Creation of Easement occurs in 4 ways:
a.Reservation – a provision in a deed creating some new servitude, which did not exist before as an independent interest
i.Occurs when you actually grant someone else an easement and go and record it at the courthouse
ii.Easements by reservation do not end without another deed that destroys the easement
iii.Reservation = reserve an easement for the grantor
iv.Express Grant = give easement through the grant to a third party
b.Estoppel occurs when the dominant estate holder acts in reliance on the belief that an easement exists, the servient estate holder asserts that no easement exists, and then the dominant estate holder claims that the servient estate holder should be estopped from denying the existence of the easement
i.Implied easement by estoppel ends when the reason for the estoppel ends
ii.The use must come after the grant
c.Implication
i.Implied easement by an existing use
1.necessity is a factor that gives rise to the existing use, but not an element
2.the existing use must exist at the time of conveyance
3.the existing use is called a quasi easement before the grant to the benefiting party (dominant estate holder)
4.Elements for presence of existing use
a.Use must be apparent
b.Use must be of a continuous/permanent nature
ii.Implied easement by necessity
1.Endures only as long as the reason for  the estoppel
2.Requires strict necessity
a.Means that other access, no matter how difficult defeats the necessity
d.Prescription – we are not responsible for prescription