California courts have long recognized the state’s duty to protect its tidelands, navigable waterways, and submerged lands (i.e., the land below the high tideline) under the common law public trust doctrine. However, California’s public trust doctrine has operated more as a background principle, than an independent force of law for most of its history… he courts have seen a growing number of cases alleging that cities, counties, or other trustee agencies failed to consider the indirect impacts of their decisions on the public trust uses or values.