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^ 0081 (1) when land is reserved from the public domain for a specific' federal purpose (see United States v. New Mexico, supra); or (2) when state regulatlon of the use of water bya federal agency or licensee is inconsistent with specific congressional directives governing the construction or operation of a federal project requiring the use of water (see California v. United States, supra). ill --- a. Federal reserved rights It is now settled that when the federal government reserves land for a particular federal purpose, it also reserves, by implication, enough unappropriated water as is reasonably necessary to accomplish the purposes for which Congress authorized the land to be reserved, without regard to the limitations of state law. The right to that water vests as of the date of the reservation, whether or not the water is actually put to use, and is superior to the rights of those who commence the use of water after the reservation date. See Cappaert v. United States, 426 U.S. 128, 138 (1976); Unitea-5tates v. New Mexico, supra, 438 U.S. at 698. --- Although the reserved rights doctrine is now well-recognized, its contours and scope have been defined only recently. The doctrine had its origins in United States v. Rio Grande Dam & Irrigation Co., 174 U.S. 690 (1899). In that case, the Court upheld an lnJunction restraining the petitioner from constructing an irrigation dam that would have destroyed the navigability of the Rio Grande River. While the Court recognized that Congress had by statute acquiesced in the substitution of appropriative water rights for common law riparian rights in the western states (see p. 20 supra), it found that Congress had not waived i~superior authority under the Commerce Clause to preserve the navigability of navigable waters. The Court listed two "limitations. inherent in the Supremacy Clause on the authority of the states to change the common-law rules: First, that, in the absence of specific authority from Congress, a state cannot, by its legislation, destroy the right of the United States, as the owner of lands bordering on a stream, to the 431 As we dlSCUSS lnfra, the constitutional basis for federal water rights is the same in both circumstances enumerated above, whether the rights fall within the .reserved" rights category or within the category of "specific congressional directives.. Because the Supreme Court has developed the reserved right doctrine in a few, well-defined cases, for clarity we will Set out the decisions in these two categories separately. - 25 -