The Journal of The DuPage County Bar Association

Back Issues > Vol. 21 (2008-09)

The Attorney’s Guide to Illinois Water Law
By Richard F. Bales

Introduction Your client calls you up and tells you that he is buying some waterfront property along the DuPage River, and he wants you to handle his real estate closing. Several weeks later, you review the title insurance commitment you ordered. It contains several title exceptions, the likes of which you have never seen before. What do they mean? Are they all really necessary? It is hoped that this article will provided the answers to these and other questions concerning Illinois riparian land—that is, land adjacent to creeks, streams, rivers, lakes, and other bodies of water.

For more information concerning Illinois water law, the attorney can review chapter 7 in the author’s book, Residential and Commercial Surveys in Illinois, published by the Illinois Institute for Continuing Legal Education, or the author’s article, "On the Waterfront: An Illinois Water Law Trilogy," that appeared in the May 2008 of Real Property, the Illinois State Bar Association real estate newsletter.

Navigable Waters—In General (Illinois)

A lake or river is navigable if the body of water, in its natural state, is used or is capable of being used as a highway for commerce over which trade and travel may be conducted in the customary modes of travel on water.

Regardless of who owns the bed of the Illinois navigable body of water, the public has an easement for navigation over these waters.1

Navigable Waters—In General (United States)

The Federal government has jurisdiction over certain navigable waters. See 33 CFR, part 329, section 329.4: "Navigable waters of the United States are those waters that are subject to the ebb and flow of the tide and/or are presently used, or have been used in the past, or may be susceptible for use to transport interstate or foreign commerce."

The Federal government has the right to enact legislation and thereby regulate commerce over navigable waters.2 But what is the relationship of the State of Illinois and the federal government to bodies of water such as Lake Michigan, i.e., waters that are subject to federal jurisdiction but fall (at least in part), in the State of Illinois? The Ordinance of 1787, which established the Northwest Territory, decreed that the State of Illinois has full and complete jurisdiction over all navigable waters within its borders, but subject only to the power of the federal government to enact legislation and make regulations that relate to interstate commerce. Navigable waters within the State of Illinois are subject to the control of the state until the federal government assumes jurisdiction. Title to the bed of that portion of Lake Michigan that borders the State of Illinois is vested in the State of Illinois in trust for all the people of Illinois. Thus, the State of Illinois is entrusted to protect the rights and benefits of its citizens in and to the waters of Lake Michigan that are within the boundaries of the state. However, the federal government has the paramount right to protect the navigability of these waters.3 Therefore, regardless of who owns the bed of the navigable body of water, the public has an easement for navigation over these waters. Furthermore, the Federal government can enact legislation and thereby regulate commerce over these navigable waters.4

Navigable Rivers and Streams

Navigable rivers and streams in Illinois include the Chicago River5, the Illinois River6, the Des Plaines River7, and the Mississippi River8.

Nonnavigable Waters—In General

The public has no easement for navigation over a nonnavigable stream. Otherwise, riparian rights and servitudes along navigable and nonnavigable waters are similar. For example, the owners along both navigable and nonnavigable waters cannot obstruct or divert the water flow to the injury of other riparian owners. In addition, these owners cannot pollute the water9.

The Conveyance of Lands Abutting Creeks, Streams, or Rivers

When a tract of land is bounded by a creek, stream, or river (hereafter generically called "stream"), a conveyance of that tract will convey the land under the water to the center of the stream (assuming the grantor owns to the center), unless the deed indicates an intent to convey only to the edge of the stream. This is the case, regardless of whether or not the body of water is navigable10.

Example: A title company is conducting a closing of a commercial building in Kane County, in downtown Aurora. The building is next to the Fox River. The survey shows an encroachment of an adjoining walkway into the river. What are the issues? How can they be addressed?

The Fox River is a navigable river11. In this example, the seller owns to the center of the river, subject to an easement for navigation in favor of the public. But in this case the walkway is about twenty-five feet in the air (level with the bridge that crosses the river), and therefore it does not interfere with the public’s right to the use of the river. No riparian-related exception needs to be raised on the title policy.If a riparian owner owns the land on both sides of a stream, the landowner owns the entire bed of the stream that is appurtenant to his or her lands12.

Lakes and Ponds—In General

A lake is a large inland body of water that has little or no current, which is fed by surface waters or springs, and occupies a natural depression in the surface of the earth. A pond is similar to a lake, except that it may be natural or artificial and is much smaller in size. The primary difference between a creek, stream, or river and a lake or pond is that creeks, streams, and rivers have a natural motion or current in the water. Lakes and ponds in their natural state have no such motion or current13.

Navigable Lakes

Title to the bed of navigable lakes within the boundary of Illinois is vested in the State of Illinois in trust for all the people of the state. The owners of land adjoining a navigable lake own only to the water’s edge. These navigable lakes include (at least in part) Lake Michigan14.

Example: The title company is insuring a lot adjoining Pistakee Lake, McHenry County, Illinois. The survey discloses two piers located on the land but encroaching into the lake. Is there a problem?

Yes, there is. Pistakee Lake is a navigable lake, part of the Chain of Lakes15. The State of Illinois owns the lake bed, but its use is regulated by the Department of Natural Resources. 615 ILCS 5/24 provides that "it shall be the duty of the Department of Natural Resources to carefully examine the shore lines of Lake Michigan, all other meandered lakes in Illinois and the Chicago River each year for the purpose of seeing that encroachments are not made upon or other unauthorized uses made of these bodies of water. . . ."16 In this instance the title company showed the piers as encroachments into the water and refused to endorse over them. The title company was told that the piers had been there for fifty years, and thus the doctrine of adverse possession was applicable. This statement is incorrect. Generally speaking, adverse possession is not appropriate for an encroachment into "public waters."17

Nonnavigable Lakes

The title of a riparian owner on a nonnavigable lake extends to the center of the lake18. Multiple riparian owners of the bed of a private nonnavigable lake have the right to the reasonable use and enjoyment of the surface waters of the entire lake, (not just the portion they own), provided they do not unduly interfere with the adjoining owners’ reasonable use and enjoyment of the lake19.

Artificial Watercourses

A landowner who constructs an artificial watercourse on his or her land owns that watercourse20.

Islands

A riparian owner who owns to the center of a stream owns all the islands (if any) in that half of the stream that are adjacent to his or her land21. If an island straddles the center of a stream, the owners on each side own a part of the island22.

Boundary Changes of Riparian Land by Operation of Law (An Introduction)

Generally speaking, the boundaries of one’s property change when the owner conveys a portion of the land by deed. But land boundaries can also change by operation of law. One example is the doctrine of adverse possession23; another example, discussed in the following sections, concerns riparian land.

Definitions Relating to Boundary Changes of Riparian Land

Accretion is the gradual and imperceptible addition to riparian lands that results from water washing up sand, earth, gravel, or other materials. This process is also called alluvion.

Alluvium is the land formed as the result of accretion.

Avulsion is the sudden addition or loss of land caused by the action of water or the sudden change in the bed or course of a stream.

Erosion is the gradual and imperceptible loss of riparian land by currents or tides.

Reliction is the process by which land is created by the gradual receding of water from one side of a stream, lake, or pond.

Submergence is the disappearance of land under rising water. Submergence should not be confused with erosion.

Rules of Law Relating to Boundary Changes of Riparian Land

As a stream flows, the water on the inside of a curve moves more slowly than the water on the outside of the curve. Alluvium tends to be deposited along the banks on the inside of the curve, while the bank along the outside of the curve tends to wear away because of erosion. This action, though gradual, can cause a stream to change its course over time.

The riparian owner on the inside of the curve owns the land formed by the deposit of alluvium. The riparian owner on the outside of the curve loses title to land worn away by erosion24.

The riparian owner owns the alluvium, even if it is the result of natural or artificial causes or the acts of third parties, as long as the riparian owner does not create the conditions that cause the deposit of the alluvium25.

A prolonged drought may cause the waters of a lake or pond to gradually recede from its banks. A stream may slowly diminish in size. Any land exposed by this reliction becomes the property of the adjoining riparian owner26.

Similarly, a riparian owner loses title to land that is submerged gradually and imperceptibly27.

The doctrines of reliction and submergence apply only when the changes to riparian land are gradual and imperceptible. An avulsion, or sudden and marked change in the shore line (resulting, for example, from a violent storm), does not change the boundary line of riparian land, even though the land may now be exposed or submerged28.

Title Insurance Company Exceptions Used When Insuring Riparian Land

Title insurance companies must take into account a variety of concerns when insuring title to riparian lands. For example, they have no way of knowing if land along a water boundary exists because of accretion, reliction, or avulsion. They may not know if a waterway is navigable or not. They must consider the possibility that adjacent landowners may have the right to use the surface of the waters and that these owners have the right to the unobstructed flow of the watercourse. Consequently, title companies will usually raise one or more title exceptions when insuring riparian lands.

Consider the following eight riparian land issues and title exceptions:

1. A title company might raise the following exception if insuring land adjacent to a navigable river under federal jurisdiction, such as the Chicago River:

Rights, if any, of the United States of America, the State of Illinois, the municipality, and the public in and to that part of the land lying within the bed of the [name of river], and the rights of other owners of land bordering on the river in respect to the water of said river.

The State of Illinois has full and complete jurisdiction over all navigable waters within its borders. This jurisdiction, however, is subject to the power of the federal government to regulate commerce over these waters and to enact legislation and make regulations that benefit these waters. The public has an easement for navigation. Adjoining owners have a right to the unobstructed and unpolluted flow of the water. (It is assumed that title runs to the center of the river. Otherwise, a "title runs only to the water’s edge" exception would be appropriate. In that regard, see paragraph #5 below.)

2. A title company might raise this exception if insuring land adjacent to a navigable river not under federal jurisdiction.

Rights, if any, of the State of Illinois, the municipality, and the public in and to that part of the land lying within the bed of the [name of river], and the rights of other owners of land bordering on the river in respect to the water of said river.

The State of Illinois has jurisdiction over its navigable waters. The public has an easement for navigation. Adjoining owners have a right to the unobstructed and unpolluted flow of the water. (It is assumed that title runs to the center of the river. Otherwise, a "title runs only to the water’s edge" exception would be appropriate. In that regard, see paragraph #5 below.)

A title company might not know if a river is or is not under federal jurisdiction. It would not be unreasonable for the title company to include the rights of the United States of America in a title exception when insuring land adjacent to a river.

3. If the insured land is bounded by a non-navigable stream, the title company might raise this exception:

Rights of owners of land bordering on the [name of stream] with respect to the water and use of the surface of said body of water.

The adjoining owners have the right to the unobstructed and unpolluted flow and use of the water. (It is assumed that title runs to the center of the stream. Otherwise, a "title runs only to the water’s edge" exception would be appropriate. In that regard, see paragraph #5 below.)

4. The following exception might be raised if a non-navigable stream runs through (and not along) the insured property:

Rights of adjoining owners to the uninterrupted flow of any stream that may cross the premises.

The above exception is raised because the adjoining owners have the right to the unobstructed and unpolluted flow of the water. (As the fact situation outlined here is almost identical to the facts of paragraph three, the title exceptions in these two paragraphs are also very similar.)

5. If title to riparian land runs only to the edge of a body of water, title to possible owner-created accretions might be an issue. When insuring land adjoining a non-navigable stream, consider this generic "title runs only to the water’s edge" exception:

Rights, if any, of adjoining owners in and to so much of the land, if any, as may have been formed by means other than natural accretions or accretions created by third parties.

The riparian owner owns any additional accreted land if the accretions are the result of either natural causes or the actions of third parties. The owner does not, however, own any accretions that are formed as a result of his own actions. Instead, the adjoining land owner (i.e., the owner of the bed of the body of water and not the owner of the land "next door") might have rights to the land.

6. If the land runs to the edge of a navigable body of water, the title company might consider this exception:

Rights, if any, of the United States of America and the State of Illinois in and to so much of the land, if any, as may have been formed by means other than natural accretions or may be covered by the waters of [name of body of water].

In this above example, title runs only to the water’s edge. Again, the riparian owner owns any additional accreted land if the accretions are the result of either natural causes or the actions of third parties. The owner does not, however, own any accretions that are formed as a result of his own actions. Remember that the Federal government has jurisdiction over those navigable waters that are subject to the ebb and flow of the tide and/or are presently used, or have been used in the past, or may be susceptible for use to transport interstate or foreign commerce. Because title companies have no way of knowing what navigable waters the federal government has jurisdiction over (Lake Michigan, the Illinois River, and the Chicago River being obvious examples, though), they will probably except from coverage the rights of the United States of America when insuring land adjoining navigable waters. In addition, the State of Illinois has rights in and to these waters. If the accreted land is the result of the riparian owner’s own acts, he would have no right to the land. Instead, the federal government and the State of Illinois might have rights to these accretions.

7. If the land abuts a navigable lake not subject to federal jurisdiction, the title company might consider this exception:

Rights, if any, of the State of Illinois in and to so much of the land, if any, as may have been formed by means other than natural accretions or may be covered by the waters of [name of lake].

In this example, title runs only to the water’s edge. Again, the riparian owner owns any additional accreted land if the accretions are the result of either natural causes or the actions of third parties. The owner does not, however, own any accretions that are formed as a result of his own actions. In addition, the State of Illinois has rights in and to navigable waters. (Consider, for example, the aforementioned Pistakee Lake.) If the accreted land is the result of the riparian owner’s own acts, he would have no right to the land. Instead, the State of Illinois might have rights to these accretions.

8. On the other hand, if the land adjoins a small private lake, and title runs to the center of the lake, the title company would probably raise the following exception in light of Beacham v. Lake Zurich Property Owners Association29:

Rights of owners of land bordering on [name of lake] relative to said body of water.

In the Beacham case, the Illinois Supreme Court ruled that multiple riparian owners of the bed of a private nonnavigable lake have the right to the reasonable use and enjoyment of the surface waters of the entire lake, (not just the portion they own), provided they do not unduly interfere with the adjoining owners’ reasonable use and enjoyment of the lake. In other words, other riparian owners have the right to travel over the insured riparian owner’s portion of the lake bed.

Some Final Thoughts on Title Exceptions

It seems clear that the drafting of riparian title commitment and policy exceptions must be undertaken with care. The wording of the exception will obviously depend on the nature of the body of water that is adjacent to the land being insured.

The statements made in this article are those of the author only and do not necessarily reflect the views or underwriting standards of Chicago Title Insurance Company.

1 See Du Pont v. Miller, 310 Ill. 140, 141 N.E. 423 (1923), writ of error dismissed 269 U.S. 528, 46 S.Ct. 17, 70 L.Ed. 395 (1925). Schulte v. Warren, 218 Ill. 108, 75 N.E. 783 (1905).

2 See Bofman v. Material Service Corp., 125 Ill.App.3d 1053, 466 N.E.2d 1064, 81 Ill.Dec. 262 (1st Dist. 1984); Du Pont v. Miller, 310 Ill. 140, 141 N.E. 423 (1923), writ of error dismissed 269 U.S. 528, 46 S.Ct. 17, 70 L.Ed. 395 (1925).

3 See 36 Illinois Law and Practice, hereafter I.L.P., Waters sec. 34; Du Pont v. Miller, 310 Ill. 140, 141 N.E. 423 (1923), writ of error dismissed 269 U.S. 528, 46 S.Ct. 17, 70 L.Ed. 395 (1925); Bofman v. Material Service Corp., 125 Ill.App.3d 1053, 466 N.E.2d 1064, 81 Ill.Dec. 262 (1st Dist. 1984); Leitch v. City of Chicago, 41 F.2d 728 (1930); Bowes v. City of Chicago, 3 Ill.2d 175, 120 N.E.2d 15 (1954), certiorari denied, 348 U.S. 857, 75 S.Ct. 81, 99 L.Ed 675 (1954).

4 See Du Pont v. Miller, 310 Ill. 140, 141 N.E. 423 (1923), writ of error dismissed 269 U.S. 528, 46 S.Ct. 17, 70 L.Ed. 395 (1925); Schulte v. Warren, 218 Ill. 108, 75 N.E. 783 (1905).

5 See Leitch v. Sanitary Dist. of Chicago, 369 Ill. 469, 17 N.E.2d 34 (1938).

6 See Schulte v Warren, 218 Ill. 108, 75 N.E. 783, (1905), Bofman v. Material Service Corp., 125 Ill.App.3d 1053, 466 N.E.2d 1064, 81 Ill.Dec. 262 (1st Dist. 1984), 615 ILCS 60/1.

7 People ex rel. Deneen v. Economy Light & Power Co., 241 Ill. 290, 89 N.E. 760 (1909), writ of error dismissed sub nom. People ex rel. Dunne v. Economy Light & Power Co., 234 U.S. 497, 34 S. Ct. 973, 58 L.Ed. 1429 (1914), 615 ILCS 60/1.

8 See Senko v. La Crosse Dredging Corp., 16 Ill.App.2d 154, 147 N.E.2d 708 (1957); see also 17 Administrative Code, Section 3704.APPENDIX A, for a list of navigable rivers and streams in Illinois.

9 See I.L.P., Waters secs. 4, 5.

10 See Helmer v. Castle, 109 Ill. 664 (1884); Kinsella v. Stephenson, 265 Ill. 369, 106 N.E. 950 (1914); Carter Oil v. Delworth, 120 F.2d 589 (1941); Albany R. Bridge Co. v. People, 197 Ill. 199, 64 N.E. 350 (1902); People ex rel. Deneen v. Economy Light & Power Co., 241 Ill. 290, 89 N.E. 760 (1909), writ of error dismissed sub nom. People ex. rel. Dunne v. Economy Light & Power Co., 234 U.S. 497, 34 S. Ct. 973, 58 L.Ed. 1429 (1914); Carter Oil v. Watson, 116 F.2d 195 (1940); Allott v. Wilmington Light & Power Co., 288 Ill. 541, 123 N.E. 731 (1919); Rowland v. Shoreline Boat & Ski Club, 187 Ill.App.3d 144, 544 N.E.2d 5, 135 Ill.Dec. 648 (3rd Dist. 1989); Logan D. Fitch, Real Estate Titles in Illinois (Callaghan and Company, 1948), pp. 467-68, hereafter Fitch.

11 See 17 Administrative Code, Section 3704.Appendix A.

12 People ex rel. Deneen v. Economy Light & Power Co., 241 Ill. 290, 89 N.E. 760 (1909), writ of error dismissed sub nom. People ex rel. Dunne v. Economy Light & Power Co., 234 U.S. 497, 34 S. Ct. 973, 58 L.Ed. 1429 (1914); Washington Ice Co. v. Shortall, 101 Ill. 46 (1881); Schulte v. Warren, 218 Ill. 108, 75 N.E. 783 (1905).

13 See Trustees of Schools v. Schroll, 120 Ill. 509, 12 N.E. 243 (1887); I.L.P., Waters sec. 28; C.J.S. Waters sec. 236.

14 See Dupue Rod & Gun Club v. Marliere, 332 Ill. 322, 163 N.E. 683 (1928); Wilton v. Van Hessen, 249 Ill. 182, 94 N.E. 134 (1911); Chicago Yacht Club v. Marks, 97 Ill.App. 406 (1st Dist. 1901); Bowes v. City of Chicago, 3 Ill.2d 175, 120 N.E.2d 15 (1954), certiorari denied, 348 U.S. 857, 75 S.Ct. 81, 99 L.Ed 675 (1954); Wilkinson v. Watts, 309 Ill. 607, 141 N.E. 383 (1923); Illinois Cent. R. Co. v. State of Illinois, 146 U.S. 387, 13 S.Ct. 110, 36 L.Ed. 1018 (1892); 615 ILCS 5/24; Fitch, pp. 470-471.

15 See 17 Administrative Code, Section 3704.Appendix A.

16 See also 615 ILCS 5/26; Revell v. People, 177 Ill. 468, 52 N.E. 1052 (1898).

17 See 735 ILCS 5/13-120(6).

18 Hardin v. Jordan, 140 U.S. 371, 11 S.Ct. 808, 35 L.Ed. 428 (1891); 36 I.L.P., Waters sec. 30.

19 See Beacham v. Lake Zurich Property Owners Association, 123 Ill.2d 227, 526 N.E.2d 154, 122 Ill.Dec. 14 (1988); see also Statler v. Catalano, 293 Ill. App. 3d 483, 691 N.E. 2d 384, 229 Ill. Dec. 274 (5th Dist. 1997); Roketa v. Hoyer, 327 Ill. App. 3d 374, 763 N.E.2d 417, 261 Ill. Dec. 447 (5th Dist. 2002); Nottolini v. LaSalle National Bank, 335 Ill. App. 3d 1015, 782 N.E. 2d 980, 270 Ill. Dec. 421 (2nd Dist. 2003); Alderson v. Fatlan, No. 104772, WL 4260828, ___ Ill. 2d ___, ___ N.E.2d ___ (2008).

20 See Daum v. Cooper, 208 Ill. 391, 70 N.E. 339 (1904); Nottolini v. LaSalle National Bank, 335 Ill. App. 3d 1015, 782 N.E. 2d 980, 270 Ill. Dec. 421 (2nd Dist. 2003); Alderson v. Fatlan, No. 104772, WL 4260828, ___ Ill. 2d ___, ___ N.E.2d ___ (2008).

21 See Heckman v. Kratzer, 43 Ill.App.3d 844, 357 N.E.2d 1276, 2 Ill.Dec. 833 (1976); President, etc., of Kaskaskia v. McClure, 167 Ill. 23, 47 N.E. 72 (1897); Davis v. Haines, 349 Ill. 622, 182 N.E. 718 (1932); Bellefontaine Imp. Co. v. Niedringhaus, 181 Ill. 426, 55 N.E. 184 (1899); Albany R. Bridge Co. v. People, 197 Ill. 199, 64 N.E. 350 (1902).

22 See Nauman v. Burch, 91 Ill.App. 48 (4th Dist. 1900).

23 See 735 ILCS 5/13-101 et seq.

24 See Philip M. Rice, "A Primer on Riparian Rights," 7 Title Issues 4 (Chicago Title Insurance Company, 1998), found at www.cmetro.ctic.com; John S. Grimes, A Treatise on the Law of Surveying and Boundaries, 4th ed. (Indianapolis: Bobbs-Merrill Co., 1976), p. 775; Lovingston v. St. Clair County, 64 Ill. 56 (1872), writ of error dismissed 85 U.S. 628, 21 L.Ed. 813 (1873); St. Clair County v. Lovingston, 90 U.S. 46, 23 L.Ed. 59 (1874); McCue v. Carlton, 399 Ill. 11, 76 N.E.2d 435 (1947).

25 See St. Clair County v. Lovingston, 90 U.S. 46, 23 L.Ed. 59 (1874); Brundage v. Knox, 279 Ill. 450, 117 N.E. 123 (1917); Revell v. People, 177 Ill. 468, 52 N.E. 1052 (1898).

26 See Linn Farms, Inc. v. Edlen, 111 Ill.App.2d 294, 250 N.E.2d 681 (4th Dist. 1969); City of Peoria v. Central Nat. Bank, 224 Ill. 43, 79 N.E. 296 (1906); Hasselbring v. Lizzio, 332 Ill.App.3d 700, 773 N.E.2d 770, 266 Ill.Dec. 35 (3rd Dist. 2002); Hammond v. Shepard, 186 Ill. 235, 57 N.E. 867 (1900).

27 See Chicago Real Estate Board v. Mullenbach, 184 Ill.App. 437 (1st Dist. 1913); Schulte v. Warren, 218 Ill. 108, 75 N.E. 783 (1905).

28 See St. Clair County v. Lovingston, 90 U.S. 46, 23 L.Ed. 59 (1874); Wall v. Chicago Park Dist. 378 Ill. 81, 37 N.E.2d 752 (1941); Commissioners of Lincoln Park v. Fahrney, 250 Ill. 256, 95 N.E. 194 (1911); Chicago Real Estate Board v. Mullenbach, 184 Ill.App. 437 (1st Dist. 1913); Schulte v. Warren, 218 Ill. 108, 75 N.E. 783 (1905).

29 Beacham v. Lake Zurich Property Owners Association, 123 Ill.2d 227, 526 N.E.2d 154, 122 Ill.Dec. 14 (1988).

Richard F. Bales is employed by Chicago Title Insurance Company as Assistant Regional Counsel and Assistant Vice President in its Wheaton office. He graduated from Illinois College in Jacksonville in 1973. He received his juris doctorate degree from Northern Illinois University in 1983 and is admitted to practice law in Illinois. Dick Bales is a member of an American Land Title Association and American Congress on Surveying and Mapping liaison committee, and he helped draft the 2005 ALTA/ACSM land title survey standards.

Mr. Bales is also the author of The Great Chicago Fire and the Myth of Mrs. O’Leary’s Cow, a book wherein he claims (through the study of pre-Chicago Fire land records) to have solved the mystery of who started the Great Chicago Fire of 1871. His research was the subject of a Discovery Channel "Unsolved History" episode and a recent episode of the Weather Channel’s television show, "When Weather Changed History."

 
 
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