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© 2026 Congressional Accountability Tracker

SenateS. Rpt. 119-942025-11-04

TECHNICAL CORRECTION TO THE SHOSHONE-PAIUTE TRIBES OF THE DUCK VALLEY RESERVATION WATER RIGHTS SETTLEMENT ACT OF 2025

← Indian Affairs CommitteeView on GovInfo →

Summary

S. Rpt. 119-94 accompanies infrastructure legislation titled "Technical Correction to the Shoshone-paiute Tribes of the Duck Valley Reservation Water Rights Settlement Act of 2025". Infrastructure bills affect highways, bridges, airports, transit, water systems, broadband, ports, or federal buildings. The Indian Affairs Committee's report describes the infrastructure need, the proposed federal investment or regulatory change, and projected economic and community benefits. Infrastructure reports typically include analysis of safety, efficiency, environmental impact, and regional effects.

Full Text

Official report text. Use Ctrl+F / Cmd+F to search within the document.

Senate Report 119-94 - TECHNICAL CORRECTION TO THE SHOSHONE-PAIUTE TRIBES OF THE DUCK VALLEY RESERVATION WATER RIGHTS SETTLEMENT ACT OF 2025

[Senate Report 119-94]
[From the U.S. Government Publishing Office]

                                                  Calendar No. 261

119th Congress}                                           { Report
                                 SENATE
  1st Session }                                           { 119-94

======================================================================
 
 TECHNICAL CORRECTION TO THE SHOSHONE-PAIUTE TRIBES OF THE DUCK VALLEY 
            RESERVATION WATER RIGHTS SETTLEMENT ACT OF 2025

                                _______
                                

                November 4, 2025.--Ordered to be printed

                                _______
                                

          Ms. Murkowski, from the Committee on Indian Affairs,
                        submitted the following

                              R E P O R T

                         [To accompany S. 546]

      [Including cost estimate of the Congressional Budget Office]

    The Committee on Indian Affairs, to which was referred the 
bill (S. 546) to amend the Omnibus Public Land Management Act 
of 2009 to make a technical correction to the water rights 
settlement for the Shoshone-Paiute Tribes of the Duck Valley 
Reservation, and for other purposes, having considered the 
same, reports favorably thereon without amendment and 
recommends that the bill do pass.

                                PURPOSE

    The purpose of S. 546 is to amend the Omnibus Public Land 
Management Act of 2009 to authorize payment to the Shoshone-
Paiute Tribes of the Duck Valley Reservation (Tribes) in an 
amount equivalent to the unpaid interest that would have 
accrued if interest accrual were permitted on the Tribes' water 
settlement trust funds deposited between October 1, 2009 and 
January 25, 2016.

                          BACKGROUND AND NEED

    The Duck Valley Reservation encompasses 290,000 acres of 
land on the border between Nevada and Idaho, along the East 
Fork of the Owyhee River, a tributary to the Snake River. The 
Reservation was established by executive order in 1877 and 
expanded by executive orders in 1886 and 1910.
    The Tribes have consistently used the water sources on the 
Reservation for agriculture, livestock, and domestic purposes. 
The Reservation, however, lacks sufficient reliable 
infrastructure to provide dependable water for irrigation and 
drinking, and this lack of water infrastructure has been a 
chronic problem since the Reservation was first established in 
1877.
    Inconsistent natural flows and non-Indian settlement north 
and south of the Reservation in Nevada have led to chronic 
water stress and conflict with other water users over 
generations. Additionally, federal attempts to alleviate these 
concerns--including the Bureau of Reclamation's nearby Owyhee 
Project and the Bureau of Indian Affairs' Duck Valley Indian 
Irrigation Project--further complicated water storage and 
economic development on the Reservation.
    For example, in the 1930s, the federal government 
authorized and built the Bureau of Indian Affairs' Duck Valley 
Indian Irrigation Project (Project) to provide water storage 
along the East Fork of the Owyhee River for irrigation and 
stock water purposes on the Reservation. The Project failed to 
provide the Tribes complete relief because the Project's 
primary water storage facility, the Wild Horse Reservoir, was 
located approximately 15 miles from the Reservation, which 
increased potential conflict with off-reservation water users 
and reduced the number of acres available to the Tribes for 
cultivation and other development opportunities. Moreover, the 
Project did not receive sufficient funding for the Tribes to 
perform adequate operation and maintenance activities pursuant 
to their self-governance compact. As a result, the Project 
facilities fell into disrepair, which led to fallow lands and 
sub-optimal production.
    In 2009, Congress enacted the Shoshone-Paiute Tribes of the 
Duck Valley Reservation Water Rights Settlement (``Settlement 
Act'') as part of the Omnibus Lands Act of 2009.\1\ The 
Settlement Act quantified the Tribes' disputed water rights, 
including federal reserved water rights. The Settlement Act 
also (1) resolved the Tribes' claims against the United States 
for its failure to protect the Tribes' water rights and natural 
resources; (2) assisted the Tribes in their efforts to 
rehabilitate the Duck Valley Indian Irrigation Project; and (3) 
provided municipal water supplies and other critical water 
related projects.\2\
---------------------------------------------------------------------------
    \1\Pub. L. 111-11 Sec. Sec. 10801-10809 (2009).
    \2\81 Fed. Reg. 4063-4064 (Jan. 25, 2016).
---------------------------------------------------------------------------
    Specifically, the Settlement Act authorized a total of $60 
million to two Trust Funds for the Tribes to rehabilitate the 
Project and for other activities over a five-year period. 
Between Fiscal Years 2010-2014, $45 million was deposited into 
a Development Fund\3\ and $15 million was deposited into a 
Maintenance Fund.\4\ Pursuant to the Settlement Act, the 
settlement funds began to be appropriated on October 1, 2009, 
and the Department of the Interior (Department) immediately 
began investing the funds, earning interest.
---------------------------------------------------------------------------
    \3\Supra, note 1 at Sec. 10807(b)(3).
    \4\Supra, note 1 at Sec. 10807(c)(3).
---------------------------------------------------------------------------
    On January 25, 2016, and pursuant to the Settlement Act, 
the Secretary of the Interior published a notice of findings in 
the Federal Register making the settlement enforceable.\5\ In 
February 2016, the Department opined that this ``enforceability 
date'' was the earliest date upon which the settlement funds 
could be invested per the terms of the settlement.\6\ 
Accordingly, the Department withdrew all the interest accrued 
before the enforceability date and deposited it in the Federal 
Treasury.
---------------------------------------------------------------------------
    \5\81 Fed. Reg. 4063-4064 (Jan. 25, 2016); Pub. L. No. 111-11 
Sec. 10808(d).
    \6\See Senate Committee on Indian Affairs Legislative Hearing, 
October 6, 2021 (Statement of Brian Thomas, Chairman, Shoshone-Paiute 
Tribes of the Duck Valley Reservation).
---------------------------------------------------------------------------
    The Department agrees that prohibiting investment of a 
Tribe's settlement funds prior to the enforceability date is 
uncommon in Indian water settlements.\7\ In fact, only five 
Tribes are subject to this unusual restriction, and the 
Department supports reimbursement in all five of these 
cases.\8\ S. 546 will provide parity with other Indian Water 
Settlements by authorizing the appropriation of the unpaid 
interest that would have accrued before the enforceability 
date.
---------------------------------------------------------------------------
    \7\See Senate Committee on Indian Affairs Legislative Hearing, 
October 6, 2021 (Statement of Bryan Newland Assistant Secretary for 
Indian Affairs, United States Department of the Interior) (stating 
``[t]he provision in the Duck Valley Settlement Act prohibiting 
investment until an enforceability date is reached is not common in 
Indian water rights settlements. It appears in the Duck Valley 
settlement and other settlements enacted in 2009-2010, including the 
Crow Tribe Water Rights Settlement Act of 2010, Pub. L. No. 111-291; 
the Taos Pueblo Indian Water Rights Settlement Act, Pub. L. No. 111-
291; the Aamodt Litigation Settlement Act, Pub. L. No. 111-291; and the 
Navajo-Gallup Water Supply Project and Navajo Nation Water Rights, Pub. 
L. No. 111-11.'').
    \8\See, id. (stating ``[t]he Department supports S. 648 and, as a 
matter of equity, would support similar legislation to resolve this 
same issue in the four other Indian water rights settlements approved 
by Congress in 2009 and 2010'').
---------------------------------------------------------------------------

                                SUMMARY

    S. 546 authorizes the appropriation of $5,124,902.12 for 
deposit into the Settlement Act's Development Fund. This 
represents the amount of unpaid interest that would have 
accrued if interest accrual were permitted on the Tribes' water 
settlement trust funds deposited between October 1, 2009 (when 
the funds were initially appropriated) and January 25, 2016 
(the enforceability date).

                          LEGISLATIVE HISTORY

    S. 546 was introduced by Senator Cortez Masto on February 
12, 2025, with Senators Crapo, Risch and Rosen as cosponsors. 
On March 5, 2025, the Committee met at a duly convened business 
meeting and ordered S. 546 reported favorably, without 
amendment, by voice vote.
    In the 118th Congress, an identical bill, S. 950, was 
introduced by Senator Cortez Masto on March 22, 2023, with 
Senators Crapo, Risch and Rosen as cosponsors. On March 29, 
2023, the Committee held a business meeting to consider S. 950 
and ordered the bill to be reported favorably, with an 
amendment, by voice vote (S. Rept. 118-80). S. 950 passed the 
Senate on December 18, 2023, by unanimous consent.
    H.R. 1738, identical companion legislation to S. 950 was 
introduced by Representative Amodei in the House of 
Representatives on March 23, 2023. H.R. 1738 was referred to 
the House Committee on Natural Resources.
    In the 117th Congress, a similar bill, S. 648, was 
introduced by Senator Cortez Masto on March 9, 2021, with 
Senators Crapo, Risch and Rosen as cosponsors. The Committee 
held a hearing on S. 648 on October 6, 2021 (S. Hrg. 117-138). 
The Committee held a business meeting to consider S. 648 on 
November 17, 2021, and ordered the bill reported favorably, 
with an amendment in the nature of a substitute. (S. Rept. 117-
93).
    On March 12, 2021, Representative Amodei (R-NV) introduced 
H.R. 1869, identical companion legislation to S. 648. A hearing 
was held on H.R. 1869 in the House Natural Resources 
Subcommittee on Water, Oceans and Wildlife on June 29, 2021.

                        COMMITTEE RECOMMENDATION

    The Senate Committee on Indian Affairs in an open business 
meeting on March 5, 2025, by a majority voice vote of a quorum 
present, recommends that the Senate pass, S. 546, without 
amendment.

                      SECTION-BY-SECTION ANALYSIS

Section 1--Short title

    This section sets forth the short title as the ``Technical 
Correction to the Shoshone-Paiute Tribes of the Duck Valley 
Reservation Water Rights Settlement Act of 2025.''

Section 2--Authorization of payment of interest on trust funds 
        established under settlement

    This section amends section 10807(b)(3) of the Omnibus 
Public Lands Management Act of 2009 (P.L. 111-11) to add a new 
subparagraph that authorizes an appropriation of $5,124,902.12 
for deposit into the Development Fund.

                   COST AND BUDGETARY CONSIDERATIONS

    S. 546 would authorize the appropriation of $5.125 million 
to be deposited into the Shoshone-Paiute Tribes Water Rights 
Development Fund. The fund was established pursuant to the 
Shoshone-Paiute Tribes of the Duck Valley Reservation Water 
Rights Settlement Act of 2009 to rehabilitate water 
infrastructure projects located on the reservation in Idaho and 
Nevada.
    The settlement agreement was made effective in 2016, and 
ownership of the fund was transferred to the tribes to be held 
in trust by the federal government. Assuming appropriation of 
the authorized amount, CBO estimates that implementing the bill 
would cost $5 million over the 2025-2030 period.
    The CBO staff contact for this estimate is Alaina Rhee. The 
estimate was reviewed by H. Samuel Papenfuss, Deputy Director 
of Budget Analysis.
                                         Phillip L. Swagel,
                             Director, Congressional Budget Office.

               REGULATORY AND PAPERWORK IMPACT STATEMENT

    Paragraph 11(b) of rule XXVI of the Standing Rules of the 
Senate requires each report accompanying a bill to evaluate the 
regulatory and paperwork impact that would be incurred in 
carrying out the bill. The Committee believes that S. 546 will 
have minimal impact on regulatory or paperwork requirements.

                 EXECUTIVE TESTIMONY AND COMMUNICATIONS

    The testimony provided by the U.S. Department of the 
Interior from the October 6, 2021, hearing on S. 648 follows:

  statement of bryan newland, assistant secretary for indian affairs, 
                    u.s. department of the interior

s. 648, technical correction to the shoshone-paiute tribes of the duck 
         valley reservation water rights settlement act of 2021

    Aanii (Hello)! Good afternoon Chairman Schatz, Vice 
Chairman Murkowski, and Members of the Committee. My name is 
Bryan Newland. I am the Assistant Secretary for Indian Affairs 
at the Department of the Interior (Department). Thank you for 
the opportunity to present testimony regarding S. 648, the 
Technical Correction to the Shoshone-Paiute Tribes of the Duck 
Valley Reservation Water Rights Settlement Act of 2021.
    S. 648 would amend the Shoshone-Paiute Tribes of the Duck 
Valley Reservation Water Rights Settlement Act to authorize 
funding equivalent to interest payments that would have been 
earned between October 1, 2009 and January 25, 2016 if the 
Department had then had the authority to invest the funds. The 
Department supports S. 648.
            a. Background
    The Duck Valley Reservation, home to the Shoshone-Paiute 
Tribes (Tribes), straddles the IdahoNevada border along the 
Owyhee River, a tributary to the Snake River. The Reservation 
was established by Executive Order on April 16, 1877 and 
expanded by Executive Orders on May 4, 1886 and July 1, 1910. 
The State of Idaho initiated the Snake River Basin Adjudication 
(SRBA) in 1987. Soon thereafter, the State of Nevada reopened 
its adjudication of the Owyhee River, a tributary to the Snake 
River, an adjudication originally initiated in 1924. Both of 
these adjudications involve the water rights of the Tribes. The 
United States filed claims in Idaho's SRBA and Nevada's Owyhee 
River adjudication on behalf of the Tribes.
    At the request of the Parties, a Federal Negotiation Team 
was formed, and a settlement was reached. In 2009, Congress 
enacted the Shoshone-Paiute Tribes of the Duck Valley 
Reservation Water Rights Settlement as part of the Omnibus 
Lands Act of 2009 (Duck Valley Settlement Act). The legislation 
authorized $60 million across two Trust Funds to rehabilitate 
the Duck Valley Indian Irrigation Project, which is owned by 
the Bureau of Indian Affairs and operated by the Tribes under a 
Self-Governance compact, and for other activities. Under the 
legislation, the Trust Funds could only be invested and earn 
interest on the ``enforceability'' date which is the date that 
the Secretary published a statement in the Federal Register 
finding that all conditions for full effectiveness and 
enforceability of the settlement had occurred. The deadline to 
publish the statement of findings was March 31, 2016, and the 
Secretary published it on January 25, 2016.
    Under the Duck Valley Settlement Act, the Secretary had no 
authority to invest the Trust Funds until January 25, 2016. 
However, the Department began investing funds as they were 
appropriated and transferred to the Department. The 
Department's Solicitor's Office determined that the amounts 
earned prior to January 25, 2016 were contrary to the Anti-
Deficiency Act and, in accordance with 31 U.S.C. Sec. 3302, 
must be returned to the Federal Treasury. Accordingly, the 
Department returned to the Treasury all interest accrued before 
January 25, 2016.
    S. 648 would authorize the appropriation of the interest 
that would have accrued on balances in the Trust Funds during 
the period beginning on October 1, 2009 (when the funds were 
initially appropriated), and ending on January 25, 2016 (the 
enforceability date), for deposit into the Trust Funds.
            b. Department's Views
    The provision in the Duck Valley Settlement Act prohibiting 
investment until an enforceability date is reached is not 
common in Indian water rights settlements. It appears in the 
Duck Valley settlement and other settlements enacted in 2009-
2010, including the Crow Tribe Water Rights Settlement Act of 
2010, Pub. L. No. 111-291; the Taos Pueblo Indian Water Rights 
Settlement Act, Pub. L. No. 111-291; the Aamodt Litigation 
Settlement Act, Pub. L. No. 111-291; and the Navajo-Gallup 
Water Supply Project and Navajo Nation Water Rights, Pub. L. 
No. 111-11. In each of these settlements, funds were 
inadvertently invested and were returned to Treasury. In total 
for the five settlements, over $11 million was returned to the 
Federal Treasury. The Department supports S. 648 and, as a 
matter of equity, would support similar legislation to resolve 
this same issue in the four other Indian water rights 
settlements approved by Congress in 2009 and 2010.

                        CHANGES IN EXISTING LAW

    In compliance with subsection 12 of rule XXVI of the 
Standing Rules of the Senate, the Committee waives the 
requirement to detail changes in existing law to expedite the 
business of the Senate.

                                  [all]