LAFCO
Pacific Reefs Water District, 2024
Read the report at Local Agency Formation Commissions ↗
Pacific Reefs Water District Photo Credit
Municipal Service Review and
Sphere of Influence Update
Prepared By/For: Workshop: May 6, 2024
Mendocino LAFCo Public Hearing: June 3, 2024
200 South School Street
Adopted: June 3, 2024
Ukiah, California 95482
LAFCo Resolution No: 2023-24-06
http://www.mendolafco.org/
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Resolution No. 2023-24-06
of the Mendocino Local Agency Formation Commission
Approving the
Pacific Reefs Water District
Municipal Service Review and Sphere of Influence Update
WHEREAS, the Mendocino Local Agency Formation Commission, hereinafter referred to as
the “Commission”, is authorized to conduct municipal service reviews and establish, amend, and
update spheres of influence for local governmental agencies whose jurisdictions are within Mendocino
County; and
WHEREAS, the Commission conducted a municipal service review to evaluate the Pacific
Reefs Water District, hereinafter referred to as the “PRWD or District”, pursuant to California
Government Code Section 56430; and
WHEREAS, the Commission conducted a sphere of influence update for the District
pursuant to California Government Code Section 56425; and
WHEREAS, the Commission held a public workshop on May 6, 2024 to hear public and
agency comments and provide direction on revisions to the District’s Draft MSR/SOI update; and
WHEREAS, the Executive Officer gave sufficient notice of a public hearing to be conducted
by the Commission in the form and manner prescribed by law; and
WHEREAS, the Executive Officer’s report and recommendations on the municipal service
review and sphere of influence update were presented to the Commission in the manner provided by
law; and
WHEREAS, the Commission heard and fully considered all the evidence presented at a public
hearing held on the Municipal Service Review and Sphere of Influence update on June 3, 2024; and
WHEREAS, the Commission considered all the factors required under California
Government Code Sections 56430 and 56425.
NOW, THEREFORE, BE IT RESOLVED, DETERMINED AND ORDERED by the
Mendocino Local Agency Formation Commission, as follows:
1. The Commission, as Lead Agency, finds the municipal service review is categorically exempt
from further review under the California Environmental Quality Act pursuant to Title 14 of
the California Code of Regulations §15306 (Class 6 Exemption). This finding is based on the
use of the municipal service review as a data collection and service evaluation study. There are
no land use changes or environmental impacts created or recommended by the MSR. The
information contained within the municipal service review may be used to consider future
actions that will be subject to additional environmental review.
2. The Commission, as Lead Agency, finds the sphere of influence update is exempt from further
review under the California Environmental Quality Act pursuant to Title 14 of the California
Code of Regulations §15061(b)(3) (General Rule). This finding is based on the Commission
determining with certainty that the sphere of influence update will have no possibility of
significantly effecting the environment given that this update does not grant new municipal
LAFCo Resolution No. 2023-24-06 06-03-2024
TABLE OF CONTENTS
1 INTRODUCTION ............................................................................................................................ 1-1
1.1 Local Agency Formation Commission .................................................................................... 1-1
1.2 Mendocino LAFCo ................................................................................................................. 1-1
1.3 Municipal Service Review ...................................................................................................... 1-2
1.4 Sphere of Influence ............................................................................................................... 1-3
1.5 Additional Local Policies ........................................................................................................ 1-3
1.5.1 Mendocino County General Plan – Coastal Element ......................................................... 1-3
1.6 Senate Bill 215 ...................................................................................................................... 1-4
2 AGENCY OVERVIEW ...................................................................................................................... 2-1
2.1 History .................................................................................................................................. 2-1
2.1.1 Formation........................................................................................................................ 2-1
2.1.2 Boundary ......................................................................................................................... 2-1
2.1.3 Services ........................................................................................................................... 2-1
2.1.4 Facilities .......................................................................................................................... 2-1
2.2 Government Structure .......................................................................................................... 2-5
2.2.1 Governing Body ............................................................................................................... 2-5
2.2.2 Public Meetings ............................................................................................................... 2-6
2.2.3 Standing Committees ...................................................................................................... 2-6
2.2.4 Public Outreach ............................................................................................................... 2-6
2.2.5 Complaints ...................................................................................................................... 2-6
2.2.6 Transparency and Accountability ..................................................................................... 2-7
2.3 Operational Structure ........................................................................................................... 2-7
2.3.1 Management and Staffing ............................................................................................... 2-7
2.3.2 Agency Performance ....................................................................................................... 2-8
2.3.3 Regional and Service-Specific Participation ...................................................................... 2-8
2.3.4 Shared Service Delivery ................................................................................................... 2-9
2.3.5 Governmental Structure and Community Needs ............................................................ 2-11
2.4 Finances .............................................................................................................................. 2-11
2.4.1 Current Fiscal Health ..................................................................................................... 2-11
2.4.2 Long Term Financial Considerations ............................................................................... 2-13
2.5 Growth................................................................................................................................ 2-15
2.5.1 Area History .................................................................................................................. 2-15
2.5.2 Present and Planned Land Use and Development .......................................................... 2-17
2.5.3 Existing Population ........................................................................................................ 2-19
2.5.4 Projected Growth .......................................................................................................... 2-19
2.5.5 California Housing Goals ................................................................................................ 2-19
2.6 Disadvantaged Unincorporated Communities ..................................................................... 2-20
3 MUNICIPAL SERVICES .................................................................................................................... 3-1
3.1 Service Overview ................................................................................................................... 3-1
3.1.1 Services ........................................................................................................................... 3-1
3.1.2 Service Area .................................................................................................................... 3-1
3.1.3 Outside Agency Services .................................................................................................. 3-1
3.2 Water.................................................................................................................................... 3-2
3.2.1 System History................................................................................................................. 3-2
3.2.2 Service Overview ............................................................................................................. 3-2
3.2.3 Facilities and Infrastructure ............................................................................................. 3-2
3.2.4 Service Adequacy ............................................................................................................ 3-3
3.3 Determinations ..................................................................................................................... 3-5
3.3.1 MSR Review Factors ........................................................................................................ 3-5
4 SPHERE OF INFLUENCE ................................................................................................................. 4-1
4.1 Mendocino LAFCo Policies ..................................................................................................... 4-1
4.2 Existing Sphere of Influence .................................................................................................. 4-3
4.2.1 Study Areas ..................................................................................................................... 4-3
4.2.2 Area of Interest Designation ............................................................................................ 4-4
4.3 Proposed Sphere of Influence ............................................................................................... 4-4
4.4 Consistency with LAFCo Policies ............................................................................................ 4-4
4.5 Determinations ..................................................................................................................... 4-4
4.5.1 Present and planned land uses ........................................................................................ 4-5
4.5.2 Present and probable need for facilities and services in the area ..................................... 4-5
4.5.3 The present capacity of public facilities and adequacy of public services that the agency
provides or is authorized to provide.............................................................................................. 4-5
4.5.4 The existence of any social or economic communities of interest in the area if the
Commission determines that they are relevant to the agency ....................................................... 4-6
4.5.5 The present and probable need for public facilities and services of any disadvantaged
unincorporated communities ........................................................................................................ 4-6
4.6 Recommendation .................................................................................................................. 4-6
5 REFERENCES ................................................................................................................................. 5-1
6 ACRONYMS ................................................................................................................................... 6-1
7 ACKNOWLEDGEMENTS ................................................................................................................. 7-1
7.1 Report Preparation ............................................................................................................... 7-1
7.2 Assistance and Support ......................................................................................................... 7-1
8 APPENDICES ................................................................................................................................. 8-1
8.1 Appendix A – Open Government Resources .......................................................................... 8-1
8.2 Appendix B – Website Compliance Handout .......................................................................... 8-2
8.3 Appendix C – Housing Legislation Trends and Results ............................................................ 8-3
8.4 Appendix D – District Financial Audits ................................................................................... 8-6
Table of Figures
Figure 2-1: Pacific Reefs Water District Boundary ............................................................................................. 2-3
Figure 2-2: Mendocino County Water and Sanitation Districts and Companies ............................................... 2-4
Figure 2-3 Adjacent private water service providers ....................................................................................... 2-10
Figure 2-4: Albion and Schooner's Landing Marina ......................................................................................... 2-15
Figure 2-5 Albion, California ............................................................................................................................ 2-16
Figure 2-6 Pacific Reefs Subdivision ................................................................................................................. 2-16
Figure 2-7: Mendocino County General Plan Designations ............................................................................. 2-18
Figure 2-8: Mendocino County Zoning Map .................................................................................................... 2-18
Figure 3-1: Mendocino Coast Hydrologic Unit Watershed ................................................................................ 3-1
Figure 3-2: New 30,000-gallon bolted steel water tank replacement project schematic ........................ 3-3
INTRODUCTION 1-1
1 INTRODUCTION
This chapter provides an introductory overview of Local Agency Formation Commissions (LAFCos),
Mendocino LAFCo, and additional details relevant to the Municipal Service Review (MSR) and Sphere of
Influence (SOI) Update process for Pacific Reefs Water District (PRWD/District).
1.1 Local Agency Formation Commission
The Local Agency Formation Commission (LAFCo) is a quasi-legislative, independent local agency that was
established by State legislation in 1963 to oversee the logical and orderly formation and development of
local government agencies including cities and special districts. There is one LAFCo for each county in
California.
LAFCo is responsible for implementing the Cortese-Knox-Hertzberg Local Government Reorganization Act
of 2000 (CKH) under California Government Code Section 56000 et. seq. in order to promote orderly
growth, prevent urban sprawl, preserve agricultural and open space lands, and oversee efficient provision
of municipal services.
LAFCo has the authority to establish and reorganize cities and special districts, change their boundaries
and authorized services, allow the extension of public services, perform municipal service reviews, and
establish spheres of influence. Some of LAFCo’s duties include regulating boundary changes through
annexations or detachments and forming, consolidating, or dissolving local agencies.
1.2 Mendocino LAFCo
The CKH Act provides for flexibility in addressing State regulations to allow for adaptation to local needs.
Each LAFCo works to implement the CKH Act to meet local needs through the flexibility allowed in how
state regulations are implemented through establishment of local policies to address the unique
conditions of the county. As part of this process, Mendocino LAFCo has adopted policies, procedures and
principles that guide its operations. These policies and procedures can be found on Mendocino LAFCo’s
website1.
Mendocino LAFCo has a public Commission with seven regular Commissioners and four alternate
Commissioners. The Commission is composed of two members of the Mendocino County Board of
Supervisors, two City Council members, two Special District Board of Directors members, and one Public
Member-At-Large. The Commission also includes one alternate member for each represented category.
Table 1-1 below lists the current members, the category they represent, if they are an alternate, and the
date their term expires.
Table 1-1: Current Mendocino LAFCo Commissioners, 2024
Commissioner Name Position Representative Agency Term Expires
Gerardo Gonzalez Commissioner City 2026
Candace Horsley Commissioner Special Districts 2026
Glenn McGourty Commissioner County 2024
Maureen Mulheren Chair County 2026
Mari Rodin Commissioner City 2025
1 Mendocino LAFCo Policies and Procedures Manual http://www.mendolafco.org/policies.html.
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
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INTRODUCTION 1-2
Commissioner Name Position Representative Agency Term Expires
Gerald Ward Vice-Chair/Treasurer Public 2026
Vacant Commissioner Special Districts 2024
Francois Christen Alternate Special District 2026
Douglas Crane Alternate City 2025
John Haschak Alternate County 2027
Vacant Alternate Public 2027
Source: Mendocino LAFCo
1.3 Municipal Service Review
The CKH Act requires each LAFCo to prepare a Municipal Service Review (MSR) for its cities and special
districts (GC §56430)2. MSRs are required prior to and in conjunction with the update of a Sphere of
Influence (SOI) (Assembly Committee on Local Government, 2023). This review is intended to provide
Mendocino LAFCo with the necessary and relevant information related to the services provided by PRWD.
An MSR is a comprehensive analysis of the services provided by a local government agency to evaluate
the capabilities of that agency to meet the public service needs of their current and future service area.
An MSR must address the following seven factors:
1. Growth and population projections for the affected area.
2. The location and characteristics of any disadvantaged unincorporated communities within or
contiguous to the sphere of influence.
3. Present and planned capacity of public facilities, adequacy of public services, and infrastructure
needs or deficiencies including needs or deficiencies related to sewers, municipal and industrial
water, and structural fire protection in any disadvantaged unincorporated communities within or
contiguous to the sphere of influence.
4. Financial ability of agencies to provide services.
5. Status of, and opportunities for, shared facilities.
6. Accountability for community service needs, including governmental structure and operational
efficiencies.
7. Any other matter related to effective or efficient service delivery, as required by commission
policy.
Municipal Service Reviews include written statements or determinations with respect to each of the seven
mandated areas of evaluation outlined above. These determinations provide the basis for LAFCo to
consider the appropriateness of a service provider’s existing and future service area boundary. This MSR
Update studies the water services provided by PRWD. This review also provides technical and
administrative information to support Mendocino LAFCo’s evaluation of the existing boundary for the
District.
With this MSR, Mendocino LAFCo can make informed decisions based on the best available data for the
service provider and area. Written determinations (similar to ‘findings’), as required by law, are presented
2 GC §56430 text can be found here: https://law.justia.com/codes/california/2022/code-gov/title-5/division-3/part-2/chapter-
4/section-56430/
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
Influence Update
INTRODUCTION 1-3
in Chapter 3.3. LAFCo is the sole authority regarding approval or modification of any determinations,
policies, boundaries, spheres of influence, reorganizations, and provision of services.
Ideally, an MSR will support LAFCo and will also provide the following benefits to the subject agencies:
• Provide a broad overview of agency operations including type and extent of services provided;
• Serve as a prerequisite for a SOI Update;
• Evaluate governance options and financial information;
• Identify areas within the factors noted above that may benefit from improvement;
• Demonstrate accountability and transparency to LAFCo and to the public; and
• Allow agencies to compare their operations and services with other similar agencies.
1.4 Sphere of Influence
The CKH Act requires LAFCo to adopt an Sphere of Influence (SOI) for all local agencies within its
jurisdiction. An SOI is “a plan for the probable physical boundary and service area of a local agency or
municipality as determined by the Commission” (GC §56076)3.
When reviewing an SOI for a municipal service provider, under GC §56425€4, LAFCo will consider the
following five factors:
1. The present and planned land uses in the area, including agricultural and open space lands.
2. The present and probable need for public facilities and services in the area.
3. The present capacity of public facilities and adequacy of public services that the agency provides
or is authorized to provide.
4. The existence of any social or economic communities of interest in the area if the commission
determines that they are relevant to the agency.
5. For an update of a sphere of influence of a city or special district that provides public facilities or
services related to sewers, municipal and industrial water, or structural fire protection, that occurs
pursuant to GC §56425(g) on or after July 1, 2012, the present and probable need for those public
facilities and services of any disadvantaged unincorporated communities within the existing
sphere of influence.
Sphere of Influence studies include written statements or determinations with respect to each of the five
mandated areas of evaluation outlined above. These determinations provide the basis for LAFCo to
consider the appropriateness of establishing or modifying a service provider’s SOI or probable future
boundary.
1.5 Additional Local Policies
1.5.1 Mendocino County General Plan – Coastal Element
The Mendocino County General Plan was originally adopted in November 1985 and last updated in
November of 2021. In conformance with the Coastal Act, the County maintains a Coastal Element as part
of their Local Coastal Program. Given Pacific Reefs’ coastal location, the Coastal Element includes a section
3 GC §56076 text can be found here: https://law.justia.com/codes/california/2022/code-gov/title-5/division-3/part-1/chapter-
2/section-56076/
4 GC § 56425-56434 text can be found here: https://law.justia.com/codes/california/2010/gov/56425-56434.html
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
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INTRODUCTION 1-4
of policies pertaining specifically to Pacific Reefs and the neighboring community of Albion. The
Mendocino County General Plan Coastal Element identifies the Albion Planning Area, which includes
Albion Ridge, Middle Ridge, Navarro Ridge, and the Pacific Reefs Subdivision. There are no coastal plan
policies specific to the area served by Pacific Reefs Water District.
(County, 2021a)
1.6 Senate Bill 215
Senate Bill 215 (Wiggins) requires LAFCo to consider regional transportation plans and sustainable
community strategies developed pursuant to SB 375 before making boundary decisions. Senate Bill 375
(Sustainable Communities and Climate Protection Act) requires each metropolitan planning organization
(MPO) to address regional greenhouse gas (GHG) emission reduction targets for passenger vehicles in
their Regional Transportation Plan (RTP) by integrating planning for transportation, land-use, and housing
in a sustainable communities strategy.
Mendocino County is not located within an MPO boundary and therefore is not subject to the provisions
of SB 375. However, the Mendocino Council of Governments (MCOG) supports and coordinates the local
planning efforts of Mendocino County and the Cities of Fort Bragg, Point Arena, Ukiah, and Willits to
address regional housing and transportation needs and helps provide a framework for sustainable
regional growth patterns through the 2018 Mendocino County Regional Housing Needs Allocation (RNHA)
Plan and Vision Mendocino 2030 Blueprint Plan. MCOG is also responsible for allocating regional
transportation funding to transportation improvement projects consistent with the 2017 RTP for
Mendocino County.
Mendocino County and the Cities of Fort Bragg, Point Arena, Ukiah, and Willits are the local agencies
primarily responsible for planning regional growth patterns through adoption and implementation of
general plan and zoning regulations. While Mendocino County is not subject to the provisions of SB 375,
LAFCo will review applicable regional transportation and growth plans when considering a change of
organization or reorganization application.
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
Influence Update
AGENCY OVERVIEW 2-1
2 AGENCY OVERVIEW
Table 2-1 PRWD Profile
Agency Name: Pacific Reefs Water District
General Manager/Contact: Robert Cutler, President
Office Location: 34177 Pacific Reefs Road, Albion, CA 95410
Mailing Address: PO Box 314, Albion, CA 95410
Phone Number: (707) 937-2234
Website: None
Email: robert.cutler@attglobal.net
Date of Formation: June 5, 1967
Agency Type: Independent Special District, Single-Service Provider
Enabling Legislation County Water District Law: Water Code § 34000–38501
Board Meeting Schedule: Quarterly at Board member residences within the District, on a
rotating basis; dates and agendas are distributed two weeks prior
to meetings.
2.1 History
2.1.1 Formation
The Pacific Reefs Water District (PRWD/District) was formed on June 5, 1967 under California Water Code
§34503, by LAFCo Resolution No. 67-5, for the sole purpose of providing water service to the Pacific Reefs
Subdivision residents. The Certificate of Filing with the Office of the Secretary of State is dated January 8,
1968.
2.1.2 Boundary
The District is located in an unincorporated area of southwestern Mendocino County, near the small
unincorporated coastal community of Albion. The District is located approximately a half mile south of
Albion, which is approximately seven miles south of the Village of Mendocino. The District’s service area
is a narrow strip of land on the ocean bluffs located between State Highway 1 and the Pacific Ocean. The
District boundary coincides with the Pacific Reefs Subdivision, a 24-lot gated, residential subdivision
served by private streets that encompasses approximately 34 acres. See Figure 2-1.
2.1.2.1 BOUNDARY CHANGE HISTORY
There have been no changes to the District boundary since its formation in 1967.
2.1.3 Services
The District provides water services to lot owners within the Pacific Reefs Subdivision. No other services
are provided and no out-of-agency connections exist. For more information regarding this service, refer
to Section 3.
2.1.4 Facilities
On average, the District supplies approximately 400,000 gallons of drinking water annually to its 14
customers and provides backup water supply to 3 additional customers within the District that are on
private wells. The District owns a small parcel less than an acre in size, which houses the springs and well,
water storage tanks and pumphouse facilities. The storage tanks include a 30,000-gallon steel-bolted tank,
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
Influence Update
AGENCY OVERVIEW 2-2
constructed in 2024; two 5,000 gallon plastic tanks; a water treatment shed; and associated
infrastructure. The distribution system consists of approximately 2,000 feet of 3-inch and 4-inch
graduated water supply lines from the water tanks to each of the 24 lots within the subdivision. For more
information regarding District facilities and infrastructure, refer to Section 3.
2.1.4.1 LATENT POWERS
Latent powers are those services, functions or powers authorized by the principal act under which the
District is formed, but that are not being exercised and have not been authorized by LAFCo. The California
Water District Law (Water Code §34000 – 38501) identifies the following potential powers:
a) Production, storage, transmission, and distribution of water for irrigation, domestic, industrial,
and municipal purposes, and any drainage or reclamation works connected therewith or
incidental thereto.
The PRWD is a single-service provider delivering water services only and no other latent powers are
authorized under its principal act. Wastewater service within the District boundaries is currently provided
by private on-site septic systems.
Other water service providers in the nearby region are listed below:
• Albion Mutual Water Company
• Albion Field Station
• Seafoam Lodge
For a regional map of Mendocino County’s water and sanitation districts and companies see Figure 2-2.
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
Influence Update
Albion
River
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Pacific Reefs Water District Pacific Reefs Water Distirct Highways
o
Pacific Reefs Water District SOI Roads
Source: This map was prepared by the Mendocino County
Information Services Division GIS Program, May 30, 2023.
Albion Mutual Water Company
Note: This map is not a survey product.
320 160 0 320
Parcels
Feet
AGENCY OVERVIEW 2-5
2.2 Government Structure
2.2.1 Governing Body
The Board of Directors is the legislative body for the District and is responsible for establishing policy,
adopting and amending the annual budget, enacting ordinances, adopting resolutions, and appointing
committees.
The District is governed by a five-member Board of Directors, which until 1993 was the Mendocino County
Board of Supervisors. In 1993, an independent board was appointed by the Board of Supervisors to serve
the District. PRWD is a landowner-voter district (§56050) with directors elected by landowners within the
district boundary to serve four-year terms. In accordance with best practices and the intent of Elections
Code 10505, the board should consider establishing staggered terms aligned with the General Election
cycle.
See Table 2-2 PRWD Board of Directors for the current directors and their term limits.
Table 2-2 PRWD Board of Directors
Name Office/Position Term Expiration
Robert Cutler President November 2025
Donald Falk Director November 2025
Stephen Francescini Director November 2025
Howard Pines Director November 2025
Jeannette Rasker Director November 2025
Source: Cutler, 2023
In order to be elected to the Board, candidates must be registered voters residing within the District
boundaries. If there are insufficient candidates for election of Board vacancies, or if the number of filed
candidates is equal to the number of Board vacancies, then District Board members may be appointed in
lieu of election by the County Board of Supervisors per Elections Code §10515. New Board members take
office at noon on the first Friday in December following their election.
Government Code §1780-1782 governs the process for appointment of Board of Director seats vacated
prior to the scheduled term expiration date. The District Board of Directors has 60 days to appoint an
interested and qualified individual to a vacant seat if proper notice requirements have been met. If the
District cannot fill the seat within the 60-day period, the Mendocino County Board of Supervisors can
appoint a Director to the District Board during a 30-day period following the initial 60-day period. If the
vacant seat is not filled during the total 90-day period, the vacant seat remains empty until the next
election.
The District Board of Directors elect officers annually at the January regular meeting. Officers include a
President, Secretary and Treasurer. The Board President serves as the representative for the District.
District Board members do not receive compensation for their public service or a stipend for attending
meetings (Cutler, 2023).
There have been no board vacancies in recent years.
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
Influence Update
AGENCY OVERVIEW 2-6
2.2.2 Public Meetings
Board meetings are held quarterly on the third Thursday of every third month (February, May, August,
November). Meetings are held by Zoom at board member residences on a rotational basis. To promote
transparency and accessibility for the public, the District should consider holding meetings in a public
meeting space.
Agendas are e-mailed and mailed to each of the property owners and interested parties two weeks prior
to each meeting. Minutes of the meetings are distributed within two weeks following the meetings. Public
comments are accepted at each meeting.
In accordance with the Brown Act, all District Board meetings are open to the public and are publicly
posted a minimum of 72 hours prior to regular meetings, or a minimum of 24 hours prior to special
meetings.
Public notices and meeting agendas are posted at the meeting location and emailed to all residents.
Meeting summaries are kept for all District Board of Directors meetings and are adopted at a subsequent
meeting. Additionally, public notices regarding Board of Director vacancies are emailed to all residents.
Regular board meetings, records, annual budgets and financial audits are kept current and maintained by
the Board President and Secretary. Public meeting information, including past agendas, reports,
resolutions, and approved meeting minutes are available upon request from the District Secretary.
2.2.3 Standing Committees
Committees assist in carrying out various functions of local government. The District currently does not
have any standing committees.
2.2.4 Public Outreach
With the passage of Senate Bill (SB) 929 in 2018, all special districts are required to establish and maintain
a website with specific information and accessibility requirements by January 2020 (a compliance handout
is included in Appendix B – Website Compliance Handout). SB 929 does allow for a special district to be
exempt from the website requirements if the District has adopted a resolution declaring that a hardship
exists that prevents the district from establishing or maintaining a website; the District has done so.
The District currently does not have website; however, the District emails all customers with updated
information including meeting notices and agendas. If any immediate problems occur with the water
system, the District will email all customers and physically post the pertinent information at each
customer’s property if appropriate.
2.2.5 Complaints
Landowners within the District may file complaints with any Director or staff member in person or by
phone, e-mail or mail. Complaints are typically discussed at the next board meeting. No complaints have
been received in the last five years.
LAFCo staff recommends that the Commission review any complaints at the next MSR/SOI Update, or
within three years of the completion of this MSR, whichever comes first.
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
Influence Update
AGENCY OVERVIEW 2-7
2.2.6 Transparency and Accountability
The PRWD Bylaws were originally approved on February 24, 1996; there have been no updates since
(Cutler, 2023). The Bylaws serve as the legal guidelines of the organization and provide written rules that
control internal affairs. They define the District's official name, purpose, officers titles and responsibilities,
how officers are to be assigned, how meetings should be conducted, and how often meetings will be held.
The District does not maintain any other additional policies outside of the Bylaws (Cutler, 2023).
The Political Reform Act requires all state and local government agencies to adopt and promulgate a
Conflict-of-Interest Code pursuant to GC §81000 et seq. The District does not currently maintain a Conflict-
of-Interest Code; however, Board members prepare annual Form 700s and submit to the State.
The Political Reform Act also requires persons who hold office to disclose their investments, interests in
real property, and incomes by filing a Statement of Economic Interests (Fair Political Practices Commission
Form 700) each year pursuant to GC §87203. The District maintains that they are current on their required
Form 700 filings with the Mendocino County Clerk’s Office (Cutler, 2023).
According to AB 1234, if a local agency provides compensation or reimbursement of expenses to local
government officials, then all local officials are required to receive two hours of training on public service
ethics laws and principles at least once every two years, and establish a written policy on reimbursements
pursuant to Government Code §53235. The District currently pays a stipend to the Board Treasurer
($2,240/year) and a Secretary ($1,200/year), neither of which are Board members.
Presently, neither the District staff or Directors attend any Brown Act related or ethics trainings making
the District in violation of the AB 1234. LAFCo recommends the District Board members and staff comply
with these requirements.
Refer to Appendix A for a brief list of educational resources regarding open government laws and
Appendix B for a website compliance handout.
2.3 Operational Structure
2.3.1 Management and Staffing
Operations and maintenance are performed year-round by a part-time Water Master under contract with
the District. The Water Master conducts daily inspections to ensure the system is operating correctly and
within the parameters of the District’s permit. The District holds its meetings at board member residences
and has no administrative office outside residences.
The Board President volunteers as the General Manager with the following responsibilities and duties:
oversee all management and customer service including customer billings, customer complaints,
connection enforcement duties, and managing the contract of the Water Master. (Cutler, 2023)
The Board of Directors assumes responsibility for annual budget preparation, expenditure monitoring,
Discharge Permits compliance, and Regional Water Quality Control Board (RWQCB) reporting.
Given the small size and lack of District staff, there is little need for evaluations and work load monitoring.
Board members review and approve meeting minutes, quarterly budgets and perform financial reviews.
The District does not conduct formal evaluations of overall district performance, such as benchmarking or
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annual reports. However, the Water Master attends all Board meetings to report and receive feedback
and direction from the Board. The contract with the Water Master is reviewed annually.
2.3.1.1 CONTRACT STAFFING AND SERVICES
The District maintains a contract for a Water Master and utilizes an independent Certified Public Account
(CPA) for biennial audits. (Cutler, 2023)
2.3.2 Agency Performance
A component of monitoring agency performance is routinely evaluating staff productivity. Because the
District has no employees other than the contracted Water Master, the District measures performance
through the Water Master’s regular reports at each District meeting. (Cutler, 2023)
The District also monitors and evaluates agency operations through regulatory reporting and review of
District databases and records.
2.3.2.1 CHALLENGES
The District states they are experiencing no challenges in providing services.
2.3.2.2 DISTINGUISHED SERVICE
The District did not provide any information related to distinguished services.
2.3.2.3 STRATEGIC OR SUCCESSION PLAN
The District does not have an established strategic plan, mission statement, or official goals. While the
District is not legally obligated to maintain these types of documents and/or plans, doing so helps to
provide an identity and some sense of security when it comes to the future of the District.
In lieu of these documents, the Board considers progress and setbacks over the prior year during the
annual budget development process. (Cutler, 2023)
2.3.3 Regional and Service-Specific Participation
The District does not participate in any interagency collaborative arrangements or mutual aid agreements.
During the 2020-2022 drought emergency, the District was able to meet customer demand with existing
supply. While there has been no formal collaboration with the Albion Mutual Water Company (AMWC) to
date, the District’s Water Master also serves that water service provider as well.
The District participates in a Joint Powers Authority (JPA) with the Special Risk Management Authority
(SDRMA) for the purchasing of insurance. The SDRMA is a JPA formed pursuant to Section 6500 et. Seq.,
California Government Code, is comprised of California special districts and agencies including such
districts. The SDRMA’s purpose is to jointly fund and develop programs to provide stable, efficient, and
long-term risk financing for special districts. These programs are provided through collective self-
insurance, the purchase of insurance coverage, or a combination thereof. (Calentano, 2023)
PRWD also participates in the North Coast Resource Partnership (NCRP) Integrated Regional Water
Management (IRWM) Program and received a grant from the organization in 2021 to install a new water
tank. The District does not participate in any other regional or service-specific associations and
organizations.
LAFCo staff recommends that the District consider future group participation efforts by attending regional
and service-specific meetings and communicating with colleagues regarding industry standards, best
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management practices, changing regulations, and service delivery models implemented by other local
agencies and organizations.
2.3.4 Shared Service Delivery
2.3.4.1 ADJACENT PROVIDERS
There are several private water service providers in the Albion area that are located within a mile of the
PRWD (Figure 2-2):
• Albion Mutual Water Company (CA2300502) – community water system; 27 connections
• Albion Field Station (CA2300512) – transient non-community water system; 29 connections
• Seafoam Lodge (CA2300620) – transient non-community; 24 connections
The PRWD does not currently participate in any shared collaborations with nearby private water service
providers; however, given the close proximity (0.7 miles) to Albion Mutual Water Company the District
could consider future collaborations as part of the scope of water service provision of in the local area.
The Albion Mutual Water Company, the closest private service provider to PRWD, currently has 27 service
connections and provides residential drinking water to approximately 30 full time residents. Average
service fees range between $41 and $60 per month. The Company has two active wells (East and West
Wells) and owns and/or maintains approximately 0.8 miles of pipeline and a treatment plant at the East
Well. The Albion Mutual Water Company’s governing board consists of five elected members with one-
year terms. There are no restrictions to the number of terms a member can serve. Stakeholders meet
annually at the Whitesboro Grange. The Company has no employees though it does contract for a Water
Master and bookkeeping services. Additionally, Board members assist with administrative and operational
responsibilities.
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Seafoam Lodge
Albion Field
Station
Albion Mutual Water Company
Pacific Reefs Water District
Figure 2-3 Adjacent private water service providers
Source: State Water Board GIS Water System Tool, 2023
2.3.4.2 SHARED SERVICES AND FACILITIES
The District does not currently jointly own or share facilities or services with other agencies. There are no
areas in or near the District boundaries that would be better served by a different agency.
With respect to emergency coordination, the District maintains relations with both the Albion-Little River
Fire Protection District and the Nonella Lane neighborhood located just south of the District. (Cutler, 2023)
2.3.4.3 DUPLICATION OF SERVICES
The AMWC is a nearby service provider providing residential drinking water services to the community of
Albion. Based on its close proximity to the District there is the potential for collaboration and coordination
of services.
The AMWC is regulated by the State Water Resources Control Board (SWRCB) Department of Drinking
Water (DDW). At the time of this report there have been no identified needs for coordination of services
between PRWD and the Company. While mutual water companies do not fall under the jurisdiction of
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LAFCo, the SWRCB has the authority to encourage and mandate consolidations if the agency determines
it necessary (SWRCB, 2023). Government Code §56375(r) gives LAFCo jurisdiction over annexation of
territory served by a mutual water company that operates a public water system into the jurisdiction of a
special district, with the consent of the respective public agency and mutual water company. Should a
consolidation of the services be of interest or necessity in the future, the entities in question would submit
an application to LAFCo.
2.3.4.4 INTERAGENCY COLLABORATION
The District does not participate in any interagency collaborative arrangements or mutual aid agreements.
(Cutler, 2023)
2.3.4.5 REGIONAL AND SERVICE-SPECIFIC PARTICIPATION
The PRWD participates in the North Coast Regional Partnership (NCRP) Integrated Regional Water
Management (IRWM) Program and has successfully obtained a Proposition 1 IRWM Round 1
Implementation Grant from DWR to install a new water storage tank. Participation in these types of joint
planning activities provides opportunity to pursue joint grant applications and to leverage other regional
resources.
It is recommended that the District enhance group participation efforts to learn about new opportunities
to achieve operational efficiencies by attending regional and service-specific meetings and
communicating with colleagues regarding industry standards, best management practices, changing
regulations, and service delivery models implemented by other local agencies.
2.3.5 Governmental Structure and Community Needs
2.3.5.1 ENHANCED SERVICE DELIVERY OPTIONS
The District is the only agency providing water services to the Pacific Reefs Subdivision. The PRWD does
not share services or facilities with other districts. Fire protection for properties within PRWD is provided
by Albion-Little River Fire Protection District. Wastewater service within the PRWD is provided by private
on-site septic systems.
No opportunities for the District to achieve organizational or operational efficiencies were identified
during the preparation of this MSR. However, the District is encouraged to plan for drought resilience to
prepare for periods of extended drought.
2.3.5.2 GOVERNMENT RESTRUCTURE OPTIONS
Government restructure options should be pursued if there are potential benefits in terms of reduced
costs, greater efficiencies, better accountability or representation, or other advantages to the public. No
opportunities for government restructure options were identified during the preparation of this MSR.
2.4 Finances
2.4.1 Current Fiscal Health
The PRWD operates as a water enterprise fund, meaning that charges for services are intended to pay for
the costs of providing such services. Funding sources for the District include tax assessments and fees for
water usage. The District operates out of a single fund for operational and maintenance purposes. The
District’s operational type is considered an enterprise activity in that they are financed and operated in a
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manner similar to private business enterprises where the intent is that the costs (including depreciation)
to provide the water services to the general public are financed or recovered primarily through user
charges. These enterprise activities are accounted for in the Enterprise Fund.
The following table provides year-end (not budget) financial information for the District. Table 2-3
summarizes the Statement of Revenues, Expenses, and Changes in Fund Net Position prepared by Michael
A. Celentano, CPA. The financial information in the table below represents the short-term financial
standing of the District based on reporting annual income, expenses, and profits/losses using the accrual
basis of accounting, which is an accounting method where revenue or expenses are recorded when a
transaction occurs rather than when payment is received or made.
Table 2-3: PRWD Financial Summary
FY 18-19 ($) FY 19-20 ($) FY 20-21 ($) FY 21-22 ($)
Beginning Net Position 74,454 83,344 78,749 87,757
Ending Net Position 83,344 78,749 87,757 157,156
Operating Revenues
Water Service Fees 13,082 12,025 14,487 14,507
User Assessment 23,611 17,549 28,577 28,577
Total Operating Revenues 36,693 29,574 45,539 43,084
Operating Expenses
Maintenance and Repairs 12,742 22,792 29,451 21,435
Insurance 1,374 1,460 2,562 3,234
Permits and Fees 489 923 554 1,169
Utilities 1,104 946 1,153 1,095
Administration 7,542 3,491 8,487 4,258
Depreciation 4,559 4,559 4,559 4,559
Total Operating Expenses 27,810 34,171 46,766 35,750
Net Income/(Loss) 8,883 (4,597) (1,227) 7,334
Other Non-Operating Revenues (Expenses)
Interest Income 7 2 2 3
Grant Revenue 0 0 10,233 62,062
Total Non-Operating Revenue 7 2 10,235 62,065
(Expenses)
Change in Net Position from Prior FY - (4,595) 9,008 69,399
The District’s cash accounts are summarized in Table 2-4.
Table 2-4: Cash Accounts
Type FY 18-19 FY 19-20 FY 20-21 FY 21-22
General Operations – Checking ($43) $1,926 $1,806 $10,541
General Operations – Savings $25,004 $25,755 $27,099 $32,572
Total Cash $25,004 $27,681 $28,905 $43,113
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2.4.1.1 REVENUES AND EXPENDITURES
Expenditures totaled $35,750 in FY 2021-2022, $46,766 in FY 2020-2021, and $34,171 in FY 2019-2020.
The top expenditures included maintenance/repairs, insurance, administration and depreciation.
In FYs 2020-21 and 2021-22, the District received grant funds from the North Coast Regional Partnership
Integrated Regional Water Management Program totaling $72,298 to fund its 30,000-gallon tank
replacement project. The total grant award is $386,000, implementation of which has extended into 2024.
The District’s cash accounts (Table 2-4) show a general upwards trend that indicates financial stability for
typical annual operations and maintenance.
2.4.1.2 ASSETS AND LIABILITIES
The largest asset for the District is infrastructure for which depreciation costs have been accounted for in
the expense section. The District does not have any debts and its liabilities are limited to accounts payable.
The District does not have a needs assessment or a capital improvement plan; therefore, it is not clear
what improvements are needed and at what cost.
2.4.1.3 NET POSITION
The District is currently operating at a net positive. The District has been implementing a grant-funded
project for a tank replacement; funds are accounted for in a separate line item in the budget.
The District evaluates its financial position during development of its annual budget. The District reports
that if, during the analysis of operational needs, additional revenue is necessary, the annual assessments
are reviewed and adjusted through a public hearing process. This suggests that the District may need to
re-evaluate the existing rates and fee structure.
2.4.2 Long Term Financial Considerations
2.4.2.1 RESERVES
The District does not maintain any formal policies related to reserves. As of April 2024, reserve funds
totaled $46,283.
2.4.2.2 OUTSTANDING DEBT/COST AVOIDANCE
The District currently has no debt.
2.4.2.3 RATE RESTRUCTURING
Revenue consists of water service fees and user assessment fees. The District’s current process is to review
its rates and assessments during the annual budget development process and propose increases, when
necessary, to support the on-going delivery of services. The District Board of Directors adopts rates and
fees annually at a duly noticed Public Hearing based on actual expenditures and cost recovery.
New water service connections to the District are charged a one-time fee of $1,500. This fee is due in full
before the water service connection is completed.
Each property owner has a metered water connection, which is read monthly by the Water Master. Billings
are quarterly and prepared and sent by the District Treasurer. Rates are tiered to encourage water
conservation, and are as follows:
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Table 2-5: District Rates
Gallons Rate ($/gallon)
1 – 4,000 0.015
4,001 – 15,000 0.02
15,001+ 0.06
Administrative fees are applied to those properties not currently utilizing water services. The
administrative fees are billed quarterly and are dependent on whether or not the property has a well:
without wells, $90 per quarter; with wells, $40 per quarter.
In addition to water service rates and administration fees, the District Board adopted user/service
assessment fees to pay for increased regulatory costs. The District’s annual water service assessment fee
of $750 is collected by Mendocino County Auditor-Controller as part of each property owner’s property
tax bill (PRWD Resolution No. 05-2020). However, in FY 2020-21, a $500 special assessment was added
for the purpose of installing the new tank to increase the annual assessments to $1,250 per year through
2024-25 (PRWD Resolution Nos. 04-2021 and 01-2022). The special assessment fee for tank installation is
set to expire at the end of fiscal year 2024-25; the water service annual assessment of $750 will remain in
place (PRWD Resolution No. 01-2022).
The District’s increased regulatory requirements and associated higher operations costs indicate that the
District may need to re-evaluate existing rates and fees on a more permanent basis.
Proposition 218 was approved by California voters in November 1996 to ensure that the setting of all
taxes and most charges to property owners be transparent and subject to voter approval. In addition,
Proposition 218 seeks to curb some perceived abuses in the use of assessments and property-related fees,
specifically the use of these revenue-raising tools to pay for general governmental services rather than
property-related services (LAO, 1996).
Prop 218 requires local governments to ensure that property-related fees comply with the measure's
calculation requirements. Specifically, local governments must make sure that no property owner's fee is
greater than the proportionate cost to provide the subject service to his or her parcel. Like assessments,
this requirement may result in local governments setting property-related fee rates on a block-by-block,
or parcel-by-parcel basis (LAO, 1996).
The record is not clear on whether the assessments were established in compliance with Prop 218. It is
recommended that the District prepare a rate study to identify and plan for infrastructure needs and
anticipated operating costs, and establish appropriate rates in compliance with the Prop 218 process.
2.4.2.4 CAPITAL IMPROVEMENT PLAN
The District currently does not maintain a Capital Improvement Plan (CIP). The District has indicated that
repairs to the existing water system need to be conducted, but because the District does not have a needs
assessment or a CIP, it is not clear what the costs associated with these replacements would be.
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2.5 Growth
2.5.1 Area History
The District is located immediately south of the small, unincorporated community of Albion, which is a
census-designated place located along State Highway 1 where the Albion River meets the Pacific Ocean.
Albion was first settled in 1853 by English Sea Captain William Richardson, who built the first sawmill to
begin operating on the redwood coast. A sawmill would continue to operate in Albion for the next 75
years, the last one closing in 1928. Albion has survived as a farming and ranching community and has a
thriving tourism industry with bed and breakfast inns, restaurants, a small marina, the Albion River and
Schooner’s Landing Campgrounds, and a historic wooden bridge spanning the mouth of the Albion River.
A small fishing fleet operates out of the harbor and a college-sponsored biological field station is located
across the river. Albion also has a US Post Office and a general store. (Source: A Short History of Albion,
California: Tides Turn Vacation Home)
Figure 2-4: Albion and Schooner's Landing Marina
2.5.1.1 PACIFIC REEFS SUBDIVISION
The Pacific Reefs Subdivision was developed in the 1960s and includes a total of 24 residential lots. The
Pacific Reefs Water District was formed on June 5, 1967 to serve the Subdivision; the boundaries are
coterminous.
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Figure 2-5 Albion, California
Figure 2-6 Pacific Reefs Subdivision
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2.5.2 Present and Planned Land Use and Development
The PRWD boundaries are entirely located within the unincorporated area of Mendocino County.
Mendocino County has land use authority over privately-owned lands within the District boundary and
makes land-use decisions based on the County’s General Plan and Zoning Regulations. The PRWD is also
located in the Coastal Zone and is subject to the regulations of the Coastal Element, a part of Mendocino
County’s Local Coastal Plan as approved by the Coastal Commission. Any proposed changes to the land
use or development patterns of the District area must be approved by the Coastal Commission (County of
Mendocino General Plan, 2009).
2.5.2.1 LAND USE
The specific land use designations within the District are Rural Residential (RR5, RR1, RR5-DL, RR1-DL).
Principally permitted RR uses are residential and associated utilities, light agriculture, and home
occupation. Rural Residential is not intended to be a growth area and residences should create minimal
impact on agricultural viability. This designation has larger minimum parcel sizes (e.g., RR-1: 40,000 sq. ft.
and RR-5: 5 acres). See Figure 2-7 for General Plan designations within the District boundary.
Within the Pacific Reefs Subdivision, all of the northeastern parcels adjacent to the ocean have a
combining district designation of Development Limitations (DL). This additional designation is used on
parcels or portions of parcels that have serious constraints that may prevent or severely limit
development (slope over 30 percent, erosion, or landslide). Many parcels with this designation have
experienced severe bluff erosion and currently may have no feasible building site remaining. In each case,
on-site inspection and tests will be necessary to determine whether a building site is viable should the
property owner choose to develop.
All of the parcels east of the District are designated Rangelands (RL), which is intended to encompass lands
within the Coastal Zone that are suited for and are appropriately retained for the grazing of livestock; this
designation may also contain some timber producing areas.
2.5.2.2 DEVELOPMENT
Future growth and development within the District is subject to Mendocino County land use regulations.
The County has adopted plans and policies to regulate growth, including a General Plan and a Zoning
Ordinance. The County’s Zoning Ordinance contains three major geographical zones (Inland, Coastal, and
Mendocino Town); the Pacific Reefs area is included in the Coastal Zone (County of Mendocino Coastal
Element, 2021). As shown in Figure 2-9, the County’s Zoning Map designates most of the Pacific Reefs
Subdivision and surrounding parcels as single-family residential and coastal commercial.
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Figure 2-7: Mendocino County General Plan Designations
Figure 2-8: Mendocino County Zoning Map
Source: (Mendocino County Web Zoning Map, 2024)
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2.5.3 Existing Population
The District serves the Pacific Reefs Subdivision, which consists of primary and secondary homes owned
and occupied primarily by retirees. According to the District, the average occupancy is two persons per
household and the year-round residency is approximately 34 persons, with additional weekend and
seasonal residents. The Pacific Reefs Subdivision is located within Census Tract 110.01 in Mendocino
County, which includes the area between Little River to the north, to areas south of Elk on the southern
edge, and has an estimated population of 2,027.
The nearest community is Albion, which is a Census Designated Place (CDP) with a population of 153. The
Albion CDP encompasses approximately 1.8 square miles and includes primarily rural residential
properties with commercial development along Highway 1.
2.5.4 Projected Growth
The District’s population is limited to residents within the Pacific Reefs Subdivision; currently, 17 of the 24
lots are developed. The anticipated growth of the District is limited to development of an additional seven
lots. At the current persons per household (approximately 2 persons per household), buildout of the
subdivision would result in an estimated population of 48 persons.
The State Department of Finance (DOF) projects that the population of Mendocino County will decline by
a little more than 2.7 percent in the next 10 years, from 91,601 in 2023 to 89,091 in 2033, and 89,139 in
2043. (DOF, 2023) The projected decline of 2.7 percent throughout the County suggests that buildout of
the residential parcels will likely not occur until well beyond the planning horizon of this document (DOF,
2023). Given that the PRWD is limited to the Pacific Reefs Subdivision, which has a set number of
undeveloped lots, buildout of the District is limited to the remaining seven lots.
However, changes to California housing laws could result in a slight increase in development and density
within the District above what is discussed above.
2.5.5 California Housing Goals
In 2017, the State of California passed SB 299 and SB 1069 to address the increasingly desperate need for
affordable housing in the State. The legislation allowed local ordinances for Accessory Dwelling Unit (ADU)
construction in districts zoned for single and multifamily residential uses. An ADU is a secondary dwelling
unit for one or more persons on the same parcel as a larger, primary dwelling. An ADU can either be
attached or detached to the primary residential structure on the property but must include complete
independent living facilities (including permanent provisions for entry, living, sleeping, eating, cooking and
sanitation, and adequate water service and sewage disposal systems).
As codified by GC §65852.150, the California Legislature found and declared that, among other things,
allowing ADUs in zones that allow single-family and multifamily uses provides additional rental housing
and is an essential component in addressing California’s housing needs. In the years since, state ADU law
has been revised to improve its effectiveness in creating more housing units.
New laws have since been passed which address barriers to their implementation at scale; for example,
setting development criteria for ADUs, streamlined permit processing, and limiting impact fees.
Implementation of state law requires updating local ordinances, estimating ADU capacity when used to
address regional housing need allocations (RHNA) in housing element updates, and a housing element
program to incentivize and promote ADUs that can be offered at affordable rents.
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As the state continues to pass legislation to help tackle the ongoing housing crisis, the inevitable impacts
to service providers as a result of development will continue to mount. It is imperative that small districts
such as PRWD stay up to date on legislative changes.
For additional information and data on housing legislation see Appendix 8.3.
2.6 Disadvantaged Unincorporated Communities
Senate Bill 244, which became effective in January 2012, requires LAFCo to evaluate any Disadvantaged
Unincorporated Communities (DUCs), including the location and characteristics of any such communities,
when preparing an MSR that addresses agencies that provide water, wastewater, or structural fire
protection services5. A DUC is an unincorporated geographic area with 12 or more registered voters with
a median household income (MHI) that is less than 80 percent of the State MHI. According to the US
American Census Survey (ACS) 2022 1-Year estimates, the statewide median household income for
California was $91,551 (US Census, 2022A). Thus, the MHI DUC threshold is $73,240 and the threshold for
severely disadvantaged unincorporated communities (SDUC) (less than 60 percent of the State MHI) is
$54,930.
DUCs are identified to address a myriad of issues from environmental justice to land-use planning. Linking
these disparate issues together, the sole statutory criterion for determination of a DUC is the MHI. The
smallest geographic units for which MHI data is publicly available are census block groups. Outside of
heavily urbanized areas, however, census block groups are geographically expansive. They often include
both incorporated and unincorporated territory and do not necessarily coincide with typically understood
community boundaries. Although a block group might be identified as having a MHI of less than 80
percent, various portions of that block group could be significantly wealthier in rural areas, or the block
group could split an otherwise contiguous community.
As a result, within rural areas, such as Mendocino County, assembling income data for specific
unincorporated communities is not always straightforward. In Mendocino County, identifying and
mapping DUC locations is a complex process because the delineation of DUC boundaries often differ from
those common to the local agency and the public. Some entities, such as Sonoma County LAFCo and
Stanislaus County, utilize Census Designated Place (CDP) communities to help provide usable geographies
for DUC boundaries, but even then, mapping and data challenges persist. In particular, MHI ratios are
subject to adjustment over-time and can result in a change to a community's disadvantaged status.
Similarly, the number of registered voters can fluctuate during election years causing further variability.
SB 244 describes the general characteristics of DUCs, but it does not provide specific guidance or
methodology for how to identify them, other than providing the following criteria:
• Contains 10 or more dwelling units in close proximity to one another;
• Is either within a city sphere of influence (SOI), is an island within a city boundary, or is
geographically isolated and has existed for more than 50 years; and
• Has a median household income that is 80 percent or less than the statewide MHI
5 Technical advisory on SB 244 can be found here: https://opr.ca.gov/docs/SB244_Technical_Advisory.pdf
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• For this analysis, per CALAFCO recommendation, calculated the “MHI Threshold” i.e. 80% of the
statewide MHI as $73,240, per the ACS MHI data (The MHI for the State of California is $91,551)
(US Census, 2022A)
• Income data was sourced from the American Community Survey (“ACS”) 5-year Estimates dataset
for 2018-2022 and the 2022 ACS 1-Year Estimates.
This State legislation is intended to ensure that the needs of these communities are met when considering
service extensions and/or annexations in unincorporated areas.
Mendocino County has an MHI of $65,520 with a majority of the County considered DUCs including both
the census tract and block group that the District is located within. (US Census, 2024) The census tract the
District is located within (Census Tract 110.01) has a population of 1,889 (986 households) and a MHI of
$40,529. (Census, 2024)
As previously stated, the District is located just south of the community of Albion which is a CDP. The
population of Albion is 153 (79 households). While there is no recent income data for the CDP,
approximately 44 percent of the Albion CDP population lives below the poverty line (US Census, 2024).
Because the Pacific Reefs Water District falls within the County of Mendocino and is not a CDP, the MHI
of its residents is assumed to approximate the County MHI of $65,520. Because this amount is lower than
the Statewide MHI threshold of $73,240, the District would be considered to be located within a DUC
under this analysis.
It is worth noting that the census block group the District is located within (Block Group 1) has a population
of 1,108 (463 households) and a MHI of $66,300 (US Census, 2024). By this measure the District would
not be considered a DUC. Further, given the specifics of the Subdivision, which is a gated residential
community of 24 residential lots located immediately on the coastline, it is difficult to quantify the District
as a DUC. Real estate prices in the Subdivision are in excess of a million dollars.
The residents within Pacific Reefs subdivision receive adequate services with respect to fire, which is
provided by Albion-Little River Fire Protection District 6. Wastewater services are provided by on-site
septic systems; no issues were brought to the attention of LAFCo staff during the preparation of this study.
The residents of Pacific Reefs Subdivison are receiving the essential municipal services of fire and water.
Wastewater is provided by private, onsite septic systems and appears adequate; no reports of septic
failures have been reported.
6 Source is the 2018 Mendocino LAFCo Multi-District Fire Protection Services SOI found here:
https://www.mendolafco.org/files/01d2409c9/Multi-District+Fire+SOI+Update+Adopted+FINAL.pdf
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3 MUNICIPAL SERVICES
A Municipal Service Review (MSR) is a comprehensive analysis of the services provided by a local
government agency to evaluate the capabilities of that agency to meet the public service needs of their
current and future service area. The MSR determinations inform the SOI Update process and assist LAFCo
in considering the appropriateness of a public service provider’s existing and future service area boundary.
The information and analysis presented in Chapters 2 and 3 of this document form the basis for the MSR
determinations provided under Section 3.3.
3.1 Service Overview
This is the second MSR prepared for the District; the first was adopted by the Commission in October
2014.
3.1.1 Services
The District provides water services to lot owners within the Pacific Reefs Subdivision; no other services
are provided.
3.1.2 Service Area
The District provides water services to 14 of the 17 developed lots within the Pacific Reefs Subdivision.
Water service is provided as a secondary-connection to the remaining three property owners with private
wells within the Subdivision. Of the 24 residential lots within the Subdivision, the District has adequate
infrastructure in place to provide water to the remaining seven lots should a property owner choose to
develop.
The PRWD is located in the Mendocino
Coast Hydrologic Unit Watershed (See
Figure 3-1). This watershed covers 298
square miles and is characterized by
rugged mountainous terrain with
erodible soils forested by redwoods,
douglas firs, madrones, and tan oaks.
Substantial data collection and
watershed restoration efforts have been
undertaken, and are continuing, in the
watershed through the efforts of private
and industrial landowners and local,
state, and federal agencies.
3.1.3 Outside Agency Services
The District does not provide any services
outside its jurisdictional boundaries and
there have been no requests for
extensions of services.
Figure 3-1: Mendocino Coast Hydrologic Unit Watershed
S ource: California State Water Board, North Coast Region 1
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MUNICIPAL SERVICES 3-2
3.2 Water
3.2.1 System History
The PRWD was formed in 1965 under the provisions of the Water Code for the State of California. No
further history of services was provided to LAFCo staff.
3.2.2 Service Overview
The District’s water supply is regulated by the SWRCB Division of Drinking Water (Permit No. 2300871)
and consists of two springs and a well, all of which are located on District-owned land within the
Subdivision and District boundaries. The well is equipped with a pump that operates at approximately 1.5
gallons per minute (gpm). The spring water is collected and pumped to the storage tanks. All water flows
through a chlorinator and a ultraviolet (UV) system before being pumped into the District’s above-ground
storage tanks. Existing storage capacity is estimated to be the equivalent of 57 days of average usage.
The District supplies an average of approximately 400,000 gallons annually to its 14 customers and
provides backup water supply to 3 additional customers within the District that utilitize private wells as
their primary water source. Average daily use for the District is estimated at 1,050 gallons per day (75
gallons per residence per day on average), with an average peak day demand at 1,400 gallons per day
(gpd) (100 gallons per residence). The District reported that the backup water supply customers have not
required District water, even during the 2020-2022 drought. The system is operating at approximately 60
to 80 percent capacity.
3.2.3 Facilities and Infrastructure
The District owns a small lot of less than an acre in size, which is the location of its springs and well, water
storage tanks and pumphouse facilities. The storage tanks include a 30,000-gallon bolted steel water tank
that will fully online by June 2024; two 5,000-gallon plastic tanks; a water treatment shed; and associated
infrastructure.
The distribution system consists of graduated water lines from the water tanks to each of the 24 lots
within the subdivision. The water supply is collected from springs and well and pumped into the storage
tanks, from which it is distributed by gravity to the District’s customers. The distribution system consists
of approximately 2,000 feet of 3-inch and 4-inch supply lines.
Additional infrastructure includes fire standpipes at the tanks throughout the neighborhood.
Operations and maintenance are performed year-round by a part-time Water Master under contract with
the District. The Water Master conducts daily inspections to ensure the system is operating correctly and
within the parameters of the District’s permit.
3.2.3.1 SYSTEM IMPROVEMENTS
The District recently received grant funding and approval of a coastal development permit to replace the
20,000 redwood water tank with a 30,000-gallon bolted steel water tank (Figure 3-2). The two existing
5,000-gallon plastic water tanks will remain. The new tank will be plumbed into the existing system to
provide a year-round reliable water supply to PRWD's customers. The tank replacement project is in
under construction and is expected to be completed by June 2024.
No other infrastructure needs have been identified at the time of this report.
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Figure 3-2: New 30,000-gallon bolted steel water tank replacement project schematic
Source: Mendocino County Coastal Development Permit 20210030
3.2.4 Service Adequacy
Based on information provided by the District regarding facilities, management practice and
accountability, and financing, PRWD’s service appears to be limited. The District has a part-time
contracted Water Master that provides maintenance and monitors operations, and conducts daily
inspections to ensure the system is operating correctly. The District relies heavily on Board members to
conduct daily affairs for the District. With past difficulties in securing enough Board members to fill
vacancies, due to a very small eligible population, the District could have trouble managing the system in
the future. In addition, the District does not have any future planning documents and did not provide
LAFCo with any information regarding age of infrastructure or when replacement would be necessary.
District revenues appear to be adequate to cover expenditures so far; however, the District has very little
reserves to cover unexpected expenses and relies on grants to fund infrastructure improvements. The
current system is operating at 60-80 percent capacity and it is anticipated that the system will be able to
handle buildout of the remaining seven lots and the three secondary water users full-time. In addition,
though the District was able to provide continuing services to customers during the most recent drought,
the District does not have any future planning documents related to the effects of climate change and
potential loss of groundwater resources.
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With the recent infrastructure upgrade, the District’s existing facilities and little growth in the service area
that is expected to occur, the District and its facilities are sufficient to serve buildout of the Subdivision.
3.2.4.1 REGULATORY PERMITS AND COMPLIANCE HISTORY
The Safe Drinking Water Act requires states to report drinking water information periodically to the United
States Environmental Protection Agency (USEPA). This information is maintained in a federal database,
the Safe Drinking Water Information System (SDWIS) Federal Data Warehouse. According to the most
recent data uploaded to the SDWIS, the PRWD has had no recent water quality violations.
There are five individual sampling sites tested as part of the SDWIS monitoring for PCWD:
• Hydrant Lot 5 – Last sampled 10/2013
• Spring 01 – Last sampled 06/2023
• Spring 02 – Last sampled 06/2023
• HARMSCO WTP – No sample data available
• Lead and Copper Sample Sites - No sample data available
No Consumer Confidence Reports are available in the SDWIS for the last five years for the District.
3.2.4.2 CAPACITY
On average, the District supplies approximately 400,000 gallons annually to its 14 customers and provides
backup water supply to three additional customers within the District that are on private wells. Average
daily use for the District is estimated at 1,050 gallons per day (75 gallons per residence per day on
average), with an average peak day demand at 1,400 gallons per day (100 gallons per residence).
The system is operating at approximately 60-80 percent capacity. Thus, the District’s water supply and
infrastructure is sufficient to accommodate full buildout (24 residential lots) of the subdivision.
3.2.4.3 DROUGHT CONTINGENCY PLANNING
In the time since the last MSR/SOI report was prepared for the District, drought conditions throughout
the State have ebbed and flowed leaving some smaller service providers in dire positions. During the 2020-
2022 extreme drought conditions, the District, despite not having a drought contingency plan in place,
had sufficient water supplies to serve its customers.
It is worth noting that during that period the District did maintain informal conversations with the Albion
Mutual Water Company as well as the Albion-Little River Fire Protection District in relation to water
supplies.
Although the District did not report supply deficits during the severe drought of 2021-2022, given the wide
annual variations in available water supply throughout the region and the District’s reliance on
groundwater, it is recommended that the District develop a drought contingency plan to prepare for that
eventuality.
3.2.4.4 NEEDS AND DEFICIENCIES
Based on information within the MSR, the provision of water services to the customers located in the
District’s boundaries appears to be limited. Maintaining the small system is an ongoing challenge and with
such a limited customer base, small number of registered voters, and unknown future system upgrades
or replacement requirements, adequate funds for capital improvements are and will remain a challenge.
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3.3 Determinations
This section presents the required MSR determinations pursuant to GC §56430(a) for the PRWD.
3.3.1 MSR Review Factors
3.3.1.1 GROWTH
Growth and population projections for the affected area
1. The estimated population of the District is 34 residents.
2. The District is limited in growth to buildout of the 24 lots within the Pacific Reefs Subdivision, of which
17 are currently developed.
3. At full buildout of the Subdivision, and at current occupancy rates, the District will have an estimated
population of approximately 48 persons.
3.3.1.2 DISADVANTAGED UNINCORPORATED COMMUNITIES
The location and characteristics of any disadvantaged unincorporated communities within or contiguous
to the sphere of influence
4. The PRWD falls within the County of Mendocino and is not a CDP; therefore, the MHI of its residents
is assumed to approximate the County MHI of $65,520. Because this amount is lower than the
Statewide MHI threshold of $73,240, the District would be considered as located within a DUC under
the typical analysis. However, given the specifics of the Subdivision, which is a gated residential
community of 24 residential lots located immediately on the coastline, it is difficult to characterize
the District as a DUC.
3.3.1.3 CAPACITY OF FACILITIES AND ADEQUACY OF SERVICES
Present and planned capacity of public facilities, adequacy of public services, and infrastructure needs or
deficiencies including needs or deficiencies related to sewers, municipal and industrial water, and
structural fire protection in any disadvantaged unincorporated communities within or contiguous to the
sphere of influence
5. The District’s water sources consist of two springs and one well, which provide adequate water supply
to serve its current and projected population.
6. Construction of a new 30,000-gallon steel tank secured through grant funding ensures adequate
storage facilities for the District.
7. For purposes of depreciation, the most recent annual audit for the District estimates the useful life of
the water system at 15-30 years and general plant assets at 7 years. The District indicates no
infrastructure issues have been identified.
8. According to the most recent data uploaded to the SDWIS, the PRWD has had no recent water quality
violations.
9. The District should develop a capital improvement plan to identify, schedule, and develop funding
strategies to address aging infrastructure needs.
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3.3.1.4 FINANCIAL ABILITY OF AGENCY
Financial ability of agencies to provide services
10. The District has been operating at a net positive and appears to be financially stable. Additionally, an
infusion of grant funding supported construction of a 30,000-gallon water storage tank, which was
the District’s most costly infrastructure upgrade need, identified to date.
11. The District’s primary source of ongoing revenue is from parcel charges and fees; therefore, the
District’s current financial position is dependent upon the continued collection of those parcel charges
and fees. There appears to be insufficient administrative records regarding the establishment of the
Districts parcel charges and fees. It is highly recommended that the District Board confer with their
legal counsel on this matter to ensure that this key revenue source and is secure and the long-term
financial health of the District remains stable.
12. The District should prepare a rate study to identify and plan for infrastructure needs and anticipated
operating costs, and establish appropriate rates in compliance with the Proposition 218 process.
13. The District’s reserves account as of April 2024 totaled $46,283.
3.3.1.5 SHARED SERVICES AND FACILITIES
Status of, and opportunities for, shared facilities
14. The District operates with minimal facilities and no need for facility sharing were identified either by
the District or through this MSR process. However, should the need arise in the future, nearby private
water service providers may provide an opportunity for shared facilities and/or support.
15. The District does not own or lease any administrative facilities.
3.3.1.6 ACCOUNTABILITY, STRUCTURE AND OPERATIONAL EFFICIENCIES
Accountability for community service needs, including governmental structure and operational
efficiencies
16. The District demonstrated accountability and transparency by disclosing financial and service related
information in response to LAFCo requests.
17. The District provides accountability to its constituents through regular quarterly board meetings and
distribution of agendas, notices and meeting records.
18. To promote transparency and accessibility for the public, the District should consider holding its
meetings in a public meeting space.
19. The District should consider posting meeting notices on a public information board such as the Albion
Store bulletin board.
20. In accordance with best practices, the Board should consider establishing staggered terms aligned
with the General Election cycle.
21. The District does not currently maintain a website. However, the District has adopted hardship
resolutions for the past few years due to financial limitations. To continue compliance with SB 929,
the District should either develop and maintain a website or continue to review annually for hardships.
22. The District does not have a written mission statement or established goals and objectives. The
District should consider developing a strategic plan that could help the District improve upon (1)
facility planning efforts, (2) identification of future funding goals and opportunities, and (3)
accountability and transparency.
23. No additional cost avoidance measures have been identified.
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4 SPHERE OF INFLUENCE
LAFCo prepares a Municipal Service Review (MSR) prior to or in conjunction with the Sphere of Influence
(SOI) review process. An SOI study considers whether a change to the SOI, or probable future boundary,
of a local government agency is warranted in order to plan for the logical and orderly development of that
agency in a manner that supports CKH Law and the policies of the Commission. The MSR and required
determinations are presented in Chapters 2 and 3 of this document and form the basis of information and
analysis for this SOI review. This chapter presents the SOI study and required determinations pursuant to
GC §5642(e).
4.1 Mendocino LAFCo Policies
Is addition to making the necessary determinations for establishing or modifying an SOI consistent with
the CKH Act, the appropriateness of an agency’s SOI is also based on an evaluation of consistency with
local LAFCo policies. Sphere of Influence policies can be found in the Mendocino LAFCo Policies and
Procedures Manual adopted November 5, 20187.
10.1.1 Legislative Authority and Intent
A sphere of influence is the probable 20-year growth boundary for a jurisdiction’s physical development.
The Commission shall use spheres of influence to:
a) promote orderly growth and development within and adjacent to communities;
b) promote cooperative planning efforts among cities, the County, and special districts to address
concerns regarding land use and development standards, premature conversion of agriculture
and open space lands, and efficient provision of public services;
c) guide future local government reorganization that encourages efficiency, economy, and orderly
changes in local government; and
d) assist property owners in anticipating the availability of public services in planning for the use of
their property.
10.1.4 Reduced Spheres
The Commission shall endeavor to maintain and expand, as needed, spheres of influence to accommodate
planned and orderly urban development. The Commission shall, however, consider removal of land from
an agency’s sphere of influence if either of the following two conditions apply:
a) the land is outside the affected agency’s jurisdictional boundary but has been within the sphere of
influence for 10 or more years; or
b) the land is inside the affected agency’s jurisdictional boundary but is not expected to be developed
for urban uses or require urban-type services within the next 10 years.
10.1.5 Zero Spheres
LAFCo may adopt a “zero” sphere of influence encompassing no territory for an agency. This occurs if
LAFCo determines that the public service functions of the agency are either nonexistent, no longer
7 Mendocino LAFCo Policies and Procedures Manual can be found here:
https://www.mendolafco.org/files/8e5477867/FINAL+Adopted+Mendo+LAFCo+PP+Manual+2018+upd+12-15-23.pdf.
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needed, or should be reallocated to some other agency (e.g., mergers, consolidations). The local agency
which has been assigned a zero sphere should ultimately be dissolved.
10.1.6 Service Specific Spheres
If territory within the proposed sphere boundary of a local agency does not need all of the services of the
agency, a “service specific” sphere of influence may be designated.
10.1.7 Agriculture and Open Space Lands
Territory not in need of urban services, including open space, agriculture, recreational, rural lands, or
residential rural areas shall not be assigned to an agency’s sphere of influence unless the area’s exclusion
would impede the planned, orderly and efficient development of the area. In addition, LAFCo may adopt
a sphere of influence that excludes territory currently within that agency’s boundaries. This may occur
when LAFCo determines that the territory consists of agricultural lands, open space lands, or agricultural
preserves whose preservation would be jeopardized by inclusion within an agency’s sphere. Exclusion of
these areas from an agency’s sphere of influence indicates that detachment is appropriate.
10.1.8 Annexations Are Not Mandatory
Before territory can be annexed to a city or district, it must be within the agency’s sphere of influence
(G.G. §56375.5). However, territory within an agency’s sphere will not necessarily be annexed. A sphere
is only one of several factors that are considered by LAFCo when evaluating changes of organization or
reorganization.
10.1.9 Islands or Corridors
Sphere of influence boundaries shall not create islands or corridors unless it can be demonstrated that
the irregular boundaries represent the most logical and orderly service area of an agency.
10.1.10 Overlapping Spheres
LAFCo encourages the reduction of overlapping spheres of influence to avoid unnecessary and inefficient
duplication of services or facilities. In deciding which of two or more equally capable agencies shall include
an area within its sphere of influence, LAFCo shall consider the agencies’ service and financial capabilities,
social and economic interdependencies, topographic factors, and the effect that eventual service
extension will have on adjacent agencies. Where an area could be assigned to the sphere of influence of
more than one agency, the following hierarchy typically applies:
a) Inclusion within a city’s sphere
b) Inclusion within a multi-purpose district’s sphere
c) Inclusion within a single-purpose district’s sphere
Territory placed within a city’s sphere indicates that the city is the most logical provider of urban services.
LAFCo encourages annexation of developing territory (i.e., area not currently receiving services) that is
currently within a city’s sphere to that city rather than to one or more single-purpose special districts.
LAFCo discourages the formation of special districts within a city’s sphere. To promote efficient and
coordinated planning among the county’s various agencies, districts that provide the same type of service
shall not have overlapping spheres.
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10.1.11 Memorandum of Agreements (For City Sphere Amendments and Updates)
Prior to submitting an application to LAFCo for a new city sphere of influence or a city sphere of influence
update, the city shall meet with the County to discuss the proposed new boundaries of the sphere and
explore methods to reach agreement on development standards and planning and zoning requirements
as contained in GC §56425. If an agreement is reached between the city and County the agreement shall
be forwarded to LAFCo. The Commission shall consider and adopt a sphere of influence for the city
consistent with the policies adopted by LAFCo and the County, and LAFCo shall give great weight to the
agreement to the extent that it is consistent with LAFCo policies in its final determination of the city
sphere.
10.1.12 Areas of Interest
LAFCo may, at its discretion, designate a geographic area beyond the sphere of influence as an Area of
Interest to any local agency.
a) An Area of Interest is a geographic area beyond the sphere of influence in which land use decisions or
other governmental actions of one local agency (the "Acting Agency") impact directly or indirectly
upon another local agency (the "Interested Agency"). For example, approval of a housing project
developed to urban densities on septic tanks outside the city limits of a city and its sphere of influence
may result in the city being forced subsequently to extend sewer services to the area to deal with
septic failures and improve city roads that provide access to the development. The city in such a
situation would be the Interested Agency with appropriate reason to request special consideration
from the Acting Agency in considering projects adjacent to the city.
b) When LAFCo receives notice of a proposal from another agency relating to the Area of Concern, LAFCo
will notify the Interested Agency and will consider its comments.
c) LAFCo will encourage Acting and Interested Agencies to establish Joint Powers Agreements or other
commitments as appropriate.
4.2 Existing Sphere of Influence
The District’s SOI was first adopted in August 1994 (LAFCo Resolution No. 94-4) and confirmed in
November 2015 (LAFCo Resolution No. 15-16-06). The SOI is coterminous with its boundary, meaning the
same, and coterminous with the Pacific Reefs Subdivision boundaries. The District was formed solely to
provide water services to the Pacific Reefs Subdivision, with no potential for expansion. The District does
not provide any services outside its boundaries. Further, due to the physical limitations of the area (i.e.,
its location on an isolated seaside bluff between Highway 1 and the Pacific Ocean) the provision of services
beyond its boundaries is not readily feasible.
4.2.1 Study Areas
Study areas are unique to a specific agency and are used to define the extent of one or more locations for
SOI analysis purposes. Study areas may be created at different levels of scope and/or specificity based on
the circumstances involved. The following descriptions demonstrate the array of scenarios that may be
captured by a SOI study area.
• An area with clear geographic boundaries and scope of service needs based on years of interagency
collaboration or public engagement and a project ready for grant funding or implementation.
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• An area involving broader community regions or existing residential subdivisions with a large or long-
term vision in need of fostering and/or establishing interagency partnerships.
• An area in early stages of conception that is not currently geographically well-defined and generally
involves one or more ideas identified by agency or community leaders needing further definition.
• An area geographically defined by a gap between the boundaries of existing public service providers.
• An area adjacent to an existing agency’s boundary slated for development needing urban services.
Study areas can result in a proposed SOI or sphere expansion area or the designation of an Area of Interest
to earmark areas for enhanced interagency coordination or for future SOI consideration.
There are no study areas in or immediately surrounding the PRWD.
4.2.2 Area of Interest Designation
LAFCo’s Area of Interest Policy, per Section 10.1.12, provides for the designation or identification of
unincorporated areas located near to, but outside the jurisdictional boundary and established SOI of a city
or district, in which land use decisions or other governmental actions of another local agency directly or
indirectly impact the subject local agency.
An Area of Interest (AOI) designation serves as a compromise approach that recognizes situations
involving challenging boundary or municipal service delivery considerations, or for which urbanization
may be anticipated in the intermediate or long-range planning horizons. It is a tool intended to enhance
communication and coordination between local agencies.
An AOI designation is most helpful when the county and city or district can reach agreement that
development plans related to LAFCo designated AOI will be treated the same as if these areas were within
the city or district SOI boundary, particularly regarding notification to and consideration of input from the
city or district.
No AOIs have been identified for the PRWD.
4.3 Proposed Sphere of Influence
There are no proposed changes to the SOI with this Update. The District and LAFCo staff recommend the
Commission affirm the existing coterminous sphere.
4.4 Consistency with LAFCo Policies
Mendocino LAFCo has established local policies to implement its duties and mandates under the Cortese-
Knox-Hertzberg Act. This section identifies potential inconsistencies between the proposed SOI and local
LAFCo policies.
The proposed District SOI is consistent with Mendocino LAFCo Policies (refer to Section 4.1 for the specific
SOI policies).
4.5 Determinations
In determining the SOI for an agency, LAFCo must consider and prepare written determinations with
respect to five factors as outlined in GC §56425(e). These factors are as follows:
1. The present and planned land uses in the area, including agricultural and open space lands;
2. The present and probable need for public facilities and services in the area;
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3. The present capacity of public facilities and adequacy of public services that the agency provides
or is authorized to provide;
4. The existence of any social or economic communities of interest in the area if the Commission
determines that they are relevant to the agency; and
5. The present and probable need for public facilities and services (including sewers, municipal and
industrial water, or structural fire protection) of any disadvantaged unincorporated communities
within the existing Sphere of Influence.
LAFCo staff propose no change to the existing SOI for the District and recommend the Commission
approve the SOI determinations as presented below.
4.5.1 Present and planned land uses
The entirety of the District is located just south of the Albion community in coastal unincorporated
Mendocino County. The primary uses of the coastal zone are rural residential uses and agricultural. Future
development in the District is limited to buildout of the remaining seven residential lots within the
subdivision. Based on population projections for the County, it is likely buildout of the residential parcels
will not occur until well beyond the planning horizon of this document. Based on the District’s location in
the coastal zone, the area is subject to additional development regulations, and land use changes in the
area must be approved by both the County and Coastal Commission.
4.5.2 Present and probable need for facilities and services in the area
The District provides water services to a 14 residential connections and provides secondary backup water
supply to 3 additional connections within the District that are on private wells; there are a total of 34
customers. The service area is limited to the boundaries of the Pacific Reefs Subdivision located
immediately west of State Highway 1. The District anticipates little growth in resident population within
the near term (five years) and long-term planning horizon (20 years). Given that the PRWD is limited to
the residential properties in the Pacific Reefs Subdivision, and there are only seven undeveloped lots
within the subdivision for full build out, it is anticipated the District can accommodate future
development. Further, the projected population decline of 2.7 percent throughout the County suggests
that buildout of the residential parcels will likely not occur until well beyond the planning horizon of this
document.
4.5.3 The present capacity of public facilities and adequacy of public services that the agency
provides or is authorized to provide
The District provides water services to a 14 residential connections and provides secondary backup water
supply to 3 additional connections within the District that utilize private wells as their primary source. The
District owns a small parcel less than an acre in size, which is the location of its springs and well, water
storage tanks and pumphouse facilities. The distribution system consists of graduated water lines from
the water tanks to each of the 24 lots within the subdivision. The distribution system consists of
approximately 2,000 feet of 3-inch and 4-inch supply lines. The District is nearing completion on
construction of a new 30,000-gallon steel storage tank and also maintains two 5,000 gallon plastic tanks
for storage. The water storage is sufficient to provide year round reliable water supply for customers.
Operations and maintenance are performed by a part-time Water Master under contract who provides
their own tools for maintenance purposes and contracts with local contractors to do larger repairs and
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maintenance. Average daily use for the District is estimated at 1,050 gpd (75 gallons per residence per
day on average), with an average peak day demand at 1,400 gpd (100 gallons per residence). The system
is operating at approximately 60-80 percent capacity. Thus, the District’s water supply and infrastructure
is sufficient to accommodate full buildout (24 residential lots) of the subdivision.
4.5.4 The existence of any social or economic communities of interest in the area if the
Commission determines that they are relevant to the agency
The District is located within the unincorporated coastal zone of Mendocino County just south of the
Albion CDP. Most of the coastal zone is made up of rural uses and is geographically isolated from other
communities. Given its isolated location and financial standing, no additional communities of interest
have been identified for the District.
4.5.5 The present and probable need for public facilities and services of any disadvantaged
unincorporated communities
The District is located within the County of Mendocino and is not a CDP, the MHI of its residents is assumed
to approximate the County MHI of $65,520. Because this amount is lower than the Statewide MHI
threshold of $73,240, t the District would be considered as located within a DUC under the typical analysis.
However, given the specifics of the Subdivision, which is a gated residential community of 24 residential
lots located immediately on the coastline, it is difficult to quantify the District as a DUC.
Residents of the Pacific Reefs Subdivision are currently receiving the essential municipal services of fire
and water at adequate service levels. Wastewater is provided by private on-site septic systems, which are
regulated by the County Department of Environmental Health.
4.6 Recommendation
Pursuant to California Water Code §3540 et seq., and GOV 56425(i), the Commission does hereby
establish the functions and classes of services provided by the PRWD as limited to providing water
services. Based upon the information contained in this report, it is recommended that the District Service
Area Boundary and SOI remain unchanged and coterminous.
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
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REFERENCES 5-1
5 REFERENCES
CALAFCO, 2023. CALAFCO Statewide DUC Map Tool. [Online] Available at:
https://www.arcgis.com/apps/View/index.html?appid=4319a8066745442cbe7de6af1d13f98a.
Accessed September 20, 2023.
Caltrans, 2021. Mendocino County Economic Forecast. [Online] Available at: https://dot.ca.gov/-
/media/dot-media/programs/transportation-planning/documents/data-analytics-
services/transportation-economics/socioeconomic-forecasts/2021/2021-pdf/mendocino-
profile-a11y.pdf. Accessed August 31, 2022.
CSDA, 2013. Proposition 218 Guide for Special Districts. [Online] Available at:
https://www.waterboards.ca.gov/waterrights/water_issues/programs/drought/pricing/docs/cs
da_guide_proposition_218.pdf. Accessed April 29, 2024.
Cutler, 2023. Personal communications from Robert Cutler, PRWD Board President. November 27, 2023.
Department of Finance (DOF), 2021. Report P-2A California and County Population Projections, 2010-
2060 (2019 Baseline). [Online] Available at:
https://dof.ca.gov/Forecasting/Demographics/projections/
---, 2022. Press Release: Slowing Population Decline Puts Latest Population at 39,185,000. [Online]
https://dof.ca.gov/wp-content/uploads/Forecasting/Demographics/Documents/E-
1_2022PressRelease.pdf. May 2, 2022. Accessed August 31, 2022.
Mendocino County, 2021a. Mendocino County General Plan, Coastal Element. [Online] Available at:
https://www.mendocinocounty.gov/government/planning-building-services/plans/mendocino-
county-general-plan. Accessed April 23, 2024.
---, 2021b. Mendocino County General Plan Development Element. [Online] Available at:
https://www.mendocinocounty.org/home/showpublisheddocument/43488/637587674672130
000. Accessed May 26, 2022.
---, 2021c. Mendocino County General Plan Resource Element. [Online] Available at:
https://www.mendocinocounty.org/home/showpublisheddocument/43490/637587675329030
000. Accessed May 26, 2022.
---, 2022. Mendocino County Proposition 4 Gann Limit Calculations FY 2019-20 through FY 2022-23.
September 20, 2023. [Online] Available at:
https://www.mendocinocounty.org/home/showpublisheddocument/51899/637928935339470000
Mendocino Local Agency Formation Commission (LAFCo), 2014. Municipal Service Review of Water and
Wastewater Service Providers. [Online] Available at:
https://www.mendolafco.org/files/e406888a5/2014+Water+and+Wastewater+MSR_+Full+Doc.
pdf. Accessed September 20, 2023.
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
Influence Update
REFERENCES 5-2
___, 2015. Pacific Reefs Water District Sphere of Influence Update. [Online] Available at:
https://www.mendolafco.org/files/903eedc44/Pacific+Reefs+WD+SOI+Update+Adopted+11-2-
15+w+Reso.pdf. Accessed September 20, 2023.
North Coast Resource Partnership (NCRP), 2023. Proposition 1 IRWM Round 1, Pacific Reefs Water
District Water Tank Replacement Project. [Online]. Available at:
https://www.northcoastresourcepartnershipprojects.org/Project/Detail/14090. Accessed
December 18, 2023.
Pacific Reefs Water District (PRWD), 1996. Bylaws of the Pacific Reefs Water District. February 24, 1996.
PMC, 2008. County of Mendocino General Plan Update Draft Environmental Impact Report, Section 4.9:
Land Use. Prepared for County of Mendocino. September 2008.
State Water Resources Control Board, Division of Drinking Water (SWRCB), 2023a. Albion Mutual Water
Company. [Online]. Available at:
https://sdwis.waterboards.ca.gov/PDWW/JSP/WaterSystemDetail.jsp?tinwsys_is_number=2865
&tinwsys_st_code=CA. Accessed September 17, 2023.
---, 2023b. Pacific Reefs Water District. [Online]. Available at:
https://sdwis.waterboards.ca.gov/PDWW/JSP/WaterSystemDetail.jsp?tinwsys_is_number=3007
&tinwsys_st_code=CA. Accessed September 17, 2023.
---, 2023c. Safe and Affordable Funding for Equity and Resilience (SAFER). [Online}. Available at:
https://www.waterboards.ca.gov/drinking_water/certlic/drinkingwater/waterpartnership.html.
Accessed September 17, 2023.
U.S. Census Bureau (USCB). 2023. American Community Survey. Profile of Census Tract 110.01. [Online].
Available at:
https://data.census.gov/profile/Census_Tract_110.01,_Mendocino_County,_California?g=14000
00US06045011001. Accessed August 16, 2022.
U.S. Census Bureau (USCB). 2023a. US Census: California Hard-to-Count Index Map:
https://cacensus.maps.arcgis.com/apps/webappviewer/index.html?id=48be59de0ba94a3dacff1
c9116df8b37. Accessed August 16, 2022.
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
Influence Update
ACRONYMS 6-1
6 ACRONYMS
AB Assembly Bill
ACS American Census Survey
ADU Accessory Dwelling Unit
AMWC Albion Mutual Water Company
AOI Area of Interest
APR Annual Progress Report
CDP Census Designated Place
CEQA California Environmental Quality Act
CIP Capital Improvement Plan
CKH Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000
CPA Certified Public Accountant
DDW Division of Drinking Water
DOF Department of Finance
DUC Disadvantaged Unincorporated Community
DWR Department of Water Resources
FY Fiscal Year
GC Government Code
GHG Greenhouse gas emissions
GPD Gallons per day
GPM Gallons per minute
HCD Housing and Community Development
IRWM Integrated Regional Water Management
JADU Junior Accessory Dwelling Uni
JPA Joint Powers Authority
LAFCo Local Agency Formation Commission
MHI Median Household Income
MPO Metropolitan planning organization
MSR Municipal Service Review
MWC Mutual Water Company
NCRP North Coast Resource Partnership (IRWM)
OIR Operating Indirect Rate
OPR Office of Planning and Research
PRWD Pacific Reefs Water District
RHNA Regional housing need allocations
SB Senate Bill
SDUC Severely Disadvantaged Unincorporated Community
SDRMA Special District Risk Management Association
SDWIS Safe Drinking Water Information System
SOI Sphere of Influence
SWB State Water Board
SWRCB State Water Resources Control Board
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
Influence Update
ACKNOWLEDGEMENTS 7-1
7 ACKNOWLEDGEMENTS
7.1 Report Preparation
This Municipal Service Review and Sphere of Influence Update was prepared by Hinman & Associates
Consulting, Inc., contracted staff for Mendocino LAFCo.
Uma Hinman, Executive Officer
Spencer Richard, Analyst
7.2 Assistance and Support
This Municipal Service Review and Sphere of Influence Update could not have been completed without
the assistance and support from the following organizations and individuals.
Pacific Reefs Water District Robert Cutler, Board President
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
Influence Update
APPENDICES 8-1
8 APPENDICES
8.1 Appendix A – Open Government Resources
The purpose of this appendix is to provide a brief list of some educational resources for local agencies
interested in learning more about the broad scope of public interest laws geared towards government
transparency and accountability. This appendix is not intended to be a comprehensive reference list or to
substitute legal advice from a qualified attorney. Feel free to contact the Mendocino LAFCo office at (707)
463-4470 to make suggestions of additional resources that could be added to this appendix.
The websites listed below provide information regarding the following open government laws: (1) Public
Records Act (Government Code §6250 et seq.), (2) Political Reform Act – Conflict-of-Interest regulations
(Government Code §81000 et seq.), (3) Ethics Principles and Training (AB 1234 and Government Code
§53235), (4) Brown Act – Open Meeting regulations (Government Code §54950 et seq.), and (5) Online
Compliance regulations (Section 508 of the US Rehabilitation Act and Government Code §11135).
o Refer to the State of California Attorney General website for information regarding public access
to governmental information and processes at the following link: https://oag.ca.gov/government.
o Refer to the State of California Attorney General website for information regarding Ethics Training
Courses required pursuant to AB 1234 at the following link: https://oag.ca.gov/ethics.
o The Fair Political Practices Commission (FPPC) is primarily responsible for administering and
enforcing the Political Reform Act. The website for the Fair Political Practices Commission is
available at the following link: http://www.fppc.ca.gov/.
o Refer to the California Department of Rehabilitation website for information regarding Section
508 of the US Rehabilitation Act and other laws that address digital accessibility at the following
link: http://www.dor.ca.gov/DisabilityAccessInfo/What-are-the-Laws-that-Cover-Digital-
Accessibility.html.
o Refer to the Institute for Local Government (ILG) website to download the Good Governance
Checklist form at the following link: www.ca-ilg.org/post/good-governance-checklist-good-and-
better-practices.
o Refer to the Institute for Local Government (ILG) website to download the Ethics Law Principles
for Public Servants pamphlet at the following link: www.ca-ilg.org/node/3369.
o Refer to the Institute for Local Government (ILG) website for information regarding Ethics Training
Courses required pursuant to AB 1234 at the following link: http://www.ca-ilg.org/ethics-
education-ab-1234-training.
o Refer to the California Special Districts Association (CSDA) website for information regarding
online and website compliance webinars at the following link:
http://www.csda.net/tag/webinars/.
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
Influence Update
APPENDICES 8-2
8.2 Appendix B – Website Compliance Handout
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
Influence Update
California Website
Compliance Checklist
Use this checklist to keep your district's website compliant with
State and Federal requirements.
Public Records Act
SB 929 SB 272 AB 2853 (optional):
Our district has created and Our Enterprise System Catalog is We post public records to our
maintains a website posted on our website website
Passed in 2018, all independent special All local agencies must publish a catalog This bill allows you to refer PRA requests
districts must have a website that listing all software that meets specific to your site, if the content is displayed
includes contact information (and all requirements—free tool at getstream- there, potentially saving time, money,
other requirements) by Jan. 2020 line.com/sb272 and trees
The Brown Act State Controller Reports
AB 392: AB 2257: Financial Transaction Report: Compensation Report:
Agendas are posted to A link to the most recent A link to the Controller’s A link to the Controller’s
our website at least 72 agenda is on our home “By the Numbers” PublicPay website is
hours in advance of page, and agendas are website is posted on posted in a conspicuous
regular meetings, 24 searchable, machine- location on our website
our website
hours in advance of readable and platform
Report must be submitted by
special meetings independent Report must be submitted
April 30 of each year—you
within seven months after the
This 2011 update to the Act, Required by Jan. 2019— close of the fiscal year—you can also add the report to
originally created in 1953, text-based PDFs meet this can add the report to your your site annually, but
added the online posting requirement, Microsoft Word site annually, but posting a posting a link is easier
requirement docs do not link is easier
Healthcare District Section 508 ADA
Websites Open Data Compliance
AB 2019: AB 169: CA gov code 7405:
If we’re a healthcare district, we Anything posted on our website State governmental entities
maintain a website that includes that we call “open data” meets the shall comply with the accessibility
all items above, plus additional requirements for open data requirements of Section 508
requirements of the federal Rehabilitation Act
Defined as “retrievable, downloadable,
of 1973
Including budget, board members, indexable, and electronically searchable;
Municipal Service Review, grant policy platform independent and machine Requirements were updated in 2018—if
and recipients, and audits readable” among other things you aren't sure, you can test your site for
accessibility at achecker.ca
Website compliance made easy
csda.net getstreamline.com
The Brown Act: new agenda requirements
Tips for complying with AB 2257 by January, 2019
Placement:
What it says: An online posting of an agenda shall be posted on the primary Internet Web site
homepage of a city, county, city and county, special district, school district, or political subdivision
established by the state that is accessible through a prominent, direct link to the current agenda.
What that means: Add a link to the current agenda directly to your homepage. It cannot be in a
menu item or otherwise require more than a single click to open the agenda.
Exception:
What it says: A link to the agenda management platform may be added to the home page instead of a
link directly to the current agenda, if the agency uses an integrated agenda management platform that
meets specified requirements, including, among others, that the current agenda is the first agenda
available at the top of the integrated agenda management platform.
What that means: If you use an agenda management system, you may add a link to that system
directly to your homepage (again, not in a menu item), if the format of the agenda meets the
requirements below, and if the current agenda is the first at the top of the list.
Format:
What it says: [agenda must be] Retrievable, downloadable, indexable, and electronically searchable by
commonly used Internet search applications. Platform independent and machine readable. Available
to the public free of charge and without any restriction that would impede the reuse or redistribution of
the agenda.
What that means: You cannot add Word Docs or scanned (image-based) PDFs of your agenda to your
website–Word Docs are not platform independent (the visitor must have Word to read the file), and
scanned PDFs are not searchable. Instead, keep your agenda separate from the packet and follow
these steps:
1. From Word or other document system: Export agenda to PDF
2. Add that agenda to your website (or to your agenda management system), and include a link to
that agenda on your homepage
3. Then, you can print the agenda, add it to your pile of documents for the packet, and scan that
to PDF - just keep the packet separate from the agenda (only the agenda must meet AB 2257)
4. Keep the link on the homepage until the next agenda is available, then update the link
Questions? Contact sloane@getstreamline.com or dillong@csda.net
APPENDICES 8-3
8.3 Appendix C – Housing Legislation Trends and Results
Mendocino County and ADUs
In response to State legislation aimed at encouraging affordable housing, the County of Mendocino has
taken a number of steps to facilitate ADU construction and operation in an attempt to address the local
housing crisis. The County adopted an ADU ordinance, which outlines specific development standards.
Further, a General Plan update was adopted on 2021 that amended the Coastal Zoning Code component
of the Local Coastal Plan to establish and revise standards for ADUs in the Coastal Zone.
Because Pacific Reefs is located in the Coastal Zone of the County it is subject to coastal-specific ADU
regulations. The number of permitted ADUs within the Coastal Zone of Mendocino County (excluding the
Gualala Town Plan area) is limited to 500 units. Junior Accessory Dwelling Units (JADU), which are
accessory structures typically limited to 500 square feet in an existing space, are exempt from this cap.
Any change to the cap on the number of ADUs requires a Local Coastal Program amendment.
Per County Municipal Code Section 20.458.040 – Public Health and Safety Requirements, both an
adequate water supply and sewage capacity must be available to serve the proposed new residence as
well as existing residences on the property. Most notably, if the property is located in a service district,
the property owner must provide written approval from the service district specifically authorizing the
connection of the ADU.
With respect to coastal resource protections, ADUs and JADUs are subject to additional requirements that
impact the viability of their development (County Municipal Code Section 20.458.045).
The Larger Picture
As for how ADUs fit into the larger picture of the Mendocino County population trends, the housing data
provided in the County’s General Plan Annual Progress Report (APR) provides a reliable snapshot.
Required by the Governor’s Office of Planning and Research (OPR) and the State’s Department of Housing
and Community Development (HCD), every jurisdiction is required to provide an annual report detailing
the progress made towards implementing their housing element and meeting their RHNA allocations.
The data provided in the most recent APR for Unincorporated Mendocino County (adopted June 6TH, 2023
by the Board of Supervisors) suggests that despite strict development regulations in some places, ADUs
are certainly a factor in local housing development trends. Out of the 143 housing development
applications received in the 2022 reporting year, 38 were for ADUs; in 2021 a total of 102 housing
development applications were received, of which 35 were for ADUs. The number of ADUs compared to
single-family home applications suggests that there could continue to be some limited development of
ADUs throughout the unincorporated areas of the County. This type of development could very slightly
increase demand for water services provided by PRWD. However, any new development requires written
approval from the service provider to authorize services, providing the District the opportunity to limit
development if capacity is not available.
Regional Housing Needs Allocation (RHNA)
It is worth noting that in response to statutory requirements, policy direction from the HCD, and
mandated deadlines for delivery of housing need allocation numbers to local jurisdictions within
Mendocino County, the MCOG adopted a Regional Housing Needs Plan in 2018.
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
Influence Update
APPENDICES 8-4
Although MCOG does not typically involve themselves in housing issues, they have been designated by
HCD as the appropriate regional agency to coordinate the housing need allocation process. The political
jurisdictions that comprise the region consist of the Mendocino County unincorporated area and the cities
of Ukiah, Fort Bragg, Willits and Point Arena.
The Regional Housing Needs Plan went through numerous iterations prior to being adopted, which took
into account different allocation factors for the methodology. Throughout the process, each member
jurisdiction provided statements of constraints to HCD that detailed the land-constraints that challenge
residential development in unincorporated Mendocino County. Water resources and availability was cited
by multiple MCOG member jurisdictions as a constraint and contributed to the adjustments made by the
State on the region’s required housing allocations.
The RHNA allocations for Unincorporated Mendocino County are projected for a planning period between
8/15/2019 and 8/17/2027. Since adopting the Regional Housing Needs Plan in 2018, the County has made
progress across all income levels; the number of housing units developed and how many remain with
respect towards its RHNA allocation are detailed below, broken down by income level and deed restricted
versus non-deed restricted.
Table 8-1: Mendocino County RHNA Allocations
Projection Total
Total
RHNA Period - Units to
Income Level 2019 2020 2021 2022 Remaining
Allocation 01/01/2019- Date (All
RHNA
08/14/2019 Years)
Deed
-- -- 39 -- 21
Restricted
Very Low 291 125 166
Non-Deed
-- -- -- 65 --
Restricted
Deed
-- -- -- -- --
Restricted
Low 179 21 158
Non-Deed
-- - -- 21
Restricted
Deed
-- -- -- -- --
Restricted
Moderate 177 156 21
Non-Deed
4 -- -- -- --
Restricted
Above
702 46 40 67 51 58 262 440
Moderate
Total RHNA 1,349
Total Units 50 60 149 186 119 564 785
Extremely
Low-Income 145 15 26 21 62 83
Units*
*Progress toward extremely low-income housing need, as determined pursuant to Government Code
65583(a)(1).
(HCD, 2023)
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
Influence Update
APPENDICES 8-5
With respect to how RHNA requirements may affect PRWD, the State continues to push for more housing
across the state including in communities located on the coast such as Albion and the Pacific Reefs
Subdivision. While these coastal communities are subject to additional regulation and governing bodies
(i.e. the Coastal Commission), housing mandates can affect these areas similar to inland communities.
While there are few undeveloped lots in the Pacific Reefs Subdivision, evolving legislation could allow for
increased development potential that supports the State’s housing goals.
Additional Recent State Housing Legislation
In addition to the Legislature’s concerted effort to progress ADU development statewide, there have been
numerous other housing bills passed in recent years aimed at addressing the housing affordability crisis.
• SB9 - Authorizes a property owner to split a single-family lot into two lots and place up to two
units on each new lot. Therefore, the bill permits up to four units on properties currently limited
to single-family houses. SB 9 also mandates that local agencies approve development projects
that meet specified size and design standards.
• SB10 - Establishes a process for local governments to increase the density of parcels in transit-rich
areas or on urban infill sites to up to 10 residential units per parcel. Such an ordinance must be
adopted between Jan. 1, 2021, and Jan. 1, 2029, and is exempt from CEQA.
• SB35 - Applies in cities that are not meeting their Regional Housing Need Allocation (RHNA) goal
for construction of above-moderate income housing and/or housing for households below 80%
area median income (AMI). SB-35 amends Government Code Section 65913.4 to require local
entities to streamline the approval of certain housing projects by providing a ministerial approval
process.
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
Influence Update
APPENDICES 8-6
8.4 Appendix D – District Financial Audits
Pacific Reefs Water District | 2024 Municipal Service Review and Sphere of
Influence Update