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a complex natural system such as a national park or other natural area. The Idaho Supreme Court has, however, held that a claim to the entire natural flow, provided it is proved necessary, is an adequate quantification.' Quantification in the manner suggested is not without problems, however. The problems are not legal or techni- cal. One problem arises from the apparent expectation of Congress, the states, and others, that federal reserved rights for existing natural-area reservations can and will be numerically quantified. This problem must be resolved in the courts. Also, quantifying reserved rights as the natural flow, subject to valid rights existing at the time of the reservation, has the effect of precluding any further devel- opment upstream of a natural-area reservation that would consume any water or change the timing of the natural flow. Of course, this is a problem only where the natural area is downstream of private interests having the need or desire to develop water. In such cases for new reservations or designations, Congress should specify that the reserved right is the natural flow, subject to valid existing rights and, further, subject to an annual amount which may be diverted for use upstream of the reservation. This may be compromising the purpose of maintenance of natural conditions. However, it is the Congress alone that has the power to make such a compromise. Conclusions The amount of water required to accomplish the purpose of natural-area reservations is the hydrologic regime existing at the time of the establishment or designation. It is not possible to quantify the hydrologic regime numerically. However, the natural flows (or levels for lakes and ponds) subject to valid rights having priorities senior to the reservation date is a legally and technically sound approach to the problem of quantifying instream flows for federal natural-area reservations. I Cappaert v. United States, 426 U.S. 128,138 (1976). 2 Id. 1 16 U.S.C. § 1. 2 The existence of implied reserved rights for wilderness areas superimposed on existing national forest and national park reservations is not certain because the Wilderness Act also provides that its purposes are "within and supplemental to" the purposes of the original reservations. 16 U.S.C. 1133(a). In United States v, New Mexico, 438 U.S. 696 (1978), the Supreme Court relied on similar language in the Multiple-Use Sustained-Yield Act to draw the critical distinction between primary reservation purposes and secondary uses for which no water was reserved. See "Federal Reserved Rights" in the proceedings of the First Western Regional Instream Flow Conference at 3-4. However, Congress has in some recent wilderness designations, provided expressly for the reservation of water to fulfill the purposes of the Wilderness Act. 1 16 U.S.C. § 1131. 2 Id. 3 16 U.S.C. §§ 1271 et seq. 1 16 U.S.C. § 1284(c). 2 16 U.S.C. § 1286(b). 3 Colorado Public Interest Group v. Train, 507 F.2d 743 (10th Cir. 1974) reviewed on other grounds, 426 U.S. 1 (1976). 4 United States v. American Trucking Associations, 310 U.S. 534, 543 (1940); Crane v. Commissioner, 331 U.S. 1, 6 (1947). 5 Webster's New International Dictionary, 2d Ed. (1952). 1 H.R. Rep. No. 700, 64th Cong., 1st Sess., 3 (1916). 2 Id. 3 Cappaert, 426 U.S. at 141. 1 As previously discussed, reserved rights are out of waters that are unappropriated at the time of the reservation. A reserved right could not be exercised to cause cessation or curtailment of diversions existing at the time of the reservation. Therefore, the term "natural hydrologic regime" as used in this paper means either virgin conditions or the hydrologic regime existing at the time of the reservation. 1 United States v. Denver, 656 P.2d 1, 20 (Colo. 1982). 2 Avondale Irrigation District v. North Idaho Properties, 577 P.2d 9, 19-20 pdaho 1978). 22