users can use the remaining water for their own beneficial purposes provided that they do not impinge on the rights of previous users; this is the priority element of the doctrine. But neither can a senior user change the manner (i.e., location) in which they appropriate water to the detriment of a junior user. These Preservation of Conditions were granted to the second user after Farmers High Line v. City of Golden (CO 1954). Beneficial use is commonly defined as agricultural, industrial or household use. The doctrine has historically excluded ecological purposes, such as maintaining a natural body of water and the wildlife that depends on it, but some jurisdictions now accept such claims. The extent to which private parties may own such rights varies among the states. Each water right has a yearly quantity and an appropriation date. Each year, the user with the earliest appropriation date (known as the "senior appropriator") may use up to their full allocation (provided the water source can supply it). Then the user with the next earliest appropriation date may use their full allocation and so on. In cases of water shortages, prior-appropriation does not require a senior user to utilize less water than usual. Therefore, during times of drought, users with junior appropriation dates might not receive their full allocation or even any water at all. When a water right is sold, it retains its original appropriation date. Only the amount of water historically consumed can be transferred if a water right is sold. For example, if alfalfa is grown using flood irrigation, the amount of the return flow may not be transferred, only the amount that would be necessary to irrigate the amount of alfalfa historically grown. Prior appropriation rights are subject to certain adverse possession-type rules to reduce speculation. Withdrawal rights can be lost or shrunk over time if unused for a certain number of years, or if a litigant can demonstrate that the water's use is not beneficial. Abandonment of a water right is rare, but occurred in Colorado in a case involving the South Fork of San Isabel Creek in Saguache County. Interaction with other allocation methods In some states, junior upstream water users may take water from downstream users, as long as they return the water in comparable quantity and quality. California and Texas grant waterfront property owners water allocations prior to any other users, in a