held by Los Angeles were granted in absence of consideration of the effects of the diversions on the public trust resources of the Mono Basin and that the allocation of water from the basin streams should be reconsidered. The state has a "duty" to protect the public's "common heritage of streams, lakes, marshlands, and tidelands." The court also ruled that the State Water Resource Control Board (SWRCB) and the courts have concurrent jurisdiction to consider the effect of water diversions on public trust resources. The court ordered a study to be prepared to determine the impact of DWP's diversion upon the public trust of Mono Lake. In subsequent proceedings following this decision, DWP has been ordered to reduce diversions by approximately two thirds until the water levels in Mono Lake recover to an acceptable level (expected to take decades). Dissent Richardson concurred with parts one through four of the majority opinion (background and history of the Mono Lake litigation; the public trust doctrine in California; The California water rights system; and, the relationship between the public trust doctrine and the California water rights system) and with the analysis of the relationship between the public trust doctrine and the water rights system in this state. However, Richardson entered a dissent from part five of the opinion (exhaustion of administrative remedies) where the majority held that the courts and the California Water Resources Board have concurrent jurisdiction in cases of this kind. Richardson's dissent of part five concluded, "The majority's suggestion that various statutory provisions contemplate the exercise of concurrent jurisdiction in cases of this kind is unconvincing." In support of this, Richardson cited the Water Code (§§ 2000, 2001, 2075) as well as Environmental Defense Fund, Inc. v. East Bay Mun. Utility Dist (1980) and (1977). Legal and policy implications The decision of the court expanded the reach of the public trust doctrine to non-navigable tributaries of navigable waters. This allows for legal challenges to be made to administrative decisions made by the state in regards water appropriations where natural resource values are affected. This potential for legal challenge on the basis of natural resource values forces administrative decisions to include specific consideration of long-term resource impairment in tandem with economic development. Therefore, although the public trust doctrine doesn't preclude the conveyance of water rights to a private party where a natural resource held in the public trust may be affected,