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G818 . . -, J.UHI;l"" 19501 The lands were arid, and, ,,;thout irrigation. were practically ,'a1ue. less. I 1 TIlc' eSsence of the Court's reasoning, which lies at the very heart of thc' Il'inters doctrine, was that a reservation of water was necessary in N,kr to ensure that the lands reserved for Indians would support "criLu\tural use and a civilized lifestyle.' 2 In other words. the pur- p~)Se of creai::lg the Ft. Belknap reservation was to provide a perma- n~nl homeland for Indians. Therefore, it was necessary to assure that c"mcient water was available to meet that purpose. A similar ratio- nak was applied in United Stales v. Powers,' 3 in which the Supreme Court found the existence of an implied reservation of water suft!- Lic'nt for the settlement and cultivation of lands within the bound- "ries of the Crow Indian Reservation, ~Iore recently, in ArizolJa v. California." the Supreme Court """in dealt with the question of the purpose of the implied regerva- t;on of water under the Winters doctrine, In this landmark decision, the claims of five Indian reservations located along the mainstem of the Colorado River were at issue." Arizoila attacked the claims for water asserted by the tribes and also challenged a special master's determination of the quantities of water which were reserved for the tribes. In its decision, the Supreme Court reviewed the history sur- rounding the creation of the five reservations and found evidence indicating a legislative intent to establish irrigated agriculture on the reservations. Consequently, the Court rejected the argument that the United States had created the Indian reservations without intending to reserve waters necessary to make the reservations productive for agriculture.' 6 The lesson from these Supreme Court decisions is that the transfer- ability of Winters water rights to off-reservation uses is limited for two reasons. First. Winlers rights were created as an adjunct to land and have no existence apart from that land. Second, Winlers rights were intended to have only a limited purpose.' 7 Thus, where the TRnSFERABIL1TY OF INDIA."! \\'A TER RIGHTS 93 II. Jei.t576. 12. Jei 13. Unilcd States v. Po\\,'crs, 305 U.S. 527.533(938). A brief synopSIS of this case ;J.ppC3.r~ below. \4. 373 U.S, 546 (1963). 15. These rcser\'atiom were Chemchue\"j, Cocop3h, Yuma. Colorado Rive; and ron .\Iohi'ovc. 16. 373 U.S. at 600. 17. The \.je..... that k'inters rights ma~' be confined to usr: on the re~er\"ation to which lhc~ a:1,; appurtenant .....as share.:! in an unpublished letter from lhe Solicitor's Ofrice. Departmenl 0:. Imerior. to the Office 01 the CaJU.ornia Altorney GcnerJ..i. da!ed September 16. 1970. "filCh addressed the proposed sale of .....a ter by the Chemehuevi Indian Tribe to the HJ.~'asu \\.1te. Compan}'. .