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Thou shall not covet thy neighbor's water: a look at the journey both Texas and the Middle East must embark upon to solve the kinks in their water regulation.


by Frederick, James A.

I. INTRODUCTION II. BACKGROUND

A. Texas Background

1. Original Adoption

2. From Tort Doctrine to Vested Property Right

3. Defining Absolute Ownership

4. Now Enter Senate Bill 1

5. Present Day Ownership

6. Persistence of the Rule of Capture

B. Middle East Background

1. Setting the Stage for Conflict

2. Turkey--Syria Iraq

3. Jordan Palestine--Israel

4. Saudi Arabia III. PROSCRIPTIVE MEASURES FOR BOTH TEXAS AND THE MIDDLE EAST

A. Reasonable Use Standard

B. Desalination IV. CONCLUSION

I. INTRODUCTION

When you think Texas, you likely picture the current President of the United States of America, George W. Bush. And, when you think President Bush, you likely think of the war in the Middle East. Regardless of political views on the matter, this serves as a connection between Texas and the Middle East. Yet, there is another, less obvious, connection that exists between these two areas: both face the challenge of how to structure their water regulation systems in order to preserve water for future generations. (1) After looking at the insufficient water regulations of Texas and countries in the Middle East, it becomes clear that both areas will need to undergo a massive overhaul in water regulations to ensure they preserve access to water. Each area will present two separate problems with regard to water regulations, but both may benefit from the same proscriptive measures in attempting to solve their water regulation problems.

II. BACKGROUND

A. Texas Background

1. Original Adoption

The English rule of capture (2) was adopted in the 1904 Texas case of Houston & Texas Central Railway Co. v. East. (3) In East, the plaintiff brought suit against the defendant railroad company for damages caused by digging a well that made the plaintiffs well run dry. (4) The Texas Supreme Court relied on the principles set forth in the English case of Acton v. Bundell to determine that one had a right to dig a well and, if that digging resulted in the drying of a neighbor's well, it would be deemed unactionable. (5) The East court necessitated the rule of capture doctrine by looking toward the principles set forth in Frazier v. Brown. (6) In Frazier, the Ohio Supreme Court found that no correlative rights with regard to underground percolating waters were recognized by law. (7) In justifying its decision, the Ohio court focused partly on policy considerations:

1. Because the existence, origin, movement and course of such waters, and the causes which govern and direct their movements, are so secret, occult and concealed, that an attempt to administer any set of legal rules in respect to them would be involved in hopeless uncertainty, and would be, therefore, practically impossible. 2. Because any such recognition of correlative rights, would interfere, to the material detriment of the common wealth, with drainage and agriculture, mining, the construction of highways and railroads, with sanitary regulations, building and the general progress of improvement in works of embellishment and utility. (8)

During this time, courts treated the rule of capture as a tort doctrine with regard to neighbors and the pumping of water. (9)

2. From Tort Doctrine to Vested Property Right

In Texas Co. v. Burkett, (10) the Texas Supreme Court fortified the rule of capture by interpreting it to be a vested property right and no longer a tort doctrine. In Burkett, the plaintiff sought to enact a contractual agreement with the defendant. (11) The defendant argued that the plaintiff did not own water and that the water actually belonged to the state; therefore, the plaintiff did not have a right to sell. (12) The court disagreed with the defendant and ruled that the plaintiff "plainly had the right to grant access to [streams] and the use of their waters for any purpose...." (13) The court in Burkett created a common law rule classifying water ownership as a vested property right. (14) There has been criticism with regard to groundwater falling under the umbrella of property rights. (15) Water ownership cannot satisfy the characteristics of an "efficient property rights system" including universality, exclusivity, transferability, and enforceability. (16)

3. Defining Absolute Ownership

After Burkett, other Texas courts began following the lead by interpreting East as expressing an absolute ownership principle. (17) The Texas Legislature codified this sentiment by enacting the Texas Underground Water Conservation Act of 1949, which recognized ownership and rights in underground water of "the owner of land, his lessees and assigns." (18) The years following the state legislature's adoption of the absolute ownership principle gave preference to protecting the water rights of farmers and ranchers. (19) This can be largely attributed to the rural influence present in that particular legislature. (20) Not until the 1960s--when legislative seats were being redistricted--did the Texas Legislature witness a rise in urban interests. (21) These urban interests viewed water in the agricultural sense until the 1980s. (22)

Notably, a majority of other states do not recognize private ownership of groundwater. (23) It is important to distinguish two types of water when discussing water ownership: surface water and groundwater. (24) Both surface water and groundwater have "different allocation rules, distinct conflict resolution frameworks, and separate administrative agencies." (25) In recognizing the value of water resources, however, the Texas Legislature has expressed a common goal of effective utilization of both groundwater and surface water sources to meet the present and future water needs in Texas. (26)

4. Now Enter Senate Bill 1

In 1997, the Texas Legislature enacted Senate Bill 1, which demonstrated that groundwater regulation should be "tailored to meet local water supply and population needs." (27) In order to accomplish this goal, the Texas Legislature created Underground Water Conservation Districts (UWCD). (28) Texas regulates its groundwater with UWCDs instead of using a regulatory scheme that creates a uniform set of rules across the state. (29) Subject to regional and state approval, UWCDs give residents who live close to water sources the power to establish rules with regard to water management. (30) This requires that each district analyze both available and anticipated water supply and demand in that particular district. (31) Once this analysis is completed, districts are to develop a plan addressing their management goals and objectives. (32) After this plan is submitted and approved by the Texas Water Development Board (TWDB), it is then integrated into the regional water plan and serves as the basis of action for a district. (33)

5. Present Day Ownership

The present day understanding of the rule of capture rests on the idea that a "landowner possesses the water beneath the surface by virtue of control over the surface." (34) Three principles guide the rule of capture in Texas: (1) water under the land belongs to the owner; (35) (2) the owner or assignee may pump as much water as he likes without being held accountable to others affected; (36) and (3) a party may sell whatever water is pumped to third parties, and such water may be used in other locations. (37)

To better understand the rule of capture, one must examine the limitations in place for owning, pumping, and selling groundwater. (38) One limitation on water ownership is the defining of exactly what water belongs to the state and what water belongs to the surface owner. (39) There are four categories of groundwater sources that determine to whom the water belongs: (1) underflow, (2) underground stream, (3) artesian, or (4) percolating. (40) Underflow of a watercourse and underground streams in defined channels belong to the state. (41) Watercourse underflow is defined as the portion of a surface watercourse that flows through sand and gravel deposits beneath the surface of the stream bed. (42) Courts will treat underground streams in defined channels as surface water--thus, not the sole property of the surface owner--if it has the same characteristics of a surface watercourse. (43) These characteristics include the presence of banks, beds that form a channel, and a current of water. (44) The importance of the artesian water restriction involves statutory provisions that prevent waste of this source and require permits for its withdrawal. (45) Percolating water belongs solely to the surface property owner. (46) Once a landowner has ownership over percolating water, further limitations are set in place to restrict what kind of usage may occur. (47)

There are two common law restrictions on a landowner's right to capture, pump, and sell percolating water. (48) First, a surface owner may not "maliciously take water for the sole purpose of injuring his neighbor ... or wantonly and willfully waste it." (49) There is, however, criticism of this limitation because some feel that proving the malice intent element is too difficult and, therefore, makes such a limitation ineffectual. (50) Additionally, there is a belief that the Texas Supreme Court created a major escape hatch by stating that "waste" refers only to "waste in use" and not "water lost during transport." (51) This distinction between use and transport was articulated in City of Corpus Christi v. City of Pleasanton where the court allowed a city to extract ten million gallons of water a day for transport without classifying it as waste. (52) The Texas Supreme Court, however, later came back in Bragg v. Edwards Aquifer Authority (53) with a broader definition of "waste" as it applied to the rule of capture limitation. It has been suggested that Bragg "opened the door for future Texas Legislatures to finally empower locally elected groundwater conservation districts with the powers necessary to regulate groundwater withdrawals without running afoul of the rule of capture." (54)

The second limitation stipulates that a landowner may not cause subsidence in neighboring land to occur through use of water on his land. (55) This limitation was created in Friendswood Development Co. v. Smith-Southwest Industries where the Texas Supreme Court ruled that a negligent subsidence exception allows for deterrence of excessive underground water withdrawals and resulting land subsidence. (56) The basic policy behind the court's ruling rested on the idea that "ownership and rights of all landowners will be better protected against subsidence if each [landowner] has a duty to produce water from his land in a manner that will not negligently damage or destroy the lands of others." (57)

With these restrictions in place, however effective they may or may not be, the rule of capture still allows a landowner to appropriate waters while on his land and make whatever use of that water he chooses. (58) All of this is without regard to the fact that his use may cut off the flow of water toward neighboring land, thus depriving that neighboring landowner of water use. (59)

As one might imagine, the rule of capture has led to controversy, (60) but more importantly, it has also led to a massive depletion of water supplies. (61) A major part of this depletion can be accredited to the large growth of urban areas in Texas, which has put a strain on groundwater resources. (62)

6. Persistence of the Rule of Capture

With all of its negative effects and the inundation of criticism with regard to the rule of capture, why do courts still adhere to it? Two justifications have been posed to help answer this question: reliance on the rule and legislative deference.

For courts adhering to the rule of capture, reliance is an ever-weakening argument as time progresses and water management problems increase. (63) One rationale that has been offered to explain why reliance is a diluted basis for following the rule of capture is that although a landowner can rely on this rule to release him from liability for pumping his neighbor's well, this same landowner, in turn, realizes that the rule does not protect his well from his neighbor. (64) In fact, rural parties, such as farmers and ranchers--once the most devoted of supporters for the rule of capture and antiregulation (65)--now stand as parties calling for regulation in order to create "firm water rights." (66)

This leads to the next justification for sticking with the rule of capture: legislative deference. Texas courts point to the Texas constitution, which states that "the preservation and conservation of all such natural resources of the State are each and all hereby declared public rights and duties[,] and the Legislature shall pass all such laws as may appropriate thereto." (67) An example of such application is Sipriano v. Great Spring Waters of America, in which the court stated that "[i]t would be improper for courts to intercede at this time by changing the common law framework within which the Legislature has attempted to craft regulations to meet this state's groundwater-conservation needs." (68) This decision was due to the then-recent passing of Senate Bill 1 and the legislature's creation of a water district system to address water concerns for individual areas. (69)

Although the Texas Supreme Court has yielded to the legislature, lower Texas courts have not given such deference to Senate Bill 1. (70) In South Plains Lamesa Railroad v. High Plains Underground Water Conservation Dist. No. 1, plaintiff landowner brought action against the water district for revoking a water well permit and denying another. (71) The court held that the water district lacked the authority to deny and revoke water well permits for "disproportionate taking" in relation to track size and, by doing so, exceeded their authority. (72) Discussing the Texas Supreme Court's prior decisions, (73) the court in South Plains determined it was in a position to define aspects of the water district's power rather than deferring to the legislature. (74) This discrepancy between the more activist lower courts and the Texas Supreme Court has led some to conclude that although courts defer to the legislature, they are also the ones who are impeding the legislature from changing water regulation. (75)

B. Middle East Background

The Middle East, as a whole rather than a single country, offers a beneficial comparison to the Texas water regulation system. (76) This is due to the water problem in the Middle East, as in Texas, being a growing problem among neighbors. (77) Water has always been scarce in the Middle East, (78) but the growing need from increased populations and agricultural sectors is elevating this scarcity toward the level of crisis. (79) A major part of this problem arises from the fact that most countries in the Middle East share the same aquifers. (80) This problem is exacerbated by the number of countries that do not take into account their impact on a neighboring country's water resources. (81) It has been argued that the conflict over water rights serves as a major barrier to reaching a peaceful relationship among the countries in the Middle East. (82)

1. Setting the Stage for Conflict

Use, share, control, and management of water creates high levels of tension among Middle Eastern neighbors. (83) The Middle East, along with North Africa, represents five percent of the global population, but only .09% of global water resources. (84) A problem arises for the Middle East due to the Tigris, Euphrates, and Jordan River systems serving as the only main waterways for the region. (85) By 1990, there were eleven water-scarce countries in the Middle East and North Africa. (86) By 2025, it is predicted that an additional seven countries in this region will be added to the list. (87)

A number of factors have contributed to the increasing scarcity of water in the region. First, population rates in the Middle East are growing rapidly, and water is being consumed at such a rate that it is impossible for the water to replenish itself naturally. (88) This growth has also caused increased pressure for economic development and irresponsible patterns of urbanization and industrialization. (89) Second, domestic pollution has contributed to the deterioration in the quality of available water. (90) This can partly be attributed to the lack of environmentally conscious technology that has accompanied the industrialization of the Middle East. (91) Finally, the expansion of agriculture and industry has also eroded available water resources in the region. (92) These three factors combined have caused the per capita water availability in the Middle East to become one of the worst in the world. (93) Because water resources are continually shrinking, a number of Middle Eastern countries have turned to using treated wastewater for industry, agriculture, and the recharging of aquifers. (94) This, of course, gives rise to health risks due to the bacteria, viruses, and organisms present in the water. (95)

One of the factors contributing to tension over water in the Middle East is the fact that upwards of fifty percent of the population has to rely on water coming from another sovereign state. (96) This transboundary aspect, along with the scarcity of water in the Middle East, has been the spark of a number of conflicts. (97) Such conflicts include ones among Turkey, Iraq, and Syria over the Tigris and Euphrates River; among Israel, the Palestine Authority, and Jordan over the Jordan River Basin; and within Saudi Arabia itself. (98)

2. Turkey--Syria--Iraq

Since the 1970s, there has been a growing tension between Turkey, Syria, and Iraq over water. (99) This is due to the Tigris-Euphrates River system being the only real source of water in the region. (100) For six thousand years, the basins formed by both the Tigris and Euphrates Rivers have been part of a number of struggles for domination. (101) Turkey sits toward the north of both Syria and Iraq. For Syria, the main water source is the Euphrates River, (102) which flows down from Turkey and then into Iraq. (103) Iraq, on the other hand, relies both on the Euphrates River water supply as well as water from the Tigris River that flows from Turkey into Iraq, thus giving them an additional source of water. (104) Notably, Iraq is the country with the highest consumption of water from the Euphrates River among the other countries in the region. (105) In 1987, a protocol was signed, which allowed for Syrian access to the Euphrates River Basin. (106) However, "Turkish development efforts have increasingly threatened to marginalize and even eliminate Syrian access to water." (107) One such development effort is the Southeast Anotolia Project (GAP). (108) The goal of this project was the development of the area consisting of nine provinces in the Euphrates-Tigris basins known as the "GAP Region". (109) Originally, the GAP started as an energy production and irrigation project but has since been expanded to cover urban, rural, and agricultural infrastructures. (110)

It has been argued that this development has essentially given Turkey control of the only upstream water source for Syria. (111) In fact, the GAP will have a great impact on the water supply of Syria and Iraq flowing from the Euphrates River. (112)

3. Jordan--Palestine--Israel

Turning toward another water conflict in the Middle East, the Jordan, Palestine, and Israel region demonstrates the problems of overuse due to population growth and pollution. (113) Their water source originates in Lebanon and has a total average flow of around 1,200 cubic meters a year. (114) This water system is made up of both the Jordan and Yarmouk Rivers. (115) The Jordan River basin is viewed as the most controversial in the region due to it being the most developed and politically intricate. (116) Because a number of states that rely on the Jordan River for water are not able to harvest enough water to meet their needs, they must also rely on groundwater aquifers as a main source of water. (117) This reliance is due to Jordan's per capita water consumption, which, although one of the lowest among countries in the Middle East, is still more than the amount of water it can harvest from rainfall and from the Yarmuk River. (118) In 1994, the Israeli-Jordanian Treaty was signed, creating guidelines regarding the distribution, preservation, and availability of water from the Yarmouk and Jordan Rivers. (119) However, despite this agreement, conflict is continually rising. (120) In 1999, the climate of the region and harsh droughts caused Israel to be unable to adhere to the stipulations of the 1994 treaty and cut the annual allocation of water to Jordan by half. (121) This caused Jordan to be unable to sustain its current levels of water consumption and move toward a water rationing system. (122) Because of Jordan's limited access to water resources, its escalating water deficit is expected to reach 250 cubic meters by the year 2010. (123) With Jordan placing a high value on the "hydraulic imperative" and Israel's decreasing internal water sources, fears of a grab-for-resources is increasing among the two countries. (124)

Israel, on the other hand, has relied almost entirely on its National Water System, which is made up of the West Bank Mountain Aquifer, the Coastal Aquifer, and the Lake Kinneret Basin. (125) Because of this reliance, the "Mountain Aquifer underneath the West Bank is a point of contention between Israelis and Palestinians." (126) More specifically, one of the major issues between Israel and Palestine is Israel's blocking of Palestinian access to water supplies. (127) This has caused Israel to overexploit available resources in order to expand agricultural and industrial ventures. (128)

4. Saudi Arabia

Saudi Arabia serves as another demonstration of a country quickly approaching a water crisis. The difference between Saudi Arabia and the countries discussed above is that this particular country's problem arises from a lack of permanent bodies of waters and rivers. (129) Because of this, Saudi Arabia is forced to rely heavily on underground sources of water. (130)

A number of these underwater resources have been contaminated in various ways as a result of the Gulf War. (131) This contamination was caused, in part, by agricultural-related seepage and Iraq's burning of oil wells during the conflict. (132) Additionally, the Gulf War brought increased strain on water resources due to the bombing of water treatment facilities by U.S. troops. (133) Further straining water resources, multiple oil spills in the Persian Gulf damaged Saudi Arabian desalination facilities. (134)

As can be seen, water serves as a catalyst for conflict among various Middle Eastern countries. As with neighbors in Texas, neighbors in the Middle East recognize the importance of protecting water rights in order to ensure continued access to this valuable resource. And, as might be imagined, conflict soon follows this recognition.

III. PROSCRIPTIVE MEASURES FOR BOTH TEXAS AND THE MIDDLE EAST

Both Texas and the Middle East have severe problems with their water regulation systems. If poor management and conflict over water continues, then it will not be an available resource for future generations. (135) The issue of water security is of increasing importance due to the already existing water shortage, which will only become more prevalent in the coming years. (136) The question arises: What can be done in these two areas to ensure the water lasts? A brief examination of various theories of water rights provides guidance to answering this question.

One theory is that of absolute territorial sovereignty over water within the state's boundaries. (137) This theory is demonstrated in the 1895 Harmon Doctrine that addressed a dispute between the United States and Mexico regarding pollution in the Rio Grande River. (138) Under this doctrine, "an upstream State can freely deplete or utilize a river's flow within its boundaries without considering the effect of its actions on a downstream State." (139) However, this theory has become increasingly disfavored due to its inability to accord differences between areas sharing the common resource. (140)

The next theory to examine is the principle of prior appropriation. This theory does not give preference to either the upstream or downstream state, but rather to the state that used the water first. (141) However, as with the previous theory, this theory has not received wide international support. (142)

Another theory known as absolute territorial integrity rests on the idea that a downstream state should not have its flow of water interrupted regardless of priority. (143) Again, this is a theory that has received little international support. (144) This is due to the view that this theory places a burden on an upstream state without placing a similar burden on the downstream state. (145) Under a more general umbrella of theories, including sic utere, (146) "restricted territorial sovereignty," (147) and "restricted territorial integrity" (148) theories, a state may use water within its territorial boundaries so long as it does not prejudice the rights of access to water for other states. (149) This more general group of theories view whether a state has prejudiced another state by looking toward the degree of harm to the state allegedly prejudiced. (150) The final, more contemporary theory, known as the community of interests theory, "treats the entire river as one hydrological unit that should be managed as an integrated whole." (151) A problem arises with this theory in that it does not account for the lack of political cooperation between the various states. (152) With a basic knowledge of these above theories, the solutions discussed below may offer some guidance as to what both Texas and Middle Eastern countries can do to improve their water regulation systems.

A. Reasonable Use Standard

One solution for each area's water problems rests in what is known as reasonable use. (153) In 1997, the International Law Commission established the Convention on the Law of the Non-Navigational Uses of International Water Courses (the Convention). (154) Although the Convention deals with international watercourses applicable to neighboring Middle Eastern countries, it may also serve as a guide for neighbors in Texas. In determining the level of reasonable utilization, the Convention sets forth seven factors to consider. (155) These factors include:

(a) [g]eographic, hydrographic, hydrological, climatic, ecological and other factors of a natural character; (b) [t]he social and economic needs of the watercourse States concerned; (c) [t]he population dependent on the watercourse in each watercourse State; (d) [t]he effects of the use or uses of the watercourses in one watercourse State on other watercourse states; (e) [e]xisting and potential uses of the watercourse; (f) [c]onservation, protection, development, and economy of use of the water resources of the watercourse and the costs of measures taken to that effect; (g) [t]he availability of alternatives, of comparable value, to a particular planned or existing use. (156)

Considering these factors when evaluating a water issue in Texas or the Middle East will allow for a thorough analysis to take place before a neighbors use crosses the unreasonable threshold. (157) Notably, those areas in the Middle East categorized as "upstream states" (158) have declined to sign the Convention because of the belief it would be a loss for their country. (159) This idea of refusing to give part of one's benefit to another demonstrates an issue regarding the lack of cooperation among neighbors. These neighbors have constructed their livelihoods based on the assumption that fresh water would be available. (160) As seen in the Middle East, settlements were developed near permanent wells and in fertile valleys. (161) Because this resource has been so heavily relied upon, the shortage of water has had the effect of creating fragile relationships between nations, economic sectors, and individuals. (162)

A regional development plan would allow for the fortification of relationships among countries in the Middle East and between neighbors in Texas. (163) In a regional development plan, the area in issue is divided into different sectors, and each sector creates and enacts a water plan for that particular sector. (164) One step in enacting such a plan is the creation of separate control of water resources in a way that will suffocate past grievances. (165) Arguably, this could be accomplished by taking the control of water away from Texas and Middle Eastern governments and essentially turning water over to the private sector. (166) Some have argued that for such a transition to occur, it must be shown that profits can be made from the privatization of water. (167) Because of the increasing scarcity and continual dependence on water resources, it is highly unlikely that the profit aspect of water privatization would be a problem. (168) This privatization of water could also extend beyond mere property rights of water to the "water storage, treatment, and distribution stages." (169) All of this would involve negotiating property rights for the existing resources and any new resources that may come into play. (170) If the private sector were to control the distribution of water, then economic principles, such as competition, would "[breed] efficiency and innovation while protecting consumers from exploitation." (171) Because both Texas and Middle Eastern governments control water resources, there is no competition, and therefore, the protection for consumers against exploitation is replaced by regulation. (172) Even if the privatization of water does not take place, the need for regulation over the quality and amount of water use will continue to be required in the water resource arena. (173) Although this idea of privatization seems drastic, one can look to other countries that have enacted such a system to see that such a transition is possible. For example, in 1988, the British government sold its state-owned utilities to private investors who then sold one hundred percent of its stock to the public. (174) Additionally, the French government designed another model for privatization of water resources. Basically, the French municipalities have the responsibility of running water and sewage programs. (175) In doing this, the municipality has "the option of running their own operations or contracting them via public service concessions." (176) At the very least, some consideration must be given to the idea that the public may benefit from a partnership between governments, which would regulate health standards and water subsidies, and the private sector, which would regulate distribution. (177)

Regardless of whether the water regulation systems are governmental or privatized, it is important that there be more clearly defined lines for neighbors in both the Middle East and Texas. Each neighbor will need to be aware of what areas to harvest and what quantities of water they are entitled to use. More strongly defined boundaries of water resources would also allow for a water source to be controlled more efficiently and, therefore, produce a higher chance of water for future generations. (178) Additionally, defining property rights with regard to water and usage would allow for more equity among neighbors. This equity element will help to steer the view away from a "win-lose" situation toward more of a "win-win" integrated system of cooperation. (179) In order to ensure a smooth transition to a new regulation system, a minimal set of rules should be implemented so both Texas and Middle Eastern neighbors may adjust to the new system. Once people have adjusted to following a more integrated system, then additional regulations may be added as needed to correct problems that may arise. In order to accomplish such a system, there are a number of tools to consider when discussing the enactment of this type of demand management program. (180)

First, one can turn to the area made up of institutions and laws. (181) Supply and demand for water resources falls within the areas of land and water rights, which both fit within the legal arena. (182) Using the traditional institution of the law will help create and monitor water rights through