Bullhead weighs Lake Mead credits for recycled wastewater

BULLHEAD CITY — Bullhead City already returns treated wastewater to the Colorado River. Now it is exploring a way to earn conservation credits that could reserve some of that saved water for future use.

The City Council is scheduled to consider the proposal Tuesday, Nov. 3, as item 4 on its regular meeting agenda. City staff describes the potential to create up to 5,000 acre-feet of conservation credits annually through the Section 10 Wastewater Treatment Plant.

The decision would be an early step. The staff report and proposed exhibit say council approval would allow work on an agreement with the U.S. Bureau of Reclamation to continue. The final agreement would return for a separate vote, and approving the exhibit would not obligate the city.

Recovering water that once evaporated

The proposal concerns what happens after wastewater is treated. Section 10 receives wastewater from Bullhead homes and businesses, according to an Arizona Department of Environmental Quality permit-renewal notice.

The city exhibit describes two routes back to the river: direct discharge through a pipe and infiltration basins that send treated water into the connected aquifer. Recovering that water reduces losses from evaporation ponds.

There is a financial incentive behind the request. The exhibit says operating the direct-discharge system costs more than using evaporation ponds, and that conservation credits would give the city a reason to continue incurring that expense.

Existing savings, a different kind of credit

Bullhead’s recovery effort dates back more than a decade. A 2021 Reclamation report traces the project to a 2015 agreement and says its injection-well system began operating in September 2017. The report also documents early performance problems, with initial recovery falling below expectations.

More recent records show substantial returns. Reclamation’s 2025 water-accounting report records 3,776 acre-feet for Bullhead under the Pilot System Conservation Program. Its accompanying explanation says that program’s water benefits reservoir storage generally and does not accrue to an individual water user’s use.

The proposed approach would use a different category, Extraordinary Conservation–Intentionally Created Surplus, or EC-ICS. It contemplates credits stored in Lake Mead, with future delivery to Bullhead governed by a separate agreement. This is a water-accounting arrangement; it does not involve pumping the city’s wastewater upstream to Lake Mead.

The proposed 5,000-acre-foot annual ceiling should therefore not be read as 5,000 acre-feet of additional savings on top of existing recovery. The exhibit expressly bars counting the same reduction both as system conservation and as ICS.

What still has to happen

Federal approval and accounting rules would still matter. Reclamation’s 2027–2028 operating guidelines make new ICS creation after 2026 contingent on a Lower Division States agreement and require approval of individual creation plans. They also impose deductions and limits on future deliveries. The city’s proposed maximum is not a guaranteed balance of usable credits.

The council meeting begins at 5:30 p.m. Nov. 3 in the council chambers at 1255 Marina Boulevard. The agenda allows public comment when the item is considered.