1085 Commodore Park, 324 U.S. at 391 (“no private riparian rights of access to the waters to do such things as ‘fishing and boating and the like’”); Birnbach, 400 F.2d at 382 (“boating, fishing and hunting”); see also Lewis Blue Point Oyster Cultivation Co. v. Briggs, 229 U.S. 82, 88 (1913) (no compensation for right to use bed for oyster cultivation); but see 28 U.S.C. § 1497 (permitting oyster growers to seek damages for destruction of oyster beds cultivated on private lands).