Wanger Jones Helsley Pc Attorneys 265 E. River Park Circle, Suite 310 Oliver W. Wanger Timothy Jones**

Facts (Ground Water Report, Pages 2-3) Although the County has some responsibility and authority for setting water policies in the County, as stated in Fact No. 1, (Ground Water Report at 2 [Fact No. 1]), there are several other agencies with jurisdiction over aspects of the use and delivery of water within the County. These agencies include, for example, the United States Bureau of Reclamation; the State Water Resources Control Board; the California Department of Water Resources; the Central Valley Regional Water Resources Control Board, Region 5; and irrigation and water districts, such as the District, Chowchilla Water District ("CWD"), Gravelly Ford Water District ("GFWD"), Root Creek Water District ("RCWD"), and Aliso Water District ("AWD"). Fact No. 3 is accurate; however, the District notes that groundwater extraction wells for residential, commercial, industrial, and other uses likewise only require a well drilling permit. Fact No. 5. Unlike agricultural uses, which can be fallowed, it is not feasible to 0 halt the delivery of water to residential and urban users, notwithstanding any deficiency in the supply of water, due to the need to avoid health and safety impacts on those users. • Fact No. 10 is based upon the findings in the Gunner Ranch West SB 610 Water Assessment Study. This is not the most recent version of the study, the study has been modified several times, and the study has not been approved in any form as adequate by the County. Moreover, several commenting parties, including local agencies such as the District, have provided comments to the County questioning the adequacy of this document. Thus, to the extent the Ground Water Report makes findings on typical water usage within the County, the District recommends that the Ground Water Report reference another source for the data.