1090 See, e.g., United States v. Certain Parcels of Land in Valdez, 666 F.2d 1236 (9th Cir. 1982) (no compensation for alteration of improvements located in navigable waters); United States v. 422,978 Square Feet of Land in S.F., 445 F.2d 1180 (9th Cir. 1971) (no compensation for use of submerged land beneath navigable waters); see also United States v. Cherokee Nation, 480 U.S. 700, 701-05 (1987) (no compensable taking arises from “interference with in-stream interests result[ing] from an exercise of the Government’s power to regulate navigational uses of ‘the deep streams which penetrate our country in every direction’” (quoting Gibbons v. Ogden, 9 Wheat. 1, 195 (1824))).1091 H.R. rep. no. 91-1665, at 31 (1970) (quoted in Filiaggi, 90 F.3d at 794 n.3).