Minasian Law*

All these Districts [apparently referring to DD 200, DD 100, Butte Creek Drainage District, Reclamation District 833] have similar expenses that could be shared. DD 200 Response. DD 200 has minimal operating and administrative expense. In FY 2020 - 2021, the District expended $11,560.00 total on services and supplies, and for FY 2022 - 2023, budgeted $15,000.00 for services and supplies. The District will likely again finish the year under budget in this regard. The majority of expenditures relate to materials and labor for maintenance, which is contracted to Richvale Irrigation District, and basic administrative requirements such as insurance and professional services, including legal counsel and accounting support. DD 200 does not believe any cost saving or 'economy of scale' would be achieved through a consolidation with other Districts. With respect to operation and maintenance, the services are currently provided at cost by another California Special District. Neither the cost of materials (herbicides) nor labor will be reduced by consolidation with other Districts. With respect to Administrative costs, it is far from clear how consolidation with other Districts would reduce costs. For example, DD 200 does not own or operate significant infrastructure and has no employees. Accordingly, the District's General Commercial Liability Policy is relatively inexpensive due to the District's low risk profile. Consolidating Districts would increase the acreage, infrastructure, employees, subject to a revised insurance policy, thereby likely increasing its costs. Also, there is no guarantee that the costs of professional services provided to a consolidated District would be less than those currently provided to DD 200. The additional complexities of a bigger District with more landowners, more revenues, and expenditures may in fact require more administrative oversight. Grand Jury Report

A few drainage districts have administrative costs that outweigh the benefit to the community. DD 200 Response. It is difficult to meaningfully respond to such a broad, and unrefined statement, and it is unclear whether this observation is intended to apply to DD 200. DD 200 spent a total of $11,560.00 total on services and supplies in the 2020-2021 fiscal year, which includes the operation and maintenance of its facilities. Spread across the District's 6,636 acres, the cost amounts to $1.74 cents per acre per year, with 'administrative costs' representing only a fraction of that expense. In exchange, landowners within the District receive a reliable drainage service, which is of the utmost importance to the growing and harvesting of rice. The District's Administrative Costs include primarily, accounting and legal services. These professional service providers are necessary because of the State of California's strict accounting, regulatory, and public meeting requirements. For example, every year, the District is required to submit a Financial Activity and Compensation Report to the State Auditor's Office, and every five years, must obtain an Audit by a Certified Public Accountant. Likewise, the District must comply with requirements imposed by the County to adopt budgets, and submit check requisition requests. The District must also meet the requirements of the Brown Act, Hon. Corie Caraway, Judge of the Superior Court To: Drainage District 200's Response to Grand Jury Re: Date: August 16, 2023 Page: 3 public meeting requirements, and Public Records Act requests. These specialized and time- intensive requirements are beyond the abilities of the District's unpaid Board of Directors. Unlike other Districts, DD 200 does not have any full or part time employees, and only pays for administrative and professional services on an 'as-needed' basis. In short, the District disagrees with any implied Finding that the District's meagre administrative costs "outweigh" the benefit to the Community. Grand Jury Report

Many of these Districts have difficulty finding candidates for their governing boards. DD 200 Response. This finding does not apply to DD 200. The District has had a fully formed three member Board of Directors for its entire history. A recent vacancy on the Board of Directors caused by a Director moving out of state was promptly filled by appointment. Grand Jury Report