a method for those claiming an appropriative water right to record their claims with the county recorder of each county. In 1886, the courts addressed competing claims between riparians and appropriators in the case of "Lux v. Haggin." However, within 25 years, excessive claims to water rights threatened to affect economic development in the state. In response, the governor formed a Water Commission to make recommendations regarding California's water law. In 1913, Californian voters adopted by referendum the Water Commission Act, which created the state Water Commission and set forth an administrative procedure for acquiring an appropriative right. In 1926, the courts held that a riparian water user was entitled to the full flow of a stream, without regard to the reasonableness of the use. In response, in 1928, the California Constitution was amended to require that all water use in California be reasonable and beneficial. (Article X, Section 2). 1875–1900 In 1878, William Hammond Hall of the Office of State Engineer conducted a series of investigations in California's Central Valley and drafted a series of plans calling for various publicly funded and owned irrigation projects. Hall's study was accomplished on a budget of $100,000. The Central Valley continued to grow in the absence of a state-run project, yet Central Valley landowners and coastal cities (including San Francisco) managed to acquire water rights in the Sierra Nevada mountain range for use in the valley. 1900–1925 In response to growing political and legal contests for limited water resources, the Water Commission Act of 1913 established the Water Commission to oversee permits associated with the rights to use surface water. The Water Commission Act became effective on December 19, 1914. Landowners or water users that had established water usage prior to 1914 became senior water rights users in many of the more accessible watersheds in the state. Appropriative water rights were processed by the Division of Water Rights, originally under the State Engineer, and subsequently under the Department of Water Resources, the State Water Rights Board, and finally, the State Water Resources Control Board. In 1919, Col. Robert B. Marshall, Chief Surveyor for the U.S. Geological Survey, proposed a plan for the federal government to build a series of diversion dams, and two grand canals along the sides of the Sacramento and San Joaquin Valleys, consequently irrigating California's Central Valley. Though national interest in Marshall's plan was limited, there was an interest