and high tide lines for "fishing, fowling and navigation," traditional rights going back to the Colonial Ordinance of 1647. Maine's Supreme Court in 2011 expanded the public trust doctrine by concluding fishing, fowling and navigation are not an exclusive list; the court allowed the general public to cross private shoreline for scuba diving. The public trust doctrine also finds expression in the Great Pond law, a traditional right codified in case law and statutes in Massachusetts, Maine, and New Hampshire. The state is said to own the land below the low water mark under great ponds (ponds over ten acres), and the public retains in effect an access easement over unimproved private property for uses such as fishing, cutting ice, and hunting. In Oregon, a 1967 "Beach Bill" affirmed the state's public trust doctrine, and the right of the public to have access to the seashore virtually everywhere between the low and high tide marks. In California the situation is more complicated: private landowners often try to block traditional public beach access, which can result in protracted litigation. Freshwater use rights have also been subject to litigation in California, under the public trust doctrine. In England and Wales, there is no general public right to access the foreshore. Most land between the high and low water marks is owned by the Crown Estate, who permit access for recreation, but the courts confirmed in 1821 in the case of Blundell v Catterall that there is no right of access such as the public trust doctrine. The only public right over the foreshore is to pass over it, on water in a boat, for the purposes of fishing. Natural resources The doctrine has also been used to provide public access across and provide for continued public interest in those areas where land beneath tidally influenced waters has been filled. In some cases, the uses of that land have been limited (to transportation, for instance) and in others, there has been provision for public access across them. The doctrine has been employed to assert public interest in oil resources discovered on tidally influenced lands (Mississippi, California) and has also been used to prevent the private ownership of fish stocks and crustacean beds. In most states in the United States, lakes and navigable-in-fact streams are maintained for drinking and recreation purposes under a public-trust doctrine. In some countries, the public trust doctrine has been