Footnote 1086

1086 As the Supreme Court observed, since its decision in Rands (1967), Va. Electric (1961), and Twin City Power (1956), “the elements of compensation for which the Government must pay when it condemned fast lands riparian to a navigable stream have remained largely settled.” Kaiser Aetna v. United States, 444 U.S. 164, 176-77 (1979) (citing Rands, 389 U.S. at 123; Va. Elec., 365 U.S. at 628; and Twin City Power, 350 U.S. at 226).1087 Rivers and Harbors Act of 1970, Pub. L. No. 91-611, § 111, 84 Stat. 1818, 1821 (codified at 33 U.S.C. § 595a (2012)). These Standards refer to this statute as § 595a, using the official U.S. Code citation. The same statute has been referred to as Section 111 (an abbreviation of the session laws citation) in prior editions of these Standards and a few early federal cases.