What is the test for determining the low-water mark on the shore of Lake Champlain?

The commentator has been able heretofore to cite for his proposition only the case of State v. Cain (1967) 126 Vt. 463, 236 A.2d 501, which apparently so reasoned only in dicta and was also not cited by any party to this action. The facts in Cain, however, bear arresting similarities to the facts here: An upland landowner along the shore of Lake Champlain--a large, natural, navigable, non-tidal lake used primarily for recreation--filled a portion of the lowlying area in front of his property, despite the state's claim to the bed of the lake. (236 A.2d at pp. 502, 504, 506.) The Cain court remanded the matter for further consideration, while in dicta it rejected the landowner's claim that the relevant low-water mark boundary was "the lowest elevation point to which the lake had receded during the years examined ...," and instead endorsed a rule derived from tidal waters in which the low-water mark is determined by averaging the low-water marks over successive years. (Pp. 503-504.)