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A P R I M E R O N

Access andAllocation ofW a t e rI N P E N N S Y L V A N I A

College ofAgricultural Sciences

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Pennsylvania’s surface water resourcesinclude 65,000 miles of streams andmore than 2,400 lakes, reservoirs, andponds. Approximately 47 trilliongallons of groundwater lie beneath theground in aquifers. In an average year,42 inches of precipitation fall toreplenish our supplies.

While water may appear to beplentiful, various user groups placeheavy demands on our water re-sources. The total withdrawal ofground- and surface water exceeds 4billion gallons per day. In 1990 thestate’s largest users were thermoelec-tric power generators (58.5%),industrial/mining interests (21.6%),domestic/commercial customers(19.3%), and agricultural users(0.68%) (Solley et al., 1993).

Some water uses, such as navigation,recreation, and hydroelectric powergeneration, do not involve withdraw-ing water from its source. These areknown as instream uses. Offstream orconsumptive uses remove water from asurface or underground source and donot directly return it. Water used forirrigation and livestock is included inthe consumptive use category, soalthough agriculture represents only asmall portion of total usage, in 1990 itaccounted for a significant share(9.3%) of consumptive uses.

Groundwater is essential in Pennsyl-vania, especially for farmers and ruralresidents, a majority of whom dependon private wells for their domesticwater supply. As pathogens such asGiardia and Cryptosporidium have beenfound in surface water supplies, publicwater suppliers in rural areas haveincreasingly looked to groundwater asa cleaner source. The migration ofpeople and industry from urbancenters to rural areas has threatenedgroundwater supplies.

Introduction

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Each of the state’s water users dependson access to a certain amount of waterat any time. Periodic droughts areinevitable in this part of the country,but if potential problems are recog-nized and planned for accordingly,drought’s impacts on families, busi-nesses, and the state’s economy can bereduced. Prioritizing needs, conservingwater when possible, and clearlydefining user rights before droughtstrikes will alleviate conflicts betweencompeting users in times of scarcity.

There is a trend toward increasedpopulation growth in rural Pennsylva-nia. All but 9 counties experiencedpopulation increases between 1990and 1995, and 45 counties grew fasterthan the state average for this period.Periodic droughts and extensivedevelopment, especially in the state’ssoutheast and south-central portions,have raised critical questions abouthow water is allocated, which useshave priority in times of scarcity, andwhich level of government is bestsuited to regulate water use. Water-sheds do not follow political bound-aries, so cooperation between govern-ment units can help build consistencywithin the system of water rights law.Each water user, whether industrial,commercial, domestic, or municipal,has very different needs and concerns.To resolve conflicts effectively, usersat all levels must understand theothers’ situations and views. Such anapproach is likely to produce newsolutions with the potential to benefitall parties.

This publication is intended as aneducational primer about water rightsfor citizens, farmers, other ruralbusiness owners, and elected andappointed officials. It introduces thelegal background, vernacular, andissues of the water rights debate. Thediscussion is general and does notcover all contingencies. This publica-tion does not provide legal advice toreaders with water rights conflicts andis not intended as a substitute foradvice from a qualified lawyer.

The reader will see that the sometimesvague language of the laws and legalprecedents may be open to variousinterpretations. Owing to the devel-opments highlighted above, especiallypopulation growth, it is likely thatwater rights will soon be the subject ofincreasingly concerned debate.Informed citizens are more likely toknow their rights and to contributeeffectively to the debate.

An overview of laws governingPennsylvania’s system of surface andgroundwater allocation is presented.A history of water rights is offered;important players are identified andtheir missions and authorities ex-plained. Issues likely to be discussedand debated in the near future areidentified. These issues include:

● How will new industry and residen-tial development affect the presentsystem of water allocation?

● Which level of government is bestsuited for deciding how water rightsare allocated?

● How well defined are users’ rights?● Who should have the rights to

water when demand becomesgreater than the available supply?

● When should an individual’s rightto use a water source yield to thecommunity’s rights?

● What should the community do forpeople who may be forced to giveup their water rights for thecommunity’s benefit?

● Who should benefit from the systemof water rights?

Surface water lies in a natural, definedchannel with a bed and banks andincludes streams, rivers, ponds, andlakes. Underground streams that flowin defined channels also are treated assurface water for the purpose ofallocation. Groundwater lies belowground and is part of the water tableor is percolating down to that level.Diffuse surface water, which does notmove in a defined channel and doesnot filter down to the water table,comes from various sources includingrain, melting snow, seepage fromsprings, and flood waters. Diffusesurface water is distinguished herebecause it is treated separately underPennsylvania’s water rights system.

Pennsylvania’s system of water law isbased on numerous court rulingsdating back to the 1800s. This systemof rule-making, called common law, isdecided on a case-by-case basis, asopposed to statutory law, under whicha legislature enacts specific regula-tions. In the common law system,lawyers and judges research the factsand decisions of similar cases inhigher courts to determine whatprecedent exists to help them decidethe most effective argument andlogical ruling. Some people believethat common law causes uncertaintyin the allocation of water rightsbecause new litigation could set newprecedent. Others, however, believethis uncertainty is not that great sincepreceding cases provide a fairly clearindication of how a water rightsdispute is likely to be resolved.

An important basis for the state’swater policies is the old “English rule,”or absolute ownership principle.English rule held that a propertyowner controlled not only the surfaceof the land, but also the earth,minerals, and water below his or herland down to the center of the earthand into the atmosphere above theproperty. This policy allowed alandowner to withdraw as muchgroundwater as he or she chosewithout regard for others’ needs.

Basis of Water Law inPennsylvania

English rule was eventually modifiedand its name was changed to the“American rule,” which sets differentguidelines for surface and groundwateruse. This policy places somewhatvague restrictions on surface andgroundwater use, as is discussed below.

A significant problem withPennsylvania’s system of water law isthat there are different rules govern-ing surface water, diffuse surface water,“percolating groundwater,” andgroundwater in defined undergroundstreams, which are rare in the state.The law does not recognize thehydrologic fact that surface andgroundwater are intimately con-nected, making it difficult to effec-tively manage the total water re-source.

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The 1923 Limited Water Power andWater Supply Law and the 1939Water Rights Act were designed toprovide for review and regulation ofsurface water withdrawals by publicwater companies, municipalities, andpower companies.

Surface and GroundwaterAllocation Legislation

The Water Well Drillers License Actof 1956 requires well drillers to recordand file information on well location,rock types, well design, and yield datafor each well drilled. While thecollection of such information isimportant, there is no enforcement toadminister this act.

The Dam Safety and EncroachmentsAct of 1978, an updated version ofthe 1913 Water Obstructions Act,grants Pennsylvania’s Department ofEnvironmental Protection (DEP)authority to regulate the construction,operation, and maintenance of damsand other water obstructions. This lawhas enabled DEP to establish mini-mum flow guidelines for dammedwaterways.

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Under the common law system ofwater rights, surface water is subject tothe riparian rights doctrine. Thisstates that landowners with propertyadjacent to or crossed by a naturalbody of water with defined banks havethe right to use these waters. Ripariandoctrine does not confer the right todivert or consume a certain amount ofwater, nor does it grant ownership of aspecific quantity of water to theriparian landowner. All such propertyowners have equal rights to use thiswater. According to the originalintent of this doctrine, all riparianowners have the right to see the waterunchanged in quantity and qualitywhen it reaches them.

Surface Water Rights inPennsylvania

Domestic use (including drinking,bathing, cooking, laundry, livestockwatering, and other uses necessary forlife and health) is given priority withno regard for the amount of water leftin the stream or lake after these usesare satisfied. The next priority is thepublic’s right to navigate, followed byall nondomestic water uses. Upstreamnondomestic uses, including irriga-tion, manufacturing, and powerproduction, can be slowed if there isinsufficient water to meet downstreamdomestic or navigational needs. Thispriority ranking has been assembledover the years based on the decisionsof numerous court cases. A problemwith riparian rights doctrine is thatalthough water rights are carried withproperty ownership, there is noguarantee that the right to use thewater will remain unhindered byfuture riparian users.

The requirement that the waterremain in its natural state may hamperdevelopment of riparian land. Ripar-ian doctrine in its strictest formimplies that no one can use any waterbecause everyone else has the right toundiminished flow and unchangedquality. To lessen the impediments todevelopment, Pennsylvania hasadopted the doctrine of “reasonableuse.” The policy allows some reduc-tion in a watercourse’s flow, as long asother users are not “unreasonably”harmed. The definition of reasonableuse depends on the size of the stream,the type of use, the amount ofwithdrawal, and the circumstances ofother riparian users. Unreasonableuses include selling or wasting waterand diversion to nonriparian lands.

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Nondomestic uses of surface watersuch as irrigation, municipal supply,mining, and industry are considered“extraordinary” and are allowable onlyto the extent that they “neithermaterially nor perceptibly” diminishstream flow and are “reasonable” withrespect to the rights of other users.Generally, water taken under riparianrule may not be removed from theproperty adjacent to the waterway ordiverted to another watershed, even ifsuch removal would not adverselyaffect any other user. There are twomain ways to circumvent this provi-sion: prescription and eminentdomain.

Prescriptive water rights are gainedwhen a specific water withdrawal thatadversely affects the rights of othersoccurs peaceably, continuously,notoriously, visibly, and openly for 21years without a legal complaint. Afterthis period of time, the rights cannotbe taken away, even if there arenegative consequences for otherriparian rights holders. The amount ofthe withdrawal obtained underprescriptive water rights cannot laterbe increased. The concept of prescrip-tive rights declares that lawsuitscannot be brought to recover interestsin land after it has been in the openand adverse use and possession ofanother person for 21 years.

Prescription can result in the right fora nonriparian owner to use the water,or it can allow a legitimate riparianowner to use more water than wouldotherwise be possible given the rightsof other owners. In an old example ofprescription, a farmer dammed astream and dug ditches for irrigationpurposes. His diversion caused noharm to a mill downstream. About 40years later, drought diminished thestream’s flow, and although the farmertook no more water than before, themill owner brought the farmer tocourt on the grounds that the mill wasnot receiving enough water tooperate. The farmer claimed aprescriptive right to continue usingthe water, since use had been openand continuous for more than 21years. The Pennsylvania SupremeCourt sided in the farmer’s favor,stating that although the mill ownerwas not initially harmed by thediversion, he should have complainedbefore 21 years had passed.

Eminent domain rights to water useare acquired when municipalities orother public service agencies legallyprocure water from a private source forthe public good. Acquisition requiresa permit from the state Department ofEnvironmental Protection.

Many legal decisions in the Common-wealth have emphasized the amountof the withdrawal in comparison tothe total flow of the waterway. Forexample, a court would be more likelyto deem reasonable a large withdrawalfrom the downstream reaches of ariver where flow is most often greatestthan from the smaller upstreamsections. In this way the riparian rulehas favored establishment of water-consuming industries on the down-stream sections of the state’s majorrivers.

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Pennsylvania’s groundwater law isbased on the so-called “Americanrule.” Under this rule a landownermay withdraw percolating groundwa-ter from beneath his or her propertyfor any “natural and ordinary” usewithout regard for neighboring users.Natural and ordinary uses encompassvirtually any water use, as long as useoccurs on the landowner’s property.Uses occurring off-site are “unreason-able” and “unlawful.” This rule wasestablished at the beginning of theIndustrial Revolution to promoteeconomic growth and development,the predominant social goal at thattime.

There is some confusion within thecourt decisions about liability inrelation to groundwater withdrawalsunder the American rule. Somecourts have found the offending userliable for damages when the with-drawal interferes with other users.There is also legal precedent statingthat in order for the user to be liablefor damages, the withdrawal must be“malicious” or “negligent.” A“malicious” withdrawal is done withintent to harm one’s neighbors, whilean owner who makes a “negligent”withdrawal has failed to exercise carewhen there was a duty to do so.

The American rule is not designed todeal with conflict between compet-ing users or with drought conditions.Its provisions usually mean that thosewith the deepest wells and mostpowerful pumps get the most water(State Water Plan, 1976; Weston,1990). Landowners are thereby giventhe incentive to drill ever deeperwells and use ever more powerfulpumps, as long as the water usequalifies as natural and ordinary.

Groundwater Rights withinPennsylvania’s Common

Law System

In recent years, concerns aboutgroundwater contamination anddisputes over quantity issues in someparts of the state have raised questionsabout the appropriateness of a waterpolicy rooted in economic develop-ment and growth. Some peoplebelieve that Pennsylvania’s commonlaw system of water rights allocationmay be insufficient to safeguard thisessential natural resource. Currentwater users have no ironclad guaran-tee of their future right to use thesame amount of water since commonlaw is always subject to modificationas new cases are litigated.

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Diffuse surface water does not flow ina defined channel. Pennsylvanialandowners may collect and usediffuse surface water for their ownpurposes. Many people, however,would rather be rid of the water assoon as possible. The “natural flowdoctrine” applies to drainage. Strictinterpretations of this doctrine statethat the owner of low land mustaccept all the diffuse surface waterthat flows naturally onto the propertyfrom upper lands. The upper landowner may not increase or change theamount, speed, or direction of theflow, else he or she may be liable fordamage caused to lower owners. Somepeople feel that the requirement ofpreserving the natural drainage systemunnecessarily hinders propertydevelopment.

This sentiment has led to the applica-tion of a different rule, the “commonenemy” rule, in the drainage of urbanareas. Diffuse surface waters aretreated as a common enemy. Alllandowners have equal rights toimprove their property and changethe natural flow of these waters asnecessary, even if this harms theirneighbors, as long as the landowners’actions are reasonable. However, theupland owner cannot be negligent orfail to take due care in makingimprovements, nor may he or shedeliver the water to lower lands bymeans of artificial channels or ditches.There is some confusion about whenthe common enemy rule should beapplied versus the natural flowdoctrine.

Diffuse Surface Water Rightswithin Pennsylvania’sCommon Law System

Surface water in a constructedreservoir or a dammed or divertedriver is treated separately byPennsylvania’s present system of waterlaws. Adjacent landowners do notgain riparian rights to developed waterbecause they generally do not own theland underneath the water. Themunicipality or utility that con-structed the dam or reservoir usuallyowns the land beneath the lake andtherefore has exclusive right to thewaters. There is little precedent todetermine downstream users’ rights tostored waters. Therefore, if a conflictarises in this type of situation, theoutcome of the dispute is uncertain.

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Artificial orDeveloped Waters

The Delaware and Susquehanna Riverbasins cover the eastern two-thirds ofthe state. The western third is mainlyin the Ohio River basin. In the 1960sand 1970s the federal governmentcreated two interstate river basincommissions to manage waterinterests in the more densely popu-lated Delaware and SusquehannaRiver watersheds. The Delaware RiverBasin Commission (DRBC) arose outof a long-standing interstate legaldebate over rights to the Delaware’swater. The decisions of two courtcases in 1931 and 1954 proved tooinflexible to accommodate changingindustrial needs, so the interstatecompact was established.

The DRBC and the SusquehannaRiver Basin Commission (SRBC)have the power to issue permits forsurface and groundwater withdrawalsin excess of 100,000 gallons per day,to designate Special Protection Areas,to declare drought emergencies, andto develop a comprehensive plan forwater development and use. In

drought emergencies, state allocationprograms may be preempted by thecommissions’ regulations.

The SRBC requires all surface waterusers to replace consumptive lossesthat amount to more than one milliongallons per day, or, when combinedwith other withdrawals, exceed 25percent of the 7-day, 10-year low flowof the source stream. The DRBCregulates surface water withdrawalsgreater than 100,000 gallons per day.Both commissions generally requirereview only of projects planning towithdraw more than 100,000 gallonsof groundwater per day.

The SRBC and DRBC have imple-mented water conservation policiesapplying to all regulated users. TheDRBC created the SoutheasternPennsylvania Groundwater ProtectionArea in response to recent droughtsand expanding development in thisregion. All or parts of Bucks, Chester,Lehigh, Montgomery, and Schuylkillcounties are subject to the protection

area’s regulations, which require apermit for all groundwater withdraw-als larger than 10,000 gallons per day.The Groundwater Protection Area’sregulations are designed to ensure thattotal withdrawals do not exceed thetotal recharge of the aquifer. Newusers may be required to limit with-drawals if their use interferes with thatof established users or to providereplacement water supplies wheninterference is unavoidable.

The DRBC has been involved insettling intrastate disputes in Pennsyl-vania, something it was not designedto do. The DRBC has gotten involvedbecause the state has no easy mecha-nism for resolving disputes. Somepeople feel that this jurisdictionalanomaly is a prime example of whyCommonwealth government needs todiscuss questions of water use and toconsider alternatives.

Great Lakes’ waters fall under thejurisdiction of the International JointCommission, a six-member groupresponsible for rendering decisions onapplications to use, obstruct, or divertthese boundary waters. The commis-sion is made up of representatives ofthe contiguous U.S. states andCanadian provinces.

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Laws GoverningInterstate Waters

Lake Erie

Ohio River

Potomac River

Lake Ontario

Susquehanna River

Delaware River

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The doctrine of prior appropriation iscommonly used to allocate waterrights in the arid and semiarid westernUnited States. The doctrine allowsstorage of water when it is plentifuland diversion from places withadequate supplies to places where it isneeded. Seniority of appropriation iscentral to this doctrine. In otherwords, “first in time, first in right.”The landowner whose claim to waterdates back the furthest is the last tolose water rights during droughts andconflicts.

Aspects of appropriative rightsdoctrine and riparian rights doctrineare incorporated under hybrid or dualwater rights systems, with the riparianright usually having priority. Dual orhybrid system states incorporate ameasure of reasonableness to givesome protection to junior users.

Correlative rights doctrine holds thatthe rights of all landowners in awatershed are equal and correlative. Auser may not extract more than his orher defined share when this results ininjury to other users. This doctrine issimilar to riparian doctrine, exceptthat in times of drought, correlativerights doctrine allocates water on thebasis of relative need according to apriority of uses. Use on nonoverlyinglands is highly restricted. This system’schief downfall is that a “fair” andequal division of rights may notnecessarily lead to the most economi-cally efficient use of the availablewater. This system requires moreintensive judicial involvement insettling conflicts than does theAmerican rule system, since litigationis seldom brought until the resource isalready overextended.

A regulatory system of groundwaterallocation requires new users to obtaina permit for withdrawal from the stateadministrative agency. Preexistinguses, domestic water needs, and wellsthat withdraw less than an amount setby statute are usually not regulated. Aproposed use must be beneficial, asindicated in the enabling legislation.

Most permit systems allow virtuallyany use, including off-land uses. Somesystems rank uses as a guideline intimes of water shortage. Provisionscan be made to allow new, high-priority uses in the watershed,provided that the new user compen-sates injured permit holders orreplaces their water supply. This typeof system may exist on a statewidebasis or only in critical areas wheregroundwater is scarce.

Pennsylvania’s current system of waterallocation works fairly well exceptduring shortages or where demandexceeds the available supply. Withincreasing development, watershortages will only become morefrequent. Any new legislation in thisarea should address the managementof water resources during drought, asthis generates the most severe andnumerous conflicts. The way wemanage our water resources dependson whether we view water as propertyto which we are entitled a certainamount or as a resource that must beprotected for future generations.There are many difficult and challeng-ing issues to consider. We hope thatgreater understanding ofPennsylvania’s current water alloca-tion system and its shortcomings willhelp citizens to think critically aboutthe issues and about alternative waterrights systems that may be proposed inthe future.

Alternative WaterRegulatory Systems

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American rule—states that a land-owner may withdraw percolatingwaters beneath his or her land for“natural and ordinary” use on thatland regardless of the consequencesfor neighbors. Virtually all economicenterprises are included under thecategory of “natural and ordinary” use.

Aquifer—a geologic formation thatcontains saturated permeable materialand yields significant quantities ofwater for wells or springs.

Common enemy rule—grants alllandowners equal rights to improvetheir property and change the naturalflow of diffuse surface waters asnecessary, even if this harms theirneighbors, as long as the landowners’actions are reasonable and notnegligent and the water is notdelivered by means of artificialchannels or ditches.

Common law—a system whereby thedecisions of individual lawsuits areused to define rights that may berefined and adjusted as new litigationdeems necessary.

Consumptive use—water withdrawnand removed from the immediatesupply of origin through evaporation,incorporation into products or crops,consumption by people, or othermeans.

Developed waters—a dammed ordiverted river or reservoir.

Diffuse surface water—does notmove in a defined channel and doesnot filter down to the water table. Itcomes from various sources includingrain, melting snow, seepage fromsprings, and flood waters.

Eminent domain—a legal principlethat allows municipalities and otherpublic service agencies to acquiresurface water rights for the publicgood.

Instream use—water that is used butnot withdrawn from a ground- orsurface water supply. Possible usesinclude recreation, fish propagation,hydroelectric power generation, andnavigation.

Natural and ordinary use—withregard to percolating groundwater,encompasses virtually any water use,as long as use occurs on thelandowner’s property. The transfer ofwater off land for use elsewhere is notallowed under this provision.

Natural flow doctrine—applied todrainage in rural areas, this doctrinestates that the owner of low land mustaccept all the diffuse surface waterthat flows naturally over the propertyfrom upper lands, provided that theupper landowner does not increase orchange the amount, speed, or direc-tion of the flow.

Offstream use—water withdrawn ordiverted from a ground- or surfacewater source for uses such as publicsupply, livestock, irrigation, andindustry.

Percolating groundwater—normallyflows very slowly through soil porespaces, undefined pathways betweensoil grains. This water is either in thewater table or is filtering down to thewater table.

Prescriptive water rights—obtainedif an adverse use is practiced peace-ably, continuously, notoriously,visibly, and openly for 21 years withno legal challenge.

Reasonable use—a modification ofriparian doctrine stating that somereduction in the watercourse’s flow isacceptable, as long as other users arenot “unreasonably” harmed.

Riparian—relating to the bank of astream or lake.

Riparian doctrine—grants landown-ers with property adjacent to orcrossed by a water body the right tomake reasonable use of these waters.The doctrine grants all such propertyowners equal rights to use this water.

Statutory law—as opposed tocommon law, this is written lawenacted by a legislature that allcitizens represented by the legislaturelegally must follow.

Well yield—the rate at which a wellprovides water, usually in gallons perminute.

Glossary

Solley, W.B., R.R. Pierce, and H.A.Perlman. 1993. Estimated use of waterin the United States in 1990. U.S.Geological Survey Circular 1081.Government Printing Office, Wash-ington, D.C.

State Water Plan—Pennsylvania.1976. Ground-water law in Pennsyl-vania. Water laws and institutionalarrangements. Background ReportNo. 2. Prepared by R.T. Weston andM.W. Gang. Office of ResourceManagement, Harrisburg, PA.

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References

Weston, R.T., and J.R. Burcat. 1990.Legal aspects of Pennsylvania watermanagement. In: Water Resources inPennsylvania: Availability, Quality,and Management, S.K. Majumdar,E.W. Miller, and R.R. Parizek (eds.).The Pennsylvania Academy ofScience.

In addition to this material, theauthors wish to acknowledge the useof the following publication forbackground material:

Newton, D. 1984. Legal aspects ofgroundwater management. Bulletin 5,Northeast Center for Rural Develop-ment, Cornell University, Ithaca, NY.

Abdalla, C.W. 1995. Building bridges:The water policy debate in changingcommunities. The Northeast NetworkFood, Agriculture, and Health PolicyEducation Project, Pennsylvania StateUniversity, University Park, PA.

Lincoln, J.W., and R.G. Fox. 1992.Pennsylvania General Assembly—Aspecial report of the Joint LegislativeAir and Water Pollution Control andConservation Committee on waterresources management in Pennsylva-nia. Harrisburg, PA.

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Further Reading

Prepared by Charles Abdalla, associ-ate professor of agricultural econom-ics, Joy Drohan, project assistant/writer, and John Becker, professor ofagricultural economics and law

Penn State College of Agricultural Sciencesresearch, extension, and resident educationprograms are funded in part by Pennsylvaniacounties, the Commonwealth of Pennsylvania,and the U.S. Department of Agriculture.

This publication is available from thePublications Distribution Center, ThePennsylvania State University, 112 AgriculturalAdministration Building, University Park, PA16802. For information telephone (814) 865-6713.

Issued in furtherance of Cooperative ExtensionWork, Acts of Congress May 8 and June 30,1914, in cooperation with the U.S. Departmentof Agriculture and the Pennsylvania Legisla-ture. T. R. Alter, Director of CooperativeExtension, The Pennsylvania State University.

This publication is available in alternativemedia on request.

The Pennsylvania State University iscommitted to the policy that all persons shallhave equal access to programs, facilities,admission, and employment without regard topersonal characteristics not related to ability,performance, or qualifications as determined byUniversity policy or by state or federalauthorities. The Pennsylvania State Universitydoes not discriminate against any personbecause of age, ancestry, color, disability orhandicap, national origin, race, religious creed,sex, sexual orientation, or veteran status. Directall inquiries regarding the nondiscriminationpolicy to the Affirmative Action Director, ThePennsylvania State University, 201 WillardBuilding, University Park, PA 16802-2801; Tel.(814) 865-4700/V; (814) 863-1150/TTY.

© The Pennsylvania State University 1997

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