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. . .. . . . the reservation doctrine frustrates sourrl planning in the public am private sectors of the econany. The prospective claims of the governrrent are highly uncertain as to time, manner am quantity of use. Consequently, no pla.nJ1er or investor can establish a rreaningful water budget. It is im- p:lssible to prove how =y non-federal projects were not urrlertaken because of these uncertainties, but stat6Tlents to the Crnnnission revealed profound concern on the part of state officials." 23/ . Con=rent with the develq::nent of the reservation doctrine. the Supr6Tle Court was narro.vly construing the scope of the state role urrler the reclamation laws. Astonishing though it seems, since 1902 when the Reclamation Act was enacted, the Suprerre Court, prior to its rrost recent decision, had decided only three cases which actually presented questions of interpretation of Section 8 of the Act: Ivanhoe Irrigation District v. McCracken, 24/ City of Fresno v. California, 25/ am Arizona v. California. 26/ - Both Ivanhoe am City of Fresno dealt with the ~ct of Section 8 up:ln the 160-a=e rule and up:m the irrigation priority provision of the reclamation laws. The Court determined that where Congress has laid d= a specific am marrlatory prerequisite as binding in the operation of reclamation projects, that specific marrlate may not be ignored in favor of a general p:llicy of deference to state law. This reflects a quite narrow am traditional canon of statutory interpretation that the . specific controls the general. Nevertheless, the Court in both cases proceeded to discuss the Section generally in the broadest p:lssible tenns. 27/ "As we read Section 8," the Court said in Ivanhoe without any expla..'1ation or citation of authority, "it merely requires the United States to oorrply with state law when, in the construction and operation of a reclamation project, it becanes necessary for it to ao::ruire water rights or vested interests therein." 28/ This very sweeping limitation was reinforced in the City of Fresno case. There, after noting disapprovingly the city's claim that Section requires campliance with California's state statutes relating to the priority of danestic over irrigation uses, Mr. Justice Clark said that the effect of Section 8 in such a case is to leave to state law the definition of the property interests, if any, for which ccmpensation must be made. This interpretation of Section 8 would apparently elimin- ate state law entirely fran control Oller the distribution ani use of project water, ani would represent a total repudiation of the states I p:lsition. It was, in fact, an alm::>st verbatum adoption of the inter- pretation which the United States in its briefs had urged up:ln the -Court. With their very narro.v holdings and very broad dicta, these cases left the status of Section 8 clouded in considerable W1Certainty. ~ In the subsequent case of Arizona v. California, a central issue was how the waters app:lrtioned to each state were then to be distributed to users within the state. The case rose under the Boulder Canyon Project Act, 30/ a separate reclamation law dealing with the waters of the lower Colorado. Section 14 of that Act incorporates by reference Section 8 of the 1902 Act. . -4- 90.