In Winters v. United States (1908), the Supreme Court held that the right to use waters flowing through or adjacent to the Fort Belknap Indian Reservation was reserved to American Indians by the treaty establishing the reservation. Although this treaty did not mention water rights, the Court ruled that the federal government, when it created the reservation, intended to deal fairly with American Indians by reserving for them the waters without which their lands would have been useless. Later decisions, citing Winters, established that courts can find federal rights to reserve water for particular purposes if (1) the land in question lies within an enclave under exclusive federal jurisdiction, (2) the land has been formally withdrawn from federal public lands—i.e., withdrawn from the stock of federal lands available for private use under federal land use laws—and set aside or reserved, and (3) the circumstances reveal the government intended to reserve water as well as land when establishing the reservation.

Some American Indian tribes have also established water rights through the courts based on their traditional diversion and use of certain waters prior to the United States’ acquisition of sovereignty. For example, the Rio Grande pueblos already existed when the United States acquired sovereignty over New Mexico in 1848. Although they at that time became part of the United States, the pueblo lands never formally constituted a part of federal public lands; in any event, no treaty, statute, or executive order has ever designated or withdrawn the pueblos from public lands as American Indian reservations. This fact, however, has not barred application of the Winters doctrine. What constitutes an American Indian reservation is a question of practice, not of legal definition, and the pueblos have always been treated as reservations by the United States. This pragmatic approach is buttressed by Arizona v. California (1963), wherein the Supreme Court indicated that the manner in which any type of federal reservation is created does not affect the application to it of the Winters doctrine. Therefore, the reserved water rights of Pueblo Indians have priority over other citizens’ water rights as of 1848, the year in which pueblos must be considered to have become reservations.

    The term "episodic memory" was introduced by Tulving to refer to what he considered a uniquely human capacity-the ability to recollect specific past events, to travel back into the past in one's own mind-as distinct from the capacity simply to use information acquired through past experiences. Subsequently, Clayton et al. developed criteria to test for episodic memory in animals. According to these criteria, episodic memories are not of individual bits of information; they involvemultiple components of a single event "bound" together. Clayton sought to examine evidence of scrub jays' accurate memory of "what," "where," and "when" information and their binding of this information. In the wild, these birds store food for retrieval later during periods of food scarcity. Clayton's experiment required jays to remember the type, location, and freshness of stored food based on a unique learning event. Crickets were stored in one location and peanuts in another. Jays prefer crickets, but crickets degrade more quickly. Clayton's birds switched their preference from crickets to peanuts once the food had been stored for a certain length of time, showing that they retain information about the what, the where, and the when. Such experiments cannot, however, reveal whether the birds were reexperiencing the past when retrieving the information. Clayton acknowledged this by using the term "episodic-like" memory.

    The term "episodic memory" was introduced by Tulving to refer to what he considered a uniquely human capacity-the ability to recollect specific past events, to travel back into the past in one's own mind-as distinct from the capacity simply to use information acquired through past experiences. Subsequently, Clayton et al. developed criteria to test for episodic memory in animals. According to these criteria, episodic memories are not of individual bits of information; they involvemultiple components of a single event "bound" together. Clayton sought to examine evidence of scrub jays' accurate memory of "what," "where," and "when" information and their binding of this information. In the wild, these birds store food for retrieval later during periods of food scarcity. Clayton's experiment required jays to remember the type, location, and freshness of stored food based on a unique learning event. Crickets were stored in one location and peanuts in another. Jays prefer crickets, but crickets degrade more quickly. Clayton's birds switched their preference from crickets to peanuts once the food had been stored for a certain length of time, showing that they retain information about the what, the where, and the when. Such experiments cannot, however, reveal whether the birds were reexperiencing the past when retrieving the information. Clayton acknowledged this by using the term "episodic-like" memory.

Line	The argument for “monetizing”—or putting a
	monetary value on—ecosystem functions may be
	stated thus: Concern about the depletion of natural
	resources is widespread, but this concern, in the
(5)	absence of an economic argument for conservation,
	has not translated into significant conservational
	progress. Some critics blame this impasse on
	environmentalists, whom they believe fail to address
	the economic issues of environmental degradation.
(10)	Conservation can appear unprofitable when compared
	with the economic returns derived from converting
	natural assets (pristine coastlines, for example) into
	explicitly commercial ones (such as resort hotels).
	But according to David Pearce, that illusion stems
(15)	from the fact that “services” provided by ecological
	systems are not traded on the commodities market,
	and thus have no readily quantifiable value. To
	remedy this, says Pearce, one has to show that all
	ecosystems have economic value—indeed, that all
(20)	ecological services are economic services. Tourists
	visiting wildlife preserves, for example, create
	jobs and generate income for national economies;
	undisturbed forests and wetlands regulate water
	runoff and act as water-purifying systems, saving
(25)	millions of dollars worth of damage to property
	and to marine ecosystems. In Gretchen Daily’s
	view, monetization, while unpopular with many
	environmentalists, reflects the dominant role that
	economic considerations play in human behavior,
(30)	and the expression of economic value in a common
	currency helps inform environmental decision-making
	processes.