Excerpt from the Letter:

“Mojave objects to the proposed Plan for three principal reasons. First, to-date, many stakeholders, particularly those engaged in the cultivation of agriculture, have been denied procedural and substantive due process in the IWVGA’s development of the Plan. Second, Management Action No. 1 and the underlying modeling scenarios prioritize claims to water and allocate available water supplies among water right holders in a manner that is inconsistent with well-established principles of common law water rights and therefore contravene the Sustainable Groundwater Management Act’s (SGMA) express prohibition on determining or altering common law water rights. Last, the assumptions set forth in the Plan and the modeling scenarios developed to-date, to the extent that they can be discerned, lack scientific or factual support. In the spirit of collaboration, this letter provides recommendations to rectify the concerns and deficiencies identified herein.”

The full letter can be downloaded here:

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