Little Valley CSD MSR & SOI Update Public Review Draft - 2/9/26

Little Valley Community Services District Municipal Service Review & Sphere of Influence Update public review draft february 9, 2026 Prepared for Lassen LAFCO Submitted by Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft TABLE OF CONTENTS ............................................................................................................................................ 1 LIST OF FIGURES ................................................................................................................................................... 3 ACRONYMS AND DEFINITIONS ............................................................................................................................. 4 PREFACE ............................................................................................................................................................... 5 CONTEXT ..................................................................................................................................................................... 5 CREDITS ...................................................................................................................................................................... 5 1. EXECUTIVE SUMMARY ................................................................................................................................. 6 OVERVIEW ................................................................................................................................................................... 6 FINANCIAL ABILITY TO PROVIDE SERVICES .......................................................................................................................... 7 GOVERNANCE STRUCTURE OPTIONS ................................................................................................................................. 7 RECOMMENDATIONS ..................................................................................................................................................... 8 2. BACKGROUND ........................................................................................................................................... 11 LAFCO OVERVIEW ..................................................................................................................................................... 11 MUNICIPAL SERVICES REVIEW LEGISLATION ..................................................................................................................... 11 MUNICIPAL SERVICES REVIEW PROCESS ........................................................................................................................... 12 SPHERE OF INFLUENCE UPDATES .................................................................................................................................... 12 DISADVANTAGED UNINCORPORATED COMMUNITIES .......................................................................................................... 13 3. AGENCY OVERVIEW ................................................................................................................................... 15 LITTLE VALLEY COMMUNITY SERVICES DISTRICT ................................................................................................................ 15 Boundaries and Sphere of Influence .................................................................................................................. 17 4. ACCOUNTABILITY AND GOVERNANCE ....................................................................................................... 19 Brown Act and Website Requirements .............................................................................................................. 19 Ethics Training and Form 700 ............................................................................................................................ 20 Administrative Constraints ................................................................................................................................ 20 Document Retention .......................................................................................................................................... 21 Financial Reporting and Responsibility .............................................................................................................. 22 Intergovernmental Coordination ....................................................................................................................... 23 5. GROWTH AND POPULATION PROJECTIONS ............................................................................................... 24 6. DISADVANTAGED UNINCORPORATED COMMUNITIES ............................................................................... 25 7. FINANCIAL ABILITY TO PROVIDE SERVICES ................................................................................................. 26 8. WATER SERVICES ....................................................................................................................................... 30 TYPE AND EXTENT OF SERVICES ...................................................................................................................................... 30 Extra-territorial Services .................................................................................................................................... 30 Contracts for Services ........................................................................................................................................ 30 Overlapping Service Providers ........................................................................................................................... 30 Unserved Areas .................................................................................................................................................. 30 PLANS AND REGULATORY REQUIREMENTS ........................................................................................................................ 30 Regulatory Agencies and Key Regulations ........................................................................................................ 30 EXISTING CONDITIONS AND FACILITIES ............................................................................................................................. 32 Service Demand ................................................................................................................................................. 32 Table of Contents 1 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft SERVICE STANDARDS AND ADEQUACY ............................................................................................................................. 33 Drinking Water Quality ...................................................................................................................................... 33 Emergency Preparedness .................................................................................................................................. 34 Planned Improvements ...................................................................................................................................... 35 Challenges ......................................................................................................................................................... 36 9. FIRE SERVICES ............................................................................................................................................ 37 SERVICES OVERVIEW .................................................................................................................................................... 37 Staff ................................................................................................................................................................... 37 Dispatch ............................................................................................................................................................. 37 FACILITIES .................................................................................................................................................................. 37 Infrastructure Needs .......................................................................................................................................... 37 SERVICE DEMAND ....................................................................................................................................................... 38 Challenges ......................................................................................................................................................... 38 10. GOVERNANCE STRUCTURE OPTIONS ..................................................................................................... 40 11. MUNICIPAL SERVICE REVIEW DETERMINATIONS ................................................................................... 41 GROWTH AND POPULATION PROJECTIONS ....................................................................................................................... 41 THE LOCATION AND CHARACTERISTICS OF DISADVANTAGED UNINCORPORATED COMMUNITIES WITHIN OR CONTIGUOUS TO THE AGENCY’S SOI ............................................................................................................................................................ 41 PRESENT AND PLANNED CAPACITY OF PUBLIC FACILITIES AND ADEQUACY OF PUBLIC SERVICES, INCLUDING INFRASTRUCTURE NEEDS AND DEFICIENCIES. ...................................................................................................................................................... 41 Fire ..................................................................................................................................................................... 42 Water ................................................................................................................................................................ 42 FINANCIAL ABILITY OF AGENCIES TO PROVIDE SERVICES ...................................................................................................... 43 STATUS OF, AND OPPORTUNITIES FOR, SHARED FACILITIES .................................................................................................. 44 ACCOUNTABILITY FOR COMMUNITY SERVICE NEEDS, INCLUDING GOVERNMENTAL STRUCTURE AND OPERATIONAL EFFICIENCIES ...... 44 12. SPHERE OF INFLUENCE (SOI) UPDATE .................................................................................................... 46 SOI DETERMINATIONS ................................................................................................................................................. 46 Present and planned land uses in the area, including agricultural and open-space lands ................................ 46 Present and probable need for public facilities and services in the area ........................................................... 46 Present capacity of public facilities and adequacy of public services that the agency provides or is authorized to provide .......................................................................................................................................................... 46 Existence of any social or economic communities of interest in the area ......................................................... 47 Present and probable need for public facilities and services of any disadvantaged unincorporated communities within the existing sphere of influence ........................................................................................ 47 RECOMMENDED SPHERE OF INFLUENCE BOUNDARY ........................................................................................................... 47 Table of Contents 2 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft FIGURE 3-1: LITTLE VALLEY COMMUNITY SERVICES DISTRICT (CSD) OVERVIEW ........................................... 16 FIGURE 3-2: LITTLE VALLEY CSD BOUNDARIES AND SOI ............................................................................... 18 FIGURE 7-1: LITTLE VALLEY CSD NEW WATER RATES ................................................................................... 29 FIGURE 8-1: LITTLE VALLEY CSD ANNUAL WATER CONSUMPTION ............................................................... 33 List of Figures 3 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft AWWA: The American Water Works Association CEQA: California Environmental Quality Act CKH: Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000 CSA: County Service Area CSD: Community Services District CSDA: California Special Districts Association CSFA: The California State Firefighters' Association CWA: The Clean Water Act CWS: Central Water System DAC: Disadvantaged Community DDW: Division of Drinking Water DUCs: Disadvantaged Unincorporated Communities DWR: The California Department of Water Resources DWSRF: The Drinking Water State Revolving Fund EMS: Emergency Medical Services EPA: The Environmental Protection Agency FD: Fire Department FPPC: The California Fair Political Practices Commission FRA: Federal Responsibility Area FY: Fiscal Year GSA: Groundwater Sustainability Agency GSP: Groundwater Sustainability Plan GP: General Plan GPD: Gallons Per Day HR2W: The Human Right to Water LAFCo: Local Agency Formation Commission MOU: Memorandum of Understanding MHI: Median Household Income MSR: Municipal Service Review NA: Not Applicable NVFC: The National Volunteer Fire Council RFP: Request for Proposals RWQCB: Regional Water Quality Control Board SAFER: The Safe and Affordable Funding for Equity and Resilience Program SB: State Bill SDWA: The Safe Drinking Water Act SGMA: The Sustainable Groundwater Management Act SOI: Sphere of Influence SRA: State Responsibility Area SWRCB: State Water Resources Control Board TMDL: Total Maximum Daily Load USFS: United States Forest Service Acronyms and Definition 4 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft Prepared for the Lassen Local Agency Formation Commission (LAFCO), this report is a Municipal Services Review (MSR) covering the Little Valley Community Services District (CSD). An MSR is a state-required comprehensive study of services within a designated geographic area. This MSR focuses on a special district in Lassen County that provides water and fire services. Lassen LAFCO is required to prepare this MSR by the Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000 (Government Code §56000, et seq.), which took effect on January 1, 2001. The MSR examines services provided by Little Valley CSD, whose boundaries and governance are subject to LAFCO. The authors extend their appreciation to those individuals at Little Valley CSD who provided the information in this report and made time for interviews and document review to ensure the report's accuracy. Policy Consulting Associates conducted this MSR with the direction of Lassen LAFCO Executive Officer, Jennifer Stephenson. Melat Assefa was the primary author and analyst. Preface 5 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft This report is a municipal service review (MSR) and sphere of influence (SOI) covering the Little Valley Community Services District, prepared for the Lassen Local Agency Formation Commission (LAFCO). An MSR is a State-required comprehensive study of services that special districts or cities provide. The MSR requirement is codified in the Cortese-Knox- Hertzberg Local Government Reorganization Act of 2000 (Government Code §56000 et seq.). The most recent comprehensive MSR and SOI update for the District was completed on September 5, 2012. Additionally, the District was included in the 2020 Lassen LAFCO fire protection districts MSR and SOI update. The Little Valley Community Services District (CSD) was established in 1974 under the Community Services District Law (California Government Code § § 61000-61850) to provide a range of services to the Little Valley community. The Little Valley community and surrounding area have a population of 70, with 51 residences. Currently, the District provides water and fire protection services to the Little Valley community. The last comprehensive MSR for Little Valley CSD was adopted on September 10, 2012. The District was also included in the Lassen LAFCO Fire Protection Districts MSR and SOI conducted in 2020. The District operates under significant capacity constraints related to its small size, limited revenue base, and rural location. Governance challenges include a vacant board seat, a limited pool of qualified individuals, and the loss of foundational records, including bylaws and resolutions. The District also has no paid administrative staff, requiring board members to assume various operational and administrative duties, often incurring out-of-pocket expenses. Furthermore, due to financial limitations, the District lacks access to legal counsel, resulting in challenges with statutory compliance, including the Brown Act and personnel management. According to the District, efforts to obtain legal and administrative support from Lassen County have been unsuccessful, leading to ongoing intergovernmental coordination issues and difficulty verifying County-held fire-related special tax revenues. Additional constraints include limited technology and connectivity, which affect transparency, document compilation and record retention, training access, and overall regulatory compliance. Ch. 1 Executive Summary 6 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft Challenges in service delivery also exist largely due to volunteer turnover and recruitment, which impact fire service sustainability, water service billing delinquencies, and limited enforcement capabilities. Overall, the District remains operational at a level typical of smaller rural districts; however, its long-term sustainability depends on continued external technical support, improved intergovernmental coordination, and targeted actions to strengthen administrative capacity and regulatory compliance. Little Valley CSD faces persistent financial administration challenges, including the lack of an organized bookkeeping system, manual compilation of financial data, and turnover in the treasurer position. These constraints have limited the District's ability to meet statutory requirements under Government Code §26909, which mandates annual audits or approved alternatives such as biennial or five-year audits for low-revenue districts. The District's main source of revenue is water rates and special tax revenue for fire services. Historically, the District has faced financial challenges in funding water services due to low rates and payment delinquencies. To mitigate these funding shortfalls, the District has used fire service revenues in recent years to cover electricity costs related to water pumping. After following a Prop 218 process, including a Rate Study, the District adopted a new rate structure for customer classes and projected annual rate increases through 2029. The new rate took effect in August 2025 and aims to stabilize revenue, establish financial reserves, and fund the installation of a wellhead meter to comply with State mandates requiring flow meters at each active water source and at the entry point to the distribution system. Delinquency, however, remains a challenge as some property owners, including non-resident owners, have stopped paying their water bills due to dissatisfaction with the rate increase. Little Valley CSD has limited governance structure options due to its rural location and small population. The District faces capacity challenges in providing fire protection services, and the nearest neighboring fire agency is approximately 40 minutes away, limiting opportunities for direct operational support. Ch. 1 Executive Summary 7 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft However, the District may benefit from limited, non-operational collaboration with neighboring agencies, such as training support, information sharing, and coordination on grant opportunities for volunteer fire departments. Overall, it is recommended that the District continue implementing accountability and transparency measures identified in this Municipal Service Review (MSR) to support operational efficiency, financial sustainability, and statutory compliance. To address the issues identified throughout this report, below are various recommendations for Little Valley CSD to consider: • Little Valley CSD board members Jennifer Simos and Autumn Taff completed their Form 700 filing in November 2025, indicating late filings, while Board members James Haywood and Sammi Eddings last completed Form 700 statements in 2021 and 2023, respectively. It is recommended that all board members maintain up-to-date filings to ensure compliance with FPPC regulations and maintain transparency, regardless of whether their economic interests have changed. • Board members are required to complete ethics training every two years (AB 1234), which is available online through the FPPC; however, due to Little Valley CSD's limited internet connectivity, it may necessitate in-person training. It is recommended that the District contact the County Clerk to identify local sessions, ensuring all board members complete timely ethics training and understand the ethical standards for local government service. • SB 929 requires local agencies, including independent special districts, to maintain a website containing specified information, including meeting agendas in accordance with the Brown Act. Due to administrative capacity constraints and limited internet connectivity, Little Valley CSD does not currently maintain a website. To prevent potential noncompliance, it is recommended that the District adopt a formal hardship resolution, as permitted under SB 929, citing its inability to meet the statutory website requirements. • To further address website compliance issues, it is recommended that the District pursue alternative compliance options, such as third-party website hosting platforms (e.g., Streamline), which offer built-in federal and state regulatory compliance tools, scalable service plans at varying price points, and do not require on-site internet access. • The District faces administrative challenges, including a lack of paid staff, limited legal support, and inadequate technology, all of which hinder governance and regulatory Ch. 1 Executive Summary 8 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft compliance. To address these issues, it is recommended that the District consider joining the California Special Districts Association (CSDA), which provides member districts training, governance resources, and discounted services, including Streamline, an option for Little Valley CSD to meet SB 929 requirements. Currently, the CSDA is offering a six-month free trial membership from January 1 to June 30, 2026. It is recommended that the District enroll to evaluate the value of these resources before committing to a paid membership. • The District has experienced theft and vandalism, resulting in the loss of foundational records such as bylaws, minutes, and resolutions, with no backups available. Limited technology, including the absence of district-owned computers and poor internet connectivity, hinders records management, which requires reliance on long-tenured personnel to reestablish policies and procedures. To mitigate these risks, it is recommended that the District adopt a formal records management policy in compliance with Government Code §§60200–60204. This will ensure proper retention, safeguarding, and destruction of critical documents. • The District faces ongoing challenges with financial administration, including the lack of bookkeeping and treasurer turnover, which limit its ability to complete audits, creating the risk of noncompliance with Government Code §26909 reporting requirements. In coordination with the Lassen County auditor, the District should consider compliant audit alternatives, such as biennial or five-year audits. • The District faces difficulty coordinating with County offices, limiting access to special tax revenues collected by the County, audit guidance, and legal support. It is recommended that the District explore direct remittance of County-collected funds and work with Lassen LAFCO to establish formal protocols, including regular meetings with County staff to improve compliance, fund tracking, and operational efficiency. • To address water billing delinquencies, it is recommended that the District transition from monthly to annual billing through the Lassen County tax roll. Doing so aligns with the existing fire special tax collection method and reduces delinquency and administrative costs. Additionally, the District should explore direct remittance of County-collected funds to improve fund tracking, cash flow management, and timely payment of expenses. • The District reports volunteer turnover, and the appointment of a new fire chief necessitates training to maintain adequate fire and EMS services. It is recommended that the District leverage cost-effective resources, including the National Volunteer Fire Council's (NVFC) virtual training programs, grants, and equipment donation Ch. 1 Executive Summary 9 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft opportunities, as well as the California State Firefighters' Association's (CSFA) periodic free in-person recruitment and retention workshops with reimbursed travel. These efforts would strengthen volunteer capacity, reduce turnover, and improve operational effectiveness. Ch. 1 Executive Summary 10 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft LAFCO regulates boundary changes proposed by public agencies or individuals through approval, denial, conditions, and modification. It also regulates the extension of public services by cities and special districts outside their boundaries. LAFCO is empowered to initiate updates to a Sphere of Influence (SOI) and proposals involving the dissolution or consolidation of special districts, mergers, the establishment of subsidiary districts, and any reorganizations. Otherwise, LAFCO actions must originate as petitions or resolutions from affected voters, landowners, cities, or districts. The Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000 requires LAFCO to review and update SOIs every five years, or as necessary, and to review municipal services before updating SOIs. This requirement arises from the identified need for a more coordinated and efficient public service structure to support California's anticipated growth. Municipal Service Reviews provide LAFCO with a tool to study existing and future public service conditions comprehensively and to evaluate organizational options for accommodating growth, preventing urban sprawl, and ensuring that critical services are provided efficiently. Government Code §56430 requires LAFCO to conduct a review of municipal services provided in the County by region, sub-region, or other designated geographic area, or by type of service, as appropriate. LAFCO must include a written statement of determination addressing each of the following topics for each review: • Growth and population projections for the affected area. • The location and characteristics of any disadvantaged unincorporated communities (DUCs) within or contiguous to the SOI, • Present and planned capacity of public facilities and adequacy of public services, including infrastructure needs or deficiencies (including needs or deficiencies related to sewers, municipal and industrial water, and structural fire protection in any DUCs within or contiguous to the sphere of influence), • Financial ability of agencies to provide services, • Status of and opportunities for shared facilities, Ch. 2 Background 11 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft • Accountability for community service needs, including governmental structure and operational efficiencies, and • Any other matter related to effective or efficient service delivery, as required by commission policy. The MSR process does not require LAFCO to initiate changes in an organization based on service review findings, only that LAFCO identifies potential government structure options. However, LAFCO, other local agencies, and the public may subsequently use the determinations to analyze prospective changes in organization or reorganization or to establish or amend SOIs. Within its legal authorization, LAFCO may act with respect to a recommended change of organization or reorganization on its initiative (e.g., certain types of consolidations) or in response to a proposal (i.e., initiated by resolution or petition by landowners or registered voters). MSRs are exempt from the California Environmental Quality Act (CEQA) pursuant to §15306 (information collection) of the CEQA Guidelines. LAFCO's actions to adopt MSR determinations are not considered "projects" subject to CEQA. The Commission is charged with developing and updating the SOI for each city and special district within the county. SOIs must be updated every five years or as necessary. In determining the SOI, LAFCO is required to complete an MSR and adopt the seven determinations previously discussed. An SOI is a LAFCO-approved plan that designates an agency's probable future boundary and service area. Spheres are planning tools used to provide guidance for individual boundary change proposals and are intended to encourage efficient provision of organized community services and prevent duplication of service delivery. Territory cannot be annexed by LAFCO to a city or a district unless it is within that agency's sphere. The purposes of the SOI include the following: to ensure the efficient provision of services, discourage urban sprawl and premature conversion of agricultural and open space lands, and prevent overlapping jurisdictions and duplication of services. LAFCO cannot regulate land use, dictate internal operations or administration of any local agency, or set rates. LAFCO is empowered to enact policies that indirectly affect land use decisions. On a regional level, LAFCO promotes logical and orderly development of Ch. 2 Background 12 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft communities as it considers and decides individual proposals. LAFCO has a role in reconciling differences between agency plans so that the most efficient urban service arrangements are created for the benefit of current and future area residents and property owners. The Cortese-Knox-Hertzberg (CKH) Act requires LAFCO to develop and determine the SOI of each local governmental agency within the county and review and update the SOI every five years. LAFCOs are empowered to adopt, update and amend the SOI. They may do so with or without an application and any interested person may submit an application proposing an SOI amendment. LAFCO may recommend government reorganizations to particular agencies in the county, using the SOIs as the basis for those recommendations. In addition, in adopting or amending an SOI, LAFCO must make the following determinations: • Present and planned land uses in the area, including agricultural and open-space lands, • Present and probable need for public facilities and services in the area, • Present capacity of public facilities and adequacy of public services that the agency provides or is authorized to provide, • Existence of any social or economic communities of interest in the area if the Commission determines these are relevant to the agency, and • Present and probable need for water, wastewater, and structural fire protection facilities, and services of any DUCs within the existing sphere of influence. By statute, LAFCO must notify affected agencies 21 days before holding the public hearing to consider the SOI and may not update the SOI until after that hearing. The LAFCO Executive Officer must issue a report including recommendations on the SOI amendments and updates under consideration at least five days before the public hearing. LAFCO is required to evaluate disadvantaged unincorporated communities (DUCs) as part of this service review, including the location and characteristics of any such communities. The purpose of Senate Bill (SB) 244 (Wolk, 2011) is to begin to address the complex legal, financial, and political barriers that contribute to regional inequity and infrastructure deficits within DUCs. Identifying and including these communities in the long-range planning of a city or a special district is required by SB 244. Ch. 2 Background 13 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft CKH requires LAFCO to make determinations regarding DUCs when considering a change of organization, reorganization, sphere of influence expansion, and when conducting municipal service reviews. For any updates to an SOI of a local agency (city or special district) that provides public facilities or services related to sewer, municipal and industrial water, or structural fire protection, LAFCO shall consider and prepare written determinations regarding the present and planned capacity of public facilities and the adequacy of public services. LAFCO shall also consider infrastructure needs or deficiencies for any DUC within or contiguous to the SOI. CKH prohibits LAFCO from approving an annexation to a city of any territory greater than 10 acres if a DUC is contiguous to the proposed annexation, unless an application to annex the DUC has been filed with LAFCO. An application to annex a contiguous DUC shall not be required if a prior application for annexation of the same DUC has been made in the preceding five years or if the Commission finds, based upon written evidence, that a majority of the registered voters within the affected territory are opposed to annexation. Government Code §56033.5 defines a DUC as 1) all or a portion of a "disadvantaged community" as defined by §79505.5 of the Water Code, and as 2) "inhabited territory" (12 or more registered voters), as defined by §56046, or as determined by commission policy. Ch. 2 Background 14 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft The Little Valley Community Services District (CSD) was established in 1974 under the Community Services District Law (California Government Code § § 61000-61850) to provide a range of services to the Little Valley community. The unincorporated community of Little Valley was originally developed as a residential area for employees of a former lumber mill. Although the lands and homes where the mill workers lived were later sold, easements for all existing utilities were retained.1 Little Valley is located in the northwest corner of Lassen County on Little Valley Road, 19 miles southeast of Highway 299 and the community of McArthur, and 43 miles northwest of Susanville.2 The community sits at an elevation of 4,190 feet and is relatively isolated from other populated areas of the County, with the only paved road beginning in Pittville on the Lassen-Shasta County line, about 15 miles northwest of Little Valley. According to the Lassen County Assessor's Office, Little Valley consists of 83 parcels, of which 52 are improved lands and 31 are undeveloped. The surrounding area includes several federal and private landholdings, including forested parcels to the west and south owned by the USDA Forest Service (Lassen National Forest), Bureau of Land Management lands to the north and east, and approximately 700 acres owned and managed by Roseburg Resources Company adjacent to the community, mostly to the west. Additionally, Little Valley Meadow and Dixie Valley are privately owned by local ranches. Currently, the District provides water and fire protection services to the Little Valley community. The last comprehensive MSR for Little Valley CSD was adopted on September 10, 2012. The District was also included in the Lassen LAFCO Fire Protection Districts MSR and SOI conducted in 2020. General information about the District is shown in Figure 3-1. 1 Lassen LAFCO MSR, Little Valley Community Services District. Adopted September 10, 2012. p.7-8. 2 Little Valley Community Services District, Water Rate Study. Final Report. February 27, 2025. Ch. 3 Agency Overview 15 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft Figure 3-1: Little Valley Community Services District (CSD) Overview little valley csd Contact Information Contact: Dr. Sammi Eddings, Chairman Address: 653-305 Seymour Lane, Little Valley, CA 96056 Website: N/A Formation Information Independent Special Date of Formation: 1974 Agency Type: District Governing Body Governing Body: Board of Directors Members: 4; 1 Vacancy Manner of Selection: Elected Length of Term: 4 Little Valley 2nd Wednesday of Meetings Location: Community Center Meetings Date: each month 5 p.m. Population Population ~70 Registered Voters ~30 Purpose Powers CSDs are empowered to Enabling Legislation: California Latent Powers: provide but not Government Code actively providing as §61000- 61850 of 1/1/06. Municipal services provided Water, Fire and Emergency Medical Services Area Served Boundary Size: ~170 acres Location: Little Valley Community Municipal Service Reviews Little Valley CSD MSR and SOI update, September 2012 Past MSRs: Fire Protection Districts MSR and SOI update, June 2020 Ch. 3 Agency Overview 16 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft Little Valley CSD encompasses approximately 170 acres, or 0.27 square miles. The current Sphere of Influence (SOI) is coterminous with the District's boundaries. Lassen LAFCO last reaffirmed the District's SOI on September 10, 2012, and the CSD's Fire Department services SOI was reaffirmed in June 2020. The SOI for both water and fire services encompasses the same service area. Refer to the map in Figure 3-2 for the District's SOI and boundaries. Ch. 3 Agency Overview 17 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft Figure 3-2: Little Valley CSD Boundaries and SOI R 7 E LITTLE VA LLE Y R LOOMIS CABIN RD D 16 15 14 BLACK RIDGE LO RD Little Valley D R Y E L L A V E L T T LI LITTLE VA 8014 LLEY R 23 21 22 D Ch. 3 Agency Overview 18 Policy Consulting Associates, LLC N 53 T Lassen Local Agency Formation Commission Little Valley Community Services District and Sphere of Influence Boundary ·|}þ 299 Bieber PittviNlleubieber Madeline "This map does not depict a legal property L S it to tl n e e V s a L lle a y nding ·|}þ 139 Term R o avendale A S S L b d o e u sc n r d ip a t r i y o n a n a d s m de a f y in n e o d t i b n e t h u e s e S d u b a d s i v a i s le io g n a l Map Act" Spaulding ·|}þ 395 E N kj Communities Little Valley CSD O Lassen County Clear Creek L W ak e e s J F t o w o h o r n e o s s d t t onville Susan S v ta il n le d L i it s c h hfi W eld endel O C E L County Boundary L S i p tt h le e r V e a o lle f y In C flu S e D nce Boundary Janesville U G Highways MilfordHerlong N T E Roads Little Valley Community Services District Little Valley CSD Herlong Junction DoyleY N Parcels and Sphere of Influence D Sectional Grid Municipal Service Review Resolution 2012-0005 Sphere of Influence Resolution 2012-0006 (MDB&M) Hallelujah Junction 0 0.05 0.1 0.2Miles Adopted:September 5, 2012 Lassen LAFCo Map Created 1/14/2026 Little Valley CSD MSR Public Review Draft Little Valley CSD is governed by a five-member Board of Directors elected to serve four-year terms. The Board currently has one vacancy, which the District reports is primarily due to a limited pool of qualified individuals within the small community. Recruitment is further constrained by the unpaid nature of the position and the significant time, travel, and out-of- pocket costs required to carry out District duties, such as driving out of town to submit water samples and communicate with County offices. The Board meets on the second Wednesday of each month at 5 p.m. at the Little Valley Community Center, 653-305 Seymour Lane, Little Valley, CA 96056. Meeting agendas are posted at community mailboxes and at the Community Center. While agendas are posted in physical locations, the District does not currently maintain a website, which limits public access to meeting materials. In addition to posting agendas in a publicly accessible physical location, the Brown Act3 (Government Code §§ 54954.2 and 54956), as amended by California AB 2257, requires local agencies to make agendas available on their websites at least 72 hours prior to regular meetings and at least 24 hours prior to special meetings. SB 929 (the Special Districts Transparency Act), enacted in 2018, requires that, beginning January 1, 2020, every independent special district maintain a website unless the governing board adopts a resolution declaring that a hardship exists. Little Valley CSD reports that capacity constraints and limited local connectivity within the community present challenges to maintaining a website. It is unclear whether the Board has adopted a formal resolution declaring hardship or whether any such resolution was shared with the appropriate authorities. Without a formal hardship resolution, the District may be at risk of noncompliance. It is recommended that the District adopt and retain documentation of a formal hardship resolution. The District has also expressed interest in alternative compliance options that do not require on-site internet access, including third-party website hosting services with built-in federal and state regulatory compliance checklists, such as Streamline. Such a platform would manage 3 California Government Code, Section 54950, commonly known as the "Brown Act" or "Open Meeting Law," establishes requirements and restrictions for meetings of local legislative bodies. The law ensures public access to these meetings, facilitating public participation and promoting transparency in local government decision-making. Ch. 4 Accountability & Governance 19 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft statutory posting requirements for special districts and offer scalable plans ranging from basic compliance features to more comprehensive website functionality. The Political Reform Act of 1974 (California Government Code Sections 81000-81003) requires designated officials, including every elected official and public employee who makes or influences governmental decisions, to file an annual Statement of Economic Interests (Form 700) disclosing their economic interests in order to promote transparency and prevent conflicts of interest. Form 700 filings are due by April 1 each year and cover the reporting period from January 1 to December 31 of the previous year. For appointments or elections occurring later in the year, Form 700s must be filed within 30 days of assuming office. Little Valley CSD board members Jennifer Simos and Autumn Taff completed their Form 700 filing in November 2025, indicating late filings. Board members James Haywood and Sammi Eddings last completed Form 700 statements in 2021 and 2023, respectively. It is recommended that all board members maintain up-to-date filings to promote compliance and ensure transparency, regardless of whether economic interests have changed. Ethics training is also required once every two years, beginning in an odd-numbered year (AB 1234, Chapter 700, Statutes of 2005). Training is available online at the California Fair Political Practices Commission (FPPC) website. However, due to limited internet connectivity, board members may need to complete training in person. It is recommended that the District contact the County Clerk to identify local training sessions near Little Valley, ensuring that all board members complete timely ethics training and are educated on the ethical standards required for local government service. Little Valley CSD faces various administrative constraints that adversely impact operational efficiencies. According to the District, there are no paid staff for key administrative functions, including financial administration. Instead, the District relies on appointed positions such as the treasurer, a role that has experienced turnover and instability. Additionally, the District is without access to legal counsel due to financial constraints, limiting its ability to obtain guidance on Brown Act compliance, governance and employment procedures, staff discipline and terminations, and the reconstruction of significant agency Ch. 4 Accountability & Governance 20 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft documents. The District had previously sought legal guidance from County Counsel; however, it reports difficulty in receiving responses despite repeated attempts. Another significant challenge facing the District is limited internet connectivity and the lack of District-owned computers, which impedes the District's ability to maintain a website, fully comply with Brown Act requirements, properly archive significant documents, and access required trainings. To address these challenges, it is recommended that the District explore membership opportunities, such as the California Special Districts Association (CSDA). CSDA membership provides districts with access to education and training opportunities that strengthen governance capacity, improve operational practices, and enhance agency knowledge. Through CSDA membership, the District may access in-person or local ethics training workshops that accommodate connectivity constraints, helping ensure board members meet AB 1234 requirements. CSDA membership qualifies districts for discounts on essential services. Notably, members receive a 30 percent monthly discount on Streamline, a platform recommended to help the District maintain a website in compliance with SB 929 requirements. CSDA also offers members one hour of free legal advice annually, which would be particularly beneficial for Little Valley CSD, given its ongoing compliance challenges, including guidance on redrafting the District's foundational documents and staff management. Regular CSDA memberships are priced based on a district's operating revenues and range from $246 to $10,323 annually. CSDA is currently offering a trial membership running from January 1 through June 30, 2026. It is recommended that Little Valley CSD enroll in this no- cost trial to evaluate whether the professional development opportunities, resources, and support provided by CSDA would be beneficial to the District prior to committing to a paid membership. The District has experienced incidents of theft and vandalism, including the loss of keys and destruction of foundational records such as bylaws, minutes, and resolutions. No backups or copies of these records currently exist. Technology limitations, including the absence of District- owned computers and limited internet connectivity, further hinder the District's ability to maintain and safeguard records. As a result, the District is currently reestablishing policies and procedures without documented references, relying on long-serving personnel for institutional knowledge. Ch. 4 Accountability & Governance 21 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft It is recommended that the District adopt a records management guideline in compliance with Government Code §§ 60200–602044, which outlines records retention requirements for special districts, including proper procedures for records destruction. This step would ensure that formal accountability procedures are in place to prevent similar incidents of improper document destruction and further loss of critical documents. The District faces ongoing challenges with financial administration and record-keeping, making it unclear when its most recent audits were completed. Government Code §26909 (a) requires all special districts to have an annual audit conducted by a certified public accountant or the County auditor. Furthermore, Government Code §26909 requires special districts to submit annual audits to the State Controller, the County Auditor, and the LAFCO of the county in which the special district is located within 12 months following the end of the fiscal year. For agencies such as Little Valley CSD, whose financials are not processed solely by the County, the annual audit requirement may be replaced via a unanimous request of the special district's governing board and the unanimous approval of the county board of supervisors. The following alternatives may be used in place of an annual audit: a biennial audit; a five-year audit if revenues are below a threshold set by the board of supervisors; or an audit conducted at intervals recommended by the County Auditor, provided that an audit is completed at least once every five years. The District reports that the absence of organized bookkeeping and financial records, requiring manual compilation of financial information, has limited its ability to support the audit process. Turnover in the District's treasurer position and the lack of other qualified staff to assume financial duties have further hampered effective financial administration. The lack of completed audits and limited financial capacity also contribute to challenges in tracking and verifying funds held by the County. Without timely audits, the District remains vulnerable to noncompliance with state reporting requirements. 4 According to this statute, although certain categories of records are always prohibited from destruction, the legislative body of a special district may authorize the destruction or disposition of an eligible category of records if it adopts a resolution stating that doing so will not harm the district's or the public's interests and maintains a categorized list describing the destroyed records. The absence of foundational records may impact the District's ability to demonstrate compliance with governance and statutory requirements. Ch. 4 Accountability & Governance 22 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft The District reports ongoing challenges in coordinating with County offices, which affect financial administration, access to funds, and compliance with statutory requirements. Access to special tax revenues for fire services, which are collected and held by the County, requires the adoption of a formal resolution. The District has experienced persistent difficulty communicating with County staff, including the County Auditor and County Counsel, which limits its ability to verify fund status, track revenues, and implement audit requirements. While the County Auditor is responsible for reviewing and approving audit alternatives, the District reports ongoing difficulty in obtaining responses, which is affecting compliance and operational efficiency. To address these challenges, it is recommended that the District explore the option of direct remittance of special tax revenues from the County to improve fund tracking, cash flow management, and the timely payment of District expenses. Effective communication with the County Auditor is necessary to receive guidance on audit compliance, including audit timing and available alternatives. It is further recommended that the District coordinate with Lassen LAFCO to support effective intergovernmental coordination with the County. LAFCO could assist the District in establishing formal agreements or protocols with County offices, including regular meetings, routine release of fund statements, and scheduled audits to improve compliance and operational efficiency. In addition to financial coordination, such agreements can also help ensure that the District obtains timely legal guidance from County Counsel on the appropriate implementation of audit and governance recommendations. Ch. 4 Accountability & Governance 23 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft The population within the Little Valley CSD has remained stable. When the last MSR was conducted in 2012, the District's population was estimated to be 90 to 100 year-round residents, with a total of up to 130 during the summer. As of 2025, the District reports a population of 70, with 51 residences. No significant growth is anticipated in the foreseeable future, as the District mainly serves as a summer home and retirement community. Many homes and properties in the community are considered "vacation/hunting cabins" and typically remain unoccupied except during the summer and hunting seasons.5 Additionally, there are no job opportunities within Little Valley, requiring residents to commute outside the community for work. Essential services, including medical and dental care, grocery stores, gas stations, and shopping centers, are located 20-25 miles away.6 The lack of local resources further indicates that growth and development within the community will likely remain minimal. 5 Little Valley Community in Lassen County Wildfire Risk Assessment. Prepared by Lassen County Fire Safe Council, Inc., Adopted by Little Valley FIREWISE Board: December 16, 2014. p.3 6 Lassen LAFCO MSR, Little Valley Community Services District. Adopted September 10, 2012. p.8. Ch. 5 Growth 24 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft LAFCO is required to evaluate disadvantaged unincorporated communities as part of this service review, including the location and characteristics of any such communities. The intent and history of this requirement are outlined in the Background Section of this report. A disadvantaged unincorporated community is defined as any area with 12 or more registered voters, or as determined by commission policy, where the median household income is less than 80 percent of the statewide annual median.7 The California Department of Water Resources (DWR) has developed a mapping tool to assist in determining which communities meet the disadvantaged community's median household income definition. DWR is not bound by the same law as LAFCO to define communities with a minimum threshold of 12 or more registered voters. Because income information is not available for this level of analysis, disadvantaged unincorporated communities with smaller populations that meet LAFCO's definition cannot be identified at this time. The DWR Mapping Tool is an interactive map application that allows users to overlay the following three US Census geographies as separate data layers—Census Place, Census Tract, and Census Block Group. The specific dataset used in the tool is the US Census American Community Survey Five-Year Data: 2016 - 2020. Only those census geographies that meet the disadvantaged community (DAC) definition are shown on the map (i.e., only those with an annual median household income (MHI) that is less than 80 percent of the Statewide annual MHI). According to Census Bureau data, the statewide MHI for 2017-2021 is estimated at $84,097; hence, the calculated threshold of $67,277 defines whether a community is identified as disadvantaged. Per the DWR Mapping Tool, the entirety of the Little Valley CSD is considered a disadvantaged community. 7 Government Code §56033.5 defines a DUC as 1) all or a portion of a "disadvantaged community" as defined by §79505.5 of the Water Code, and as 2) "inhabited territory" (12 or more registered voters), as defined by §56046, or as determined by commission policy. Ch. 6 DUCs 25 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft Little Valley CSD's sources of revenue are water rates and special tax revenue for fire services. Prior to August 1, 2025, the District charged a flat monthly water rate of $13 per parcel. Since the system is unmetered, customers are not billed based on actual water consumption levels. The District also charged a $140 monthly fee for ranch connections and a $350 per-truck fill- up (per 4,000 gallons) for out-of-area customers. Although the District previously collected fees for multiple truck fill-ups each year, demand has declined in recent years, and the District now anticipates only one fill-up annually. Additionally, customers without an active service connection were charged a $23 availability fee.8 Historically, the District has faced financial challenges in funding water services due to low rates that have not been updated for years and a high rate of payment delinquency. To mitigate funding shortfalls, the District has used fire service revenues in recent years to cover electricity costs for pumping water. As mentioned previously, the special tax for fire services, set at $10 per month, is collected through the Lassen County tax roll. In accordance with Proposition 218, the District conducted a Water Rate Study in February 2025 to determine a sustainable rate structure for the next five years that recovers the full cost of water service, including operations, maintenance, capital improvements, and reserve accumulation. Proposition 218 establishes procedural requirements that local governments must follow before imposing or increasing property-related fees or charges, including obtaining taxpayer approval. Article XIII D, Section 6 requires local governments to: 9 • Identify the parcels upon which a fee or charge is proposed for imposition, • Calculate the amount of the fee proposed to be imposed on each parcel, • Provide written notice by mail to the record owner of each identified parcel, • Conduct a public hearing on the proposed fee not less than 45 days after the mailing, • Consider all protests against the proposed fee or charge, and 8 Little Valley Community Services District, Water Rate Study 2025. p.5. 9 League of California Cities: Proposition 26 and 218 Implementation Guide. p.82. Ch. 7 Finance 26 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft • If written protests against the fee are presented by a majority of owners of the identified parcels, the fee cannot be imposed. Under Prop 218, agencies must send written notice of the proposed increase to property owners 45 days in advance of a scheduled public hearing. The notice must include: (a) the amount of the proposed fee or charge; (b) the basis upon which it was calculated; (c) the reason for the fee or charge; and (d) the date, time, and location of the public hearing.10 Pursuant to Government Code § 53755(b), a protest may be submitted by either an owner of a parcel or a tenant directly liable for the proposed fee or charge. However, only one protest per parcel is counted when determining whether a majority protest exists for a proposed new or increased fee or charge. Water, sewer, and refuse collection fees are exempt from the voter approval requirements of Article XIII D 6 (c).11 Charges for water service are exempt from additional voting requirements of Prop 218, given that the charges do not exceed the cost of providing service and are adopted in compliance with the procedural requirements. The 2025 Rate Study indicates that the existing rates were projected to generate approximately $10,100 in annual revenue, while operating costs were estimated at $23,400. Electricity costs, which account for 62 percent of the District's water-related expenses, are projected to increase by eight percent annually due to inflation, while all other expenses are anticipated to increase four percent per year. Due to the continued revenue shortfall, the District has been unable to maintain adequate cash reserves, with a reported zero cash balance as of January 1, 2025. The American Water Works Association (AWWA) recommends that municipal utilities maintain reserves to cover unexpected expenses and emergency repairs and to provide financial stability during unforeseen events. The domestic water rate was increased to a fixed monthly charge of $53 per parcel. Ranch service rates were increased to $159 per month. A new non-residential rate of $30 per month was also implemented for parcels with no dwelling units and not subject to irrigation rates. For irrigation (specifically for cannabis plants sold commercially), a monthly rate of $0.91 per plant is proposed for the growing season from June to October. Additionally, swimming pool service is set to be billed at $100 per fill for up to 20,000 gallons, with a limit of one fill per summer. 10 California Special District Association (CSDA) Proposition 218 Guide for Special Districts, 2013, p.35. 11 League of California Cities: Proposition 26 and 218 Implementation Guide. p.97. Ch. 7 Finance 27 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft Figure 7-1 illustrates the new rates for the various customer classes, including the projected subsequent annual rate increases through 2029. At the end of the five-year rate adjustment period, the District's water utility is projected to accumulate approximately $22,300 in reserves. The revenue from the rate increases will also fund the installation of a wellhead meter to comply with State mandates requiring flow meters at each active water source and at the entry point to the distribution system. The wellhead meter project is planned for 2027 and is estimated to cost $2,000. Once completed, water production from each source will be metered, and total system production will be recorded at least monthly. Since the new rates took effect in August 2025, the District reports that delinquency remains a challenge as some property owners, including non-resident owners, have stopped paying their water bills due to dissatisfaction with the rate increase.12 To recover large sums of overdue balances, the District has leveraged the County's Teeter Program, which allows the County to collect delinquent payments on the District's behalf. This assistance from the County has significantly improved cash flow and reduced outstanding receivables. However, to address ongoing delinquency challenges, the Rate Study recommends that the District, similar to its approach for fire assessments, consider transitioning from monthly water billing to annual billing through the Lassen County tax roll. This method would improve payment reliability and reduce administrative costs by streamlining water utility billing through the property tax collection process.13 12 Interview with Little Valley CSD. November 11, 2025. 13 Little Valley Community Services District, Water Rate Study 2025. p.9. Ch. 7 Finance 28 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft Figure 7-1: Little Valley CSD New Water Rates proposed water rates 2025 2026 2027 2028 2029 customer class current aug 1 july 1 july 1 july 1 july 1 Domestic Service Per Parcel (monthly) $13.00 $53.00 $55.00 $57.00 $60.00 $62.00 Ranch (monthly) $140.00 $159.00 $165.00 $172.00 $179.00 $186.00 Non-residential $13.00 $30.00 $31.00 $32.00 $34.00 $35.00 Availability Fee $23.00 $23.00 $23.00 $23.00 $23.00 $23.00 Outside Water (Truck Fill-Up per 4,000 gallons) $350.00 $350.00 $350.00 $350.00 $350.00 $350.00 Swimming Pool Fill Up (20,000 gallons) - $100.00 $104.00 $108.00 $112.00 $116.00 Irrigation Per Plant (monthly) - $0.91 $0.94 $0.98 $1.02 $1.06 Ch. 7 Finance 29 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft Little Valley CSD has a central water system (CWS) that provides water services to the unincorporated community of Little Valley, comprising approximately 60 parcels.14 Little Valley CSD provides truck fill-up services for out-of-area customers. The District relies on an on-call water operator for system failures or emergencies and required reporting, while community volunteers perform routine system maintenance. There are no overlapping service providers within Little Valley CSD. There are no unserved areas within the Little Valley CSD. Federal, state, and local agencies play regulatory roles in California water. Key regulators and regulatory provisions are discussed in more detail below. The Environmental Protection Agency (EPA) sets national drinking water quality standards and oversees implementation of the Safe Drinking Water Act (SDWA). The SDWA establishes regulations to protect public drinking water supplies, including standards for contaminants, treatment techniques, and monitoring requirements. Another key federal law that provides the legal basis and authority for water quality standards is the Clean Water Act (CWA). Enacted in 1972, the CWA regulates pollutant discharges into 14 Community Water Systems (CWS) are city, county, regulated utilities, regional water systems and even small water companies and districts where people live. CWS is a type of public water system that provides water for human consumption to 15 or more connections or regularly serves 25 or more people daily for at least 60 days out of the year. Ch. 8 Water Services 30 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft surface waters through permits, addresses nonpoint source pollution, protects wetlands, and mandates water quality monitoring and reporting. Section 303(d) of the CWA requires the identification of water bodies that do not meet, or are not expected to meet, water quality standards (i.e., impaired water bodies). For each impaired water body, the EPA and state or regional boards must establish a Total Maximum Daily Load (TMDL)15, which is the maximum amount of a pollutant that a water body can receive while still meeting water quality standards. The TMDLs require local agencies to monitor pollutant levels and develop remedial actions that will prevent contaminants from exceeding maximum allowable levels. In California, the implementation of the SDWA is primarily overseen by the State Water Resources Control Board (SWRCB) and its Division of Drinking Water (DDW). The SWRCB is responsible for protecting water quality and ensuring compliance with state and federal drinking water standards. The SWRCB also oversees the Safe Drinking Water Plan for California, which outlines statewide strategies to ensure the delivery of safe drinking water. The requirements for this plan are outlined in California Health & Safety Code Section 116355, which identifies the topics to be addressed and mandates periodic updates. The most recent plan update was adopted in 2025 to incorporate topics from previous plans, as well as new topics that had been signed into law. Notably, Assembly Bill 2501 (Chu), enacted in 2018 (Statutes of 2018, Chapter 871), amended Section 116355 to include a review of the use of administrators for disadvantaged communities' public water systems and an evaluation of the success of consolidating drinking water systems. California's principal water quality law, the Porter-Cologne Act (1969), establishes the framework for regulating water quality in the state. This Act empowers SWRCB and the nine Regional Water Quality Control Boards (RWQCBs) to adopt water quality control plans, set water quality objectives, and issue permits for waste discharge. Each RWQCB has jurisdiction over a major watershed region. Located in Lassen County, the Little Valley CSD falls under the jurisdiction of the Lahontan RWQCB. This regional board is responsible for protecting and managing water quality, developing and enforcing water quality objectives, and implementing plans to safeguard surface and groundwater resources within its jurisdiction. 15 TMDLs define the maximum amount of a pollutant that a water body can receive while still meeting water quality standards. Ch. 8 Water Services 31 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft The Lahontan RWQCB also plays a key role in implementing TMDLs and directing agencies to implement remediation strategies for impaired water bodies in its jurisdiction. According to the most recent Integrated Report, approximately 16 water bodies in Lassen County, some of which extend into neighboring counties, are listed as impaired.16 Regulatory oversight of these impaired water bodies falls under the jurisdiction of the applicable RWQCB based on the watershed in which each water body is located. Groundwater management within California is governed by the Sustainable Groundwater Management Act (SGMA), enacted in 2014. SGMA requires local Groundwater Sustainability Agencies (GSAs) to develop and implement Groundwater Sustainability Plans (GSPs) that address overdraft and ensure the long-term sustainability of groundwater basins designated by the Department of Water Resources (DWR) as medium or high priority. Little Valley CSD relies on groundwater sourced from the 4,867-acre Dixie Valley Groundwater Basin, which is classified by DWR as a very low-priority basin. As such, it is exempt from the requirement to develop a GSP or to establish a GSA, which is a local agency responsible for managing groundwater resources and overseeing groundwater management activities in compliance with California's SGMA. The Little Valley CSD water infrastructure consists of a groundwater well, a 126,000-gallon storage tank, and a distribution system. Additionally, five additional private wells are located within Little Valley. The District leases the site for the storage tank from the Sierra Pacific Lumber Company for $10 per year.17 Little Valley CSD provides water services to 43 connections, consisting of domestic and ranch customers. Domestic service includes 41 residential connections that support indoor and outdoor water use, including up to 10 cannabis plants for personal use and/or irrigation of up to a half- acre for gardens or lawns. These parcels are estimated to use approximately 350 gallons per day (gpd). 16 State Water Resources Control Board (SWRCB). California 2024 Integrated Report (303(d) List/305(b) Report.https://www.waterboards.ca.gov/water_issues/programs/water_quality_assessment/2020_2022_integrated_report.html. 17 Lassen LAFCO MSR, Little Valley Community Services District. Adopted September 10, 2012. p.15. Ch. 8 Water Services 32 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft The District also serves two ranch connections, each comprising three to five single-family homes or mobile homes that are not fully occupied year-round. These ranch connections are estimated to have a daily flow of 1,050 gpd each. Additionally, the District provides irrigation water to approximately 300 cannabis plants within the community that are sold commercially. During the growing season, each plant is estimated to receive an average of 6 gpd. The District also provides swimming pool fill-ups, typically once per summer, to three customers. According to the Rate Study, since customers are unmetered, annual consumption is projected using industry standards and estimates provided by District staff. Based on these assumptions, the District's total annual water consumption is 6,338,000 gallons, as described in Figure 8-2.18 Figure 8-1: Little Valley CSD Annual Water Consumption gallons annual percent of number of per day flow total connection type units (gpd) (gallons) consumption Domestic service per parcel 41 350 5,237,750 82.6% Ranch 2 1,050 766,500 12.1% Swimming pool fill up (20,000 gallons) 3 - 60,000 0.9% Irrigation per plant 300 6 273,750 4.3% Total 6,338,000 100% Generally, several threats to drinking water exist, including chemicals that are improperly disposed of, animal and human waste, pesticides, waste injected deep underground, and naturally occurring substances that can lead to contamination. Similarly, drinking water that is not properly treated or disinfected, or that travels through an improperly maintained distribution system, may pose a health risk. The District prepares an Annual Drinking Water Quality Consumer Confidence Report to inform customers about the quality of the drinking water delivered, including the presence of any contaminants detected during year-round testing. 18 Little Valley Community Services District, Water Rate Study 2025. p.9. Ch. 8 Water Services 33 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft The most recent 2024 Consumer Confidence Report includes results from water quality monitoring conducted by the District between January 1 and December 31, 2024. The Report indicates that several contaminants, including nitrate, sodium, hardness, gross alpha, chloride, specific conductance, sulfate, and total dissolved solids, were identified in the water supply, all within their respective Maximum Contaminant Levels (MCLs)19. All identified contaminants are within safe limits, and the water quality complies with health standards. The 2024 Report also includes data from earlier years for certain contaminants, such as lead and copper, for which the SWRCB allows less frequent monitoring as their concentrations do not change frequently. The most recent sampling for lead and copper was conducted in 2021. Under regulatory requirements, the District was obligated to conduct sampling between June and September 2024; however, it failed to do so, resulting in a violation of the required three- year monitoring schedule. This was not considered an emergency, and corrective action is scheduled to be taken, with sampling planned for June through September 2025.20 Under SB 552, passed and signed in 2021, state and local governments share responsibility for preparedness and response in the event of a water shortage. For small water suppliers, such as Little Valley CSD, with fewer than 3,000 connections and serving fewer than 3,000 acre-feet, SB 552 establishes requirements including the development of an abridged water shortage contingency plan, submission of an annual report documenting water supply conditions and monthly water use, and implementation of infrastructure upgrades to meet drought-resilient standards. These requirements aim to strengthen California's ability to manage future droughts and help prevent catastrophic impacts on drinking water supplies, particularly for communities vulnerable to climate change. To address the regulatory compliance requirements of SB 552, the District engaged the Provost & Pritchard Consulting Group to evaluate the water system and prepare grant applications for several identified projects. These projects include metering all service connections, installing a security fence at the well and storage tank, installing telemetry at the well and storage tank to remotely monitor well status and storage tank water levels, and conducting interior and exterior inspection of the storage tank.21 19 The highest level of a contaminant that is allowed in drinking water. 20 2024 Consumer Confidence Report, Little Valley Community Services District. April 1, 2025. 21 Little Valley Community Services District, Water Rate Study 2025. p.7. Ch. 8 Water Services 34 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft SWRCB conducts an annual Drinking Water Needs Assessment to evaluate the condition of public water systems and domestic wells statewide. This assessment identifies communities with water systems that are failing or at risk of failing to provide safe and reliable drinking water. The assessment also serves as the foundation for prioritizing state funding and regulatory actions under the Safe and Affordable Funding for Equity and Resilience (SAFER) drinking water program. In accordance with California's Human Right to Water (HR2W) law, SAFER coordinates multiple State Water Board funding programs to ensure that all Californians have access to safe, clean, affordable, and accessible drinking water while supporting sustainable, long-term solutions for water systems. One of the primary funding mechanisms for implementing SAFER priorities is the Drinking Water State Revolving Fund (DWSRF), which provides financial assistance for planning, design, and construction projects to address drinking water system deficiencies identified through the Needs Assessment. In 2023, Little Valley CSD initiated the Drinking Water Improvement Project to address the District's aging water infrastructure, including the water storage tank constructed in 1975, which requires significant repair or replacement to maintain adequate and reliable water service for the community.22 Since project initiation, the District has pursued grant funding through programs such as the DWSRF to support planning activities, including technical studies, data collection, environmental documentation, and preparation of planning documents in anticipation of future construction. The District's initial DWSRF application was placed on hold due to the State Water Board's prioritization of funding for failing water systems. According to the SWRCB's Intended Use Plan approved in August 2025, funding is now available for at-risk water systems, a category that Little Valley CSD's water system falls under.23 The District is currently working with Pace Engineering on the planning project scope and budget in preparation for executing a funding agreement with SCWRB, estimated at $522,000.24 22 The California Environmental Quality Act (CEQA). Notice of Exemption. Little Valley CSD Drinking Water Improvement Project. 6/21/2023. 23 State of California, Drinking Water State Revolving Fund Program and Complementary Programs. Intended Use Plan. State Fiscal Year 2025-26. Approved By: State Water Resources Control Board. Approval Date: August 19, 2025 | Resolution No. 2025-0024. p.86. 24 Little Valley CSD, Request For Information. December 2025. Ch. 8 Water Services 35 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft As discussed, the District continues to face payment delinquency challenges. Historically, water service has shut off water for non-payment; however, some residents have illegally reconnected without authorization. The District is also unable to secure certain connections because they serve multiple homes, and some residents have filled large tanks for those whose service was shut off, undermining accountability and reducing the incentive to pay outstanding fees for reconnection. Enforcement options have been limited due to the Sheriff Department's refusal to intervene, citing safety concerns, which has left the District without law enforcement support. As previously mentioned, it is recommended that Little Valley CSD transition to annual water billing through the Lassen County tax roll to enhance payment reliability and reduce administrative costs by streamlining municipal service billing through the property tax collection process.25 25 Interview with Little Valley CSD. November 11, 2025. Ch. 8 Water Services 36 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft The Little Valley Fire Department (FD) provides fire suppression and emergency medical services (EMS) within the Little Valley Community. Some areas surrounding the community are US Forest Service (USFS) lands managed by the Hat Creek Ranger District of the Lassen National Forest and are designated as Federal Responsibility Areas (FRA). The remaining surrounding areas are State Responsibility Areas (SRA), where CAL FIRE is responsible for wildland fire protection.26 The Little Valley FD is a volunteer-based department staffed with three on-call firefighters and a fire chief. The Susanville Interagency Fire Center provides dispatch services to the District.27 Since the Little Valley FD is volunteer-based, the station is not staffed with on-site personnel. Alternatively, service calls are transferred to the residences of the District's board members. The Little Valley FD operates one small station located within the CSD office. The District owns two fire-related pieces of equipment: a 1984 1,700-gallon water tender and a 1991 400- gallon fire engine.28 Fire hydrants are strategically placed throughout the community, including one next to the fire hall for quick access during emergencies. The District reports that the FD hall is operating at or near its design capacity. Non-routine repairs, such as roof repairs, are estimated to cost between $2,000 and $7,000 and are 26 Community Risk Assessment for the Little Valley Community in Lassen County. Adopted by Little Valley FIREWISE® Board: December 16, 2014. p.3. 27 Lassen LAFCO. Fire Protection Districts, MSR and SOI. June 2020. 28 Little Valley CSD, Request For Information. December 2025. Ch. 9 Fire Services 37 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft required to ensure continued reliable operation. Funding is currently unavailable, and the District anticipates applying for grants to fund the necessary capital improvements. Demand for fire and EMS in the Little Valley community has remained stable due to its low population and remote location. The nearest neighboring district or fire department, the Fall River Valley Fire District, is approximately 40 minutes away, which limits opportunities for shared facilities or resources. Mutual aid requests have also been minimal in recent years, with only one call received in 2023. Annual service calls have declined over the past three years, from a high of 20 calls in 2022 to 12 in 2023 and nine in 2024. In 2024, EMS calls accounted for more than 66 percent of total calls (six calls), followed by two calls for fire or hazardous materials and one call for a motor vehicle accident.29 The District reports that recent volunteer turnover, including the appointment of a new fire chief, necessitates training for new volunteers to ensure the continued delivery of adequate fire and EMS services to the community.30 The District could explore training opportunities through organizations such as the National Volunteer Fire Council (NVFC), a national non-profit that offers a wide range of programs and partnerships to train and equip volunteer responders. Through its Virtual Classroom program, NVFC provides ongoing virtual trainings and webinars on critical fire and EMS topics. Access to these opportunities requires NVFC membership, which costs $24 per member annually. In addition, NVFC offers periodic giveaways, grants, and scholarship opportunities. Current opportunities include a pre-owned laptop donation program for NVFC member departments, through which eligible departments may enter for the chance to receive up to five laptops each. The entry period for this program is scheduled to open from January 5 through January 30th.31 Furthermore, NVFC, in partnership with State Farm, administers the Good Neighbor Firefighter Safety Program, which awarded $10,000 to 150 volunteer fire departments across 44 states in both 2024 and 2025. The grant aims to support small-town and rural fire 29 Little Valley CSD, Request For Information. December 2025. 30 Little Valley CSD, Request For Information. December 2025. 31 National Volunteer Fire Council (NVFC), Special Opportunities for Volunteer Fire, EMS, and Rescue Personnel. Ch. 9 Fire Services 38 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft departments, similar to Little Valley CSD, that operate on limited budgets and face rising equipment and gear costs. Grant funds may be used to purchase a variety of department necessities, including personal protective equipment, EMS and rescue tools, and communication devices. It is recommended that the District monitor the NVFC website for future eligibility requirements and application timelines should the Good Neighbor Firefighter Safety Program continue in 2026 and beyond. For in-person training opportunities, the District may also explore programs offered to volunteer fire departments by the California State Firefighters' Association (CSFA), including its Recruitment and Retention Workshops held throughout the state. These workshops cover a range of management and leadership skills that may be particularly beneficial for the District's new Fire Chief. Training topics include volunteer recruitment and application review, interviewing techniques, evaluating candidates, setting expectations, and motivating new volunteer firefighters. The training is offered at no cost, and participants' travel, lodging, and per diem expenses are reimbursed upon completion of the workshop.32 These efforts to train and retain existing volunteers could help the District address its ongoing challenges in volunteer recruitment and retention, particularly due to the high cost of liability insurance, by reducing turnover and improving operational effectiveness. 32 The California State Firefighters' Association (CSFA). https://californiavolunteerfire.org. Ch. 9 Fire Services 39 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft There are limited governance structure options available to the Little Valley CSD due to its rural location. As discussed in previous sections, the District faces capacity challenges in fire service delivery. Given the District's remote location, the nearest fire agency, the Fall River Valley Fire District, is located approximately 40 minutes away. The Fall River Valley Fire District is a larger agency serving portions of Lassen and Shasta Counties, with stations located in the Fall River, McArthur, Day, and Pittville areas. While geographic distance limits opportunities for direct service support, the Little Valley Fire Department may benefit from exploring other collaborative opportunities, such as a memorandum of understanding (MOU) focused on training support, information sharing, and coordination on grant opportunities relevant to volunteer fire departments. Overall, it is recommended that the District continue implementing the accountability and transparency measures discussed in prior sections of this MSR to support operational efficiency, financial sustainability, and ongoing statutory compliance. Ch. 10 Governance Options 40 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft • Historically, the population within the Little Valley CSD has remained stable. As of 2025, the District reports a population of 70. • No significant growth is anticipated in the foreseeable future, as the District mainly serves as a summer home and retirement community, with many properties considered vacation/hunting cabins that typically remain unoccupied except during the summer and hunting seasons. • Additionally, there are no job opportunities or other essential services such as medical and dental care, grocery stores, gas stations, and shopping centers within Little Valley, which further indicates that growth and development within the community will likely remain stable or minimal, if any. • According to Census Bureau data, the statewide MHI for 2017- 2021 is estimated at $84,097, and hence, the calculated threshold of $67,277 (80 percent) defines whether a community is identified as disadvantaged. According to the California Department of Water Resources (DWR) Mapping Tool, the entirety of the Little Valley CSD is considered a disadvantaged community (DAC). • The District provides water and fire protection services to the Little Valley community. Ch. 11 Determinations 41 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft • The District's volunteer Fire Department provides fire suppression and emergency medical services (EMS) within the Little Valley Community. • The Little Valley FD operates a single small station within the CSD office. The District owns two fire-related pieces of equipment: a 1984 1,700-gallon water tender and a 1991 400-gallon fire engine. • The District reports that infrastructure needs requiring non-routine repairs, such as roof repairs, are estimated to cost between $2,000 and $7,000 to ensure continued reliable operation. Funding is not readily available, and the District anticipates applying for grants to fund the necessary capital improvements. • Demand for fire and EMS in the Little Valley community has remained stable due to its low population and remote location. Annual service calls have declined over the past three years, from a high of 20 calls in 2022 to 12 in 2023 and nine in 2024. In 2024, EMS calls accounted for more than 66 percent of total calls (six calls), followed by two calls for fire or hazardous materials and one call for a motor vehicle accident • The District reports volunteer turnover and a new fire chief appointment, necessitating enhanced training for fire and EMS. Training and capacity-building opportunities are available through the National Volunteer Fire Council (NVFC), which offers virtual courses, grants, and equipment donation programs, as well as the Good Neighbor Firefighter Safety Program that provides financial support to small rural departments. Additional in-person training resources may also be available through the California State Firefighters' Association, including no-cost recruitment and leadership workshops with reimbursed travel. It is recommended that the District leverage these programs to strengthen volunteer skills, improve retention, and enhance overall operational effectiveness. • The District operates a central water system serving roughly 60 parcels in the unincorporated community of Little Valley. The District also provides truck fill-up services to out-of-area customers. • The District relies on a contracted on-call water operator to handle emergencies and required reporting, while community volunteers assist with routine system maintenance. Ch. 11 Determinations 42 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft • The District's water system includes a groundwater well, a 126,000-gallon storage tank, and a distribution network. • The District serves 43 connections, including 41 residential customers using an estimated 350 gallons per day and two ranch connections using about 1,050 gallons per day each. Additional demand comes from irrigation for approximately 300 commercially grown cannabis plants, at roughly 6 gallons per plant per day during the growing season, as well as seasonal pool fill-ups for three customers. Based on unmetered usage estimates, the District's total annual water consumption is approximately 6,338,000 gallons. • The District monitors drinking water quality and reports results annually through a Consumer Confidence Report. The 2024 report confirms that all detected contaminants were within applicable regulatory limits and complied with health standards. A monitoring violation related to lead and copper sampling occurred in 2024; however, it was not considered an emergency, and corrective sampling was scheduled for September 2025. • The District is working to meet the Senate Bill 552 emergency preparedness and reporting requirements to improve drought resilience by retaining Provost & Pritchard Consulting Group to evaluate the system and pursue grant funding for required infrastructure improvements. • The District also initiated a Drinking Water Improvement Project to address aging water infrastructure, including the 1975 water storage tank, and is currently preparing to execute a Drinking Water State Revolving Fund (DWSRF) through a planning funding agreement with the State Water Resources Control Board (SWRCB). • Little Valley CSD faces persistent financial administration challenges, including the lack of an organized bookkeeping system, manual compilation of financial data, and turnover in the treasurer position. These constraints have limited the District's ability to meet statutory requirements under Government Code §26909, which requires annual audits or approved alternatives such as biennial or five-year audits for low-revenue districts. • To address historical funding shortages in water service delivery, the District initiated a Prop 218 process, including a Rate Study to adopt a new rate structure for the various customer classes, including projected subsequent annual rate increases through 2029. • The new rate took effect in August 2025 and aims to stabilize revenue, establish financial reserves, and fund the installation of a wellhead meter to comply with State mandates. Ch. 11 Determinations 43 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft Delinquency, however, remains a challenge as some property owners, including non- resident owners, have stopped paying their water bills due to dissatisfaction with the rate increase. • To address water billing delinquencies, it is recommended that the District transition from monthly to annual water billing through the Lassen County tax roll, aligning with the existing fire special tax collection method to reduce delinquencies and administrative costs. • The District also faces ongoing challenges in tracking fire service revenues held by the County, as adoption of a formal resolution is required to receive those funds. To address these challenges, it is recommended that the District consider direct remittance of special tax revenues from the County to enhance fund tracking, improve cash flow management, and ensure timely payment of District expenses. • Due to the District's rural location, facility-sharing opportunities are limited. However, it is recommended that the District explore collaborative opportunities with the nearest fire agency, the Fall River Valley Fire District, to address capacity challenges in fire service delivery. One approach is to establish a memorandum of understanding (MOU) focused on training support, information sharing, and coordination of grant opportunities relevant to volunteer fire departments. • Little Valley CSD faces persistent challenges, including limited administrative capacity, governance constraints, inadequate financial and recordkeeping systems, restricted internet access, compliance gaps, and difficulties coordinating with County agencies. • The District is governed by a five-member elected Board, currently with one vacancy due to the limited pool of qualified volunteers and the unpaid, time-intensive nature of service. Board agendas are posted in a physical location; however, due to the lack of a District website, there is a noncompliance risk under the Brown Act and SB 929. It is recommended that the District adopt a formal hardship resolution, as allowed under SB 929, citing its inability to meet the statutory website requirements. Ch. 11 Determinations 44 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft • The District's administrative operations are also constrained by the absence of paid staff, turnover in the treasurer position, the lack of legal counsel, limited internet access, and the absence of district-owned computers, all of which reduce capacity to maintain records, manage governance, ensure regulatory compliance, and oversee personnel matters. • Due to limited intergovernmental coordination with County offices, audit compliance and legal guidance have been impacted. It is recommended that the District work with Lassen LAFCO to establish formal protocols, including regular meetings with County staff, to improve communication and operational efficiency. • Overall, it is recommended that the District continue implementing the accountability and transparency measures to support operational efficiency, financial sustainability, and ongoing statutory compliance. Ch. 11 Determinations 45 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft LAFCO is required to prepare a written statement of determination with respect to the following areas when updating a special district's SOI, as specified by the Cortese-Knox- Hertzberg Local Government Reorganization Act of 2000. • Little Valley CSD is not a land use authority and does not have primary responsibility for implementing growth strategies. • According to Lassen County's General Plan, land use within and surrounding areas of Little Valley is designated for extensive agriculture, which identifies lands devoted to or having high suitability potential for the growing of crops and/or the raising of livestock on natural or improved pasture. • There are no anticipated changes in land use in the foreseeable future. • The District encompasses 51 residences, many of which are vacation or hunting cabins that remain unoccupied for most of the year. Additionally, a lack of job opportunities and essential services, such as medical and dental care, grocery stores, gas stations, and shopping centers, within the District. • There is no significant population growth or development expected, indicating that demand for public services will remain stable. • The District's existing facilities and equipment for fire services are sufficient to meet current service demand, which has remained low and stable due to the community's small Ch. 12 SOI Update 46 Policy Consulting Associates, LLC Little Valley CSD MSR Public Review Draft population and rural location. However, aging facilities, limited funding for non-routine repairs, and volunteer turnover present ongoing capacity challenges. • The District's water system currently has sufficient capacity to meet existing water demand, and drinking water quality complies with applicable health standards. The District has also made efforts to address ongoing challenges related to water revenue shortages and aging infrastructure by increasing rates and securing grants to fund capital improvement projects. • There are no communities of interest within Little Valley CSD. • According to the DWR Mapping Tool, the entirety of Little Valley CSD is considered a disadvantaged community. It is recommended that the Commission reaffirm the existing conterminous SOI for Little Valley CSD. Ch. 12 SOI Update 47 Policy Consulting Associates, LLC