Arizona Department of Water Resources (ADWR) has posted the comments received on their proposed process for reallocation of the 96,000 acre-feet of Non-Indian Ag (NIA) water in the CAP system. Several of the comments echo my points (with additional elaboration) on some of the failings of the proposed process. Unfortunately, no one else suggested that a market mechanism for allocation would be appropriate. Of course all the other comments were from actual stakeholders who might want to be granted rights to some of this water. I acknowledge that a market is probably not in their self-interest. I think it's not inconceivable, though, that some of the industrial users (mining companies) might be willing to get behind the idea, as they would be likely to come out ahead of many of the municipal users - at least in the short-term. But in strict dollar terms they are probably better off with an administrative allocation process.
The one idea that no one seemed to get behind was the proposal by CAP to impose a reliability charge with this water to establish a fund that would attempt to firm up this somewhat unreliable supply. That was certain to be a tough sell. Seems like most users would rather deal with supply reliability issues on their own. I'll try to update again when ADWR posts the responses to the comments received, but it will likely take a while.