thermal plants in the Salt River Valley; it has participation interests ii. six other thermal plants; and it markets power from the Bureau of Reclamat ion dams on the Colorado River. Its gross revenues exceed $700 million per annum from power sales and are less than $10 million"from water deliveries. From the inception of the Salt River Project the major costs of delivering .

water have been paid by the United States and by power consumers.

5. MANAGLMENT OF ThE SALT RIVER PROJECT. The Interior Depa r traent constructed the original Project facilities and acquired the Salt River Valley canal distribution system during the period 1904-1911. It directly operated the system until it transferred its care, operation and maintenance to the Salt River Valley Water Users' Association (hereafter sometimes referred to as she " Association"), a corporation organized under the laws of the Arizona Territory in 1903.

This transfer was effected by a contract dated September 6,

%e 1917, pursuant to the authority of the proviso clause of

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1914, 38 Stat. 687, 43 U.S.C. 5499. Under supplemental contracts dated March 22, 1937, February 28, 1944, and Japto,..e 13, 1949, there was substituted for the Association the Salt River Project Agricultural Improvement and Power District (hereafter referred to as the " District"), a municipality organized under Arizona law. The Association continues to operate the Project's water system as agent for ti.e District and the District operates the electrical power system. The plaintiff and its members residing on the reservation are excluded from participation in both the Association and the District. The transfer of the care, operation and maintenance of the Salt River Project to the Association and the District did not diminish the Secretary's obligation to administer it in accordance with governing federal law.

6. THE PLAINTIFF'S LAWFUL ENTITLEMENT TO SALT RIVER WATER CONTROLLED BY THE SALT RIVER PROJECT. The plaintiff is entitled to have water from the Salt River .

delivered to its lands by the Salt River Project to the extent of the following specific water rights:

A. The Executive Order of June 14, 1879, creating the plaintiff's reser .sion reserved from the unappropriated water of the Salt R'.ver sufficient water for the productive irrigation of all of the reservation's practicably irrigable lands. The net amount of the practicably irrigable lands is 28,000 acres and the duty of water for these lands is 6 acre feet per acre per year. The annual entitlement of water under this reserved right is 168,000 acre feet per year.

l . B. A decree of the District Court of the Third l

Judicial District.of the Territory of Arizona, entered on f

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I - e 9 0 March 1, 1910, in the case of flurley v. Abbott,_ _et al., , ,

Ho 4564, determined that certain specified lands on the plaintiff's reservation allotted to individual Indian owners had a right to 12,670 acre feet per year which was prior in time to all other water rights in the Salt River Valley; and that certain other specified lands of individual Indians later brought into the reservation had a right as of 1878 to 6,055 acre feet.

C. The Act of May 18, 1916, 39 Stat. 123, directed the Secretary to provide a perpetual water right from the works of the Salt River Project for 631 ten acre allotments. With a duty of water of 6 acre feet per acre this statutory entitlement amounts to 37,860 acre feet per year for allotted lands.

D. The plaintiff's lands are entitled to share in the water dove, loped by storage in the Salt River Project reservoirs on the same basis as lands owned by non-Indians.

This constitutes an entitlement to deliveries of developed water to supplement the water rights described in subpara-graphs A, B and C to the extent that such water may be required for the proper irrigation of plaintiff's practicably

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irrigable lands and subject to its availability on a rational, non-discriminatory sharing basis.

7. ~THE SECRETARY 11AS WRONCFULLY REFUSED TO SATISFY THE PLAINTIFF'S WATER RIGHTS. The Secretary has consistently

'l followed a policy of violating federal law in administering the Salt River Project by refusing to deliver water to

atisfy the Plaintiff's water rights in the following respects:

A. Thq, Secretary h5s never satisfied the plaintiff's federal reserved rights as described in subparagraph 6A. He i

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has moreover consistently refused to acknowledge the existence of such federal reserved rights. .

< v B. The Secretary does acknowledge the validity of the wa M e, rights deer.*ed to allotted lands in Hurley v. R** t_

as described in subparagraph 6B. In most years however he i has failed to satisfy these rights fully. In 1980 for instance, the shortfall was about 8,000 acre feet.

I C. The Secretary has never complied with the mandate of the Act of May 18, 1916, as described in subparagraph 6C. During the period 1916 through 1938 the Secretary refused to deliver any part of this water right. Since 1939 the Secretary has delivered approximately 20,000 acre feet per year in partial satisfaction of this right from water developed by storage in the Salt River Project's Dartlett Dam on the Verde River. .

D. The Secretary denies the plaintiff and its members the right to share in the water developed by storage or otherwise to participate in the benefits of the Salt .

River Project by excluding the plaintiff's lar.ds from the Project's water service area and by denying its members the ri;ht to vote in the Project's managing council e'.ections.

Of all the lands within the boundaries of the Salt River Project only plaintiff's lands are excluded from the Project:'s service area. of all the people residing within the boundaries of the Salt River Project only the Indian memberc of the plaintiff's community are denied the voting franchise in elections for the Project's governing board. The systematic exclusion of Indians from Project participation is based on an order issued by the Secretary on April 14, 1914. The only stated reason for the Indian exclusi'on was that there was insufficient e

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• forty to fifty miles away right lands owned by white people from the Project water source have always been served water

..LigaouJ to the source have never been while 4 1.- 1.Wh acre feet of Project water is being cultivated; and 185,000 i delivered annually as " surplus" water to lands outside the In exclusively selecting Indians and Indian Project boundaries.

lands for exclusion f rom Salt River Project benefits the Secretary maintains an invidious racial discrimination which violates the due process clause of the Fifth Amendment to the United States Constitution.

S. T!IE SALT RIVER PROJECT'S ILLEGAL WATER DELIVERY C Ct1T RACT_S_.

The plaintiff's rights to water as described in B and C, and its right to share in water subparagraphs 6 A, storage as described in subparagraph developed by Project 60, are impaired and diminished by water delivery contracts and arrangements which violate the reclamation laws. The illegal contracts and delivery arrangements are as follows: .

A. The Secretary causes to be delivered to the (RWCD) approximately noosevelt Water Conservation District f 40,000 acre feet of Salt River water per year under color o 1924, between KWCD and the Salt a contract dated October 24, Association which was approved by River Valley Water Users' d d by a the Secretary. This contract was materially superse e stipulation and decree entered in the Superior Court of on September 19, 1940, in the case Maricopa County, Arizona, Association, No.

Salt River Valley Water Users' of Lehane v.

32021C. RWCD is a farm irrigation district lying wholly

,, and the exclusive outside the Salt River Project district is the Warren Act statutory authori,ty for deliveries to it 925, 43 U.S.C. S5523-524. The i of February 21, 1911, 36 Stat.

The Act RWCD arrangement patently violates the Warren Act.

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authorizos the Secretary to enter into deliv*ery contracts. ,

The Secretary or his delegate is not a party to the RWCD contract and he was not a party in the Lehane litigation.

- , T*.e Parren Act Shreats '.'8.tverlea.anly ofM*9ter which is

• excess to the requirements of Project lands. There can be no excess Salt River Project water for delivery to RWCD as long *

)l as the Secretary refuses to deliver water to plaintiff's j

t uncultivated lands within the Project district. The water payment terms of the RWCD contract do not comply with the requirements of t he Warren Act. The amount of water delivered to UWCD is twice that provided for in the Lehane stipulation and decree. The plaintiff petitioned the Secretary on March 27, 1980, to review the RWCD delivery arrangement and the Secreta.y did not respond to that petition.

l D. The Secretary permits the Roosevelt Irrigation Ulstrict (RID) to remove 145,000 acre feet per year of groundwater from the Salt River Project District under color of an agreement between RID and the Salt River Valley Water Users' Association dated August 25, 1921, and amended by agreements dated February 12, 1927 and May 31, 1950, all of which have been approved by the Sacretary. RID is a farm irrigation district lying wholly outside the Salt River Projact District and the exclusive statutory authority for deliveries to it is the Warren Act of February 21, 1911. The Act author-izes the Secretary to enter into delivery contracts. The Secretary is not a party to the RID contracts. The Warren Act permits deliveries only of water which is excess to the requirements of Project lands. The water delivered to RID is not excess water because the Secretary has no water to deliver to the plaintiff's uncultivated lands within the Project. Moreover, the illegal RID pumping on Project lands i

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J di has devastatingly depleted Project groundwater resources to the extent of several millions of acre feet and its continu-ation is irrational and destraet'.. e. The ,* aintif f petitioned the Secretary on March 27, 1980, to review the RID delivery l arrangement and the Secretary did not respond to that petitidn.

C. Tne Secretary delivers approximately 200,000 acre feet per year to cities within the Project's boundaries.

Deliveries to the City of Phoenix were made originally pur-suant to a contract with the Salt River Valley Water Users' Association dated January 1, 1952, which was renewed by contract dated December 30, 1969, for an additional 25 years commencing January 1, 1977. Similar contracts with the Cities of Tempe, Peoria, Gilbert, Mesa, Chandler and Scotts-dale expired on December 31, 1976, but deliveries to them continued under informal arrangements. These delivery arrange-ments violate Section 9(c) of the Reclamation Project Act of 1939, 53 Stat. 1194, 43 U.S.C. 5485h(c), which governs authorizes deliveries for municipal water supply. Section 9(c) the Secretary to enter into delivery contracts. The Secretary .

or his delegate is not a party to the contractual arrangements with the cities in the Salt River Pro]cct. Section 9(c) prohibits sales to cities which impair the efficiency of the Project for irrigation purposes. These delivery arrangements do impede the irrigation purpose of the Project because there is inadequate water to satisfy the requirements and as consistently needs of the plaintif f's lands. Section 9(4) interpreted and put in practise by the Secretary in other reclamation projects, requires the pricing system for sales of water to cities to cover an., appropriate portion of the .

f ull cost of proje,ct construction with interest and the full cost of delivering.the water. The pricing system for the

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/ v cities in the Salt substantial federal of these actual costs because they reflect 11f petitioned the and power revenue subsidies. Thc ,'etn:

1980, to review this arrangement and Secretary on March 27, 8 i tition.

the Secretary did not respond to th s pe The Secretary permits by tacit acquiescence D.

0 acre feet of 4 .

contracts for the sale of more than 100,00 non-Project return flow Project effluent water for remote in disregard of a uses in violation of the Warren Act, rd of the expressed specific mandate of Congress, and in disregaThe return i l concerns of responsible Department offic a s.

is the discharge from the water treatment flow effluent ea. Almost plants operated by the cities in the Projectrces ar and, after all of this water originated from Project sou j t water its first-use purposes are concluded, remains Pro ec Act and other Congres-subject to the terms of the Warren j ined the sional directives. The Congress specifically ent oReport.No.

Secretary from abandoning this resource in Sena e 1967, and II.R. Report No. 1312, dated 408, dated July 26, d 1968.

This water is being temporarily transporte April 24, hich lies by the cities to the Buckeye Irrigation District w Salt River Project. Its wholly outside the boundaries of the d by a contract permanent disposition is purportedly governe as seller, and the dated April 23, 1973 between the cities, i Agricultural Improvement and Power Distr ct 1

Salt River Project his contract and Arizona Public Service, as buyers. Under t sported to an the Project's return flow effluent will be tran for use by an area 50 niles from the Project boundaries ted for the atomic power plant which is b,cing construc -

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primary purpose of selling pow'er to Californ tary for a formal This contract was not presented to the Secre

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illegal. The only lawful and rational use of this return flow is to retain it in Project lands to ease the Project's severe groundwater depletion. The plaintiff petitioned the Secretary on March 27, 1990 to review this arrangement and s'

the Secretary did not respond to that petition.

E. The Secretary permits and condones the delivery of approximately 100,000 acre feet of water per year for country clubs, parks and residential lawn care contrary to the lawful requirement that Project water be first applied to serve the agricultural entitlements and needs of Project lands.

WilEREroRE the Plaintiff prays for the following relief:

1. That the Court issue an order to the Secretary of the Interior requiring him to show cause at a stated time and place why hes hould not respond to the prior petitions of the Plaintiff and why specifically he should not be required:

A. To determine and declare the reserved rights of the plaintif f's lands in the flow of the Salt River and to take all necessary actions to secure, protect and enforce those rights; B. To determine and declare the rights of allotted lands on the plaintiff's reservation to the 18,725 acre feet per year decreed in the case of tturley v. Abbott and to take all necessary actions to secure, protect and enforce tnose rights; 2 ,1 C. To determine and declare the ri 4 .

ten acre allotments on the plaintiff's reserv6.,on g perpetual right to 37,860 acie feet per year of water from j

the Salt River Pr'oject as provided in the Act of May 18, 1916, and to take all necessary actions to secure, enforce and protect those rights; .,

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v il 14, 1914, To cancel the order of Apr h D.

f's lands f rom participation in t e , ,

excluding the plaintif Salt River Project; water delivery contracts a..n E. To review the d in sub-River Project as describe ~~

arrangements of the Salt and declare the B, C, D and E; to determine paragraphs 8A, or fail to comply with the l ry extent to which they comp y tes; and to take all necessa governing reclamation statuify them as required by law; actions to suspend or mod determinations,

2. That the Court that reviewastheseit make a declaration as to may be necessary declarations, and actions; ht it issue orders further action that their lawfulness; and t athe Secretary takes all to assure that with the laws governing the l

and m y be required to comp yof the Salt River Project; ll other a

administration the plaintiff be granted a

3. That ts.

may appear just and that it be awarded its cos ttARXS, SHEA & WILKS

. Shea DY ~~ PhIII ;114 West Adams, Suite 200 Phoenix, Arizona 85003 (602) 257-1126 a

WILLIAMS & JENSE:1, Professional corporation By W.

John J. McMackin, Jr.1101 Connecticut A Washington, D.C. 20036 1

(202) 659-8201 4 e 1

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