LAFCO
Irish Beach Water District, 2025
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Photo Credit: Michael Rymer
Irish Beach Water District
2025 Municipal Service Review and Sphere of
Influence Update
Prepared By: Workshop: November 4, 2024
Mendocino LAFCo Public Hearing: March 3, 2025
200 South School Street
Adopted: March 3, 2025
Ukiah, California 95482
LAFCo Resolution No: 2024-25-09
http://www.mendolafco.org/
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Resolution No. 2024-25-09
of the Mendocino Local Agency Formation Commission
Approving the
Irish Beach Water District
Municipal Service Review and Sphere of Influence Update 2025
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 Irish
Beach Water District, hereinafter referred to as the “IBWD 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 November 4, 2024 to receive 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 March 3, 2025; 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 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 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
LAFCo Resolution No. 2024-25-09 03-03-2025
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Sphere of Influence Roads
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TABLE OF CONTENTS
LIST OF FIGURES ............................................................................................................................................ 3
LIST OF TABLES .............................................................................................................................................. 3
ACRONYMS ................................................................................................................................................... 5
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 Senate Bill 215 .......................................................................................................................... 1-3
2 AGENCY OVERVIEW ........................................................................................................................... 2-1
2.1 History ...................................................................................................................................... 2-1
2.1.1 Formation ............................................................................................................................. 2-1
2.1.2 Boundary .............................................................................................................................. 2-1
2.1.2.1 Boundary Change History ............................................................................................ 2-1
2.1.3 Services ................................................................................................................................. 2-2
2.1.4 Latent Powers....................................................................................................................... 2-2
2.2 Government Structure.............................................................................................................. 2-6
2.2.1 Governing Body .................................................................................................................... 2-6
2.2.2 Public Meetings .................................................................................................................... 2-7
2.2.3 Standing Committees ........................................................................................................... 2-7
2.2.4 Public Outreach .................................................................................................................... 2-7
2.2.5 Complaints ........................................................................................................................... 2-7
2.2.6 Transparency and Accountability ......................................................................................... 2-7
2.3 Operational Structure ............................................................................................................... 2-8
2.3.1 Management and Staffing .................................................................................................... 2-8
2.3.1.1 Contract Staffing and Services ..................................................................................... 2-9
2.3.2 Agency Performance .......................................................................................................... 2-10
2.3.2.1 Challenges .................................................................................................................. 2-10
2.3.2.2 Distinguished Services ............................................................................................... 2-10
2.3.2.3 Strategic or Succession Planning ............................................................................... 2-11
2.3.3 Regional and Service Specific Collaboration ...................................................................... 2-11
2.3.4 Shared Service Delivery ...................................................................................................... 2-11
2.3.4.1 Adjacent Providers ..................................................................................................... 2-11
2.3.4.2 Shared Services and Facilities .................................................................................... 2-14
2.3.4.3 Duplication of Services .............................................................................................. 2-14
2.3.4.4 Interagency Collaboration ......................................................................................... 2-14
2.3.4.5 Regional and Service-Specific Participation ............................................................... 2-14
2.3.5 Government Structure and Community Needs ................................................................. 2-14
2.3.5.1 Enhanced Service Delivery Options ........................................................................... 2-14
2.3.5.2 Government Restructure Options ............................................................................. 2-15
2.4 Finances .................................................................................................................................. 2-15
2.4.1 Current Fiscal Health .......................................................................................................... 2-15
2.4.1.1 Revenues and Expenditures ...................................................................................... 2-16
2.4.1.2 Assets and Liabilities .................................................................................................. 2-17
2.4.1.3 Net Position ............................................................................................................... 2-17
2.4.2 Long Term Financial Considerations .................................................................................. 2-17
2.4.2.1 Reserves ..................................................................................................................... 2-17
2.4.2.2 Outstanding Debt/Cost Avoidance ............................................................................ 2-17
2.4.2.3 Rate Restructuring ..................................................................................................... 2-18
2.4.2.4 Capital Improvement Plan ......................................................................................... 2-19
2.5 Growth .................................................................................................................................... 2-20
2.5.1 History ................................................................................................................................ 2-20
2.5.2 Present and Planned Land Use and Development ............................................................. 2-20
2.5.2.1 Land Use .................................................................................................................... 2-20
2.5.2.2 Development ............................................................................................................. 2-23
2.5.3 Existing Population ............................................................................................................. 2-23
2.5.4 Projected Growth ............................................................................................................... 2-23
2.5.5 California Housing Goals .................................................................................................... 2-23
2.6 Disadvantaged Unincorporated Communities ....................................................................... 2-24
3 MUNICIPAL SERVICES ......................................................................................................................... 3-1
3.1 Service Overview ...................................................................................................................... 3-1
3.1.1 Services ................................................................................................................................. 3-1
3.1.2 Service Areas ........................................................................................................................ 3-1
3.1.3 Outside Agency Services ...................................................................................................... 3-1
3.2 Water ........................................................................................................................................ 3-1
3.2.1 Service Overview .................................................................................................................. 3-1
3.2.2 Service Adequacy ................................................................................................................. 3-2
3.2.2.1 Water Demand and Capacity ....................................................................................... 3-3
3.2.2.2 Drought Contingency Planning .................................................................................... 3-4
3.2.2.3 Regulatory Permits and Compliance History ............................................................... 3-5
3.2.2.4 Needs and Deficiencies ................................................................................................ 3-6
3.2.3 Facilities and Assets.............................................................................................................. 3-6
3.2.3.1 System History ............................................................................................................. 3-8
3.2.3.2 System Improvements ................................................................................................. 3-9
3.2.3.3 Engineering Reports .................................................................................................. 3-10
3.3 Wastewater Services .............................................................................................................. 3-12
3.3.1 Service Overview ................................................................................................................ 3-12
3.3.2 Service Adequacy ............................................................................................................... 3-12
3.3.3 Facilities and Assets............................................................................................................ 3-12
3.3.3.1 System History ........................................................................................................... 3-12
3.3.3.2 System Improvements ............................................................................................... 3-13
3.3.3.3 Engineering Reports .................................................................................................. 3-13
3.4 Determinations ....................................................................................................................... 3-13
3.4.1 MSR Review Factors ........................................................................................................... 3-13
3.4.1.1 Growth ....................................................................................................................... 3-13
3.4.1.2 Disadvantaged Unincorporated Communities .......................................................... 3-14
3.4.1.3 Capacity of Facilities and Adequacy of Services ........................................................ 3-14
3.4.1.4 Financial Ability of Agency ......................................................................................... 3-15
3.4.1.5 Shared Services and Facilities .................................................................................... 3-16
3.4.1.6 Accountability, Structure and Operational Efficiencies ............................................. 3-16
3.4.1.7 Other Service Delivery Matters ................................................................................. 3-17
4 SPHERE OF INFLUENCE....................................................................................................................... 4-1
4.1 Mendocino LAFCo Policies ........................................................................................................ 4-1
4.2 Existing Sphere of Influence ..................................................................................................... 4-4
4.2.1 Study Areas .......................................................................................................................... 4-4
4.2.2 Area of Interest Designation ................................................................................................ 4-5
4.3 Proposed Sphere of Influence .................................................................................................. 4-5
4.4 Consistency with LAFCo Policies ............................................................................................... 4-5
4.5 Determinations ......................................................................................................................... 4-5
4.5.1 Present and planned Land Uses ........................................................................................... 4-6
4.5.2 Present and probable need for facilities and services in this area ...................................... 4-6
4.5.3 The present capacity of public facilities and adequacy of public services that the agency
provides or is authorized to provide .................................................................................................. 4-6
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 ......................................................... 4-7
4.5.5 The present and probable need for public facilities and services of any disadvantaged
unincorporated communities ............................................................................................................ 4-7
4.6 Recommendation ..................................................................................................................... 4-7
5 REFERENCES ....................................................................................................................................... 5-1
6 ACKNOWLEDGEMENTS ...................................................................................................................... 6-1
6.1 Report Preparation ................................................................................................................... 6-1
6.2 Assistance and Support ............................................................................................................ 6-1
7 APPENDICES ....................................................................................................................................... 7-1
7.1 Appendix A – Open Government Resources ............................................................................ 7-1
7.2 Appendix B – Website Compliance Handout ............................................................................ 7-2
7.3 Appendix C – Housing Legislation Trends and Results ............................................................. 7-3
7.4 Appendix D – District Financial Audits ...................................................................................... 7-6
LIST OF FIGURES
Figure 2-1: Irish Beach Water District Boundary ....................................................................................... 2-4
Figure 2-2: Mendocino County Water and Sanitation Districts and Companies ....................................... 2-5
Figure 2-3: IBWD Organization Chart ......................................................................................................... 2-9
Figure 2-4: Adjacent Private Water Service Providers ............................................................................. 2-13
Figure 2-5: Mendocino County General Plan Land Use Map ................................................................... 2-21
Figure 2-6: Mendocino County Zoning Map ............................................................................................ 2-22
Figure 3-1: Distribution and Transmission Pipelines By Age, 2014 ............................................................ 3-7
Figure 3-2: IBWD Well Activation and Tank Replacement Project Locations ............................................ 3-8
Figure 3-3: IBWD Facilities ....................................................................................................................... 3-13
LIST OF TABLES
Table 1-1: Current Mendocino LAFCO Commissioners, 2025 .................................................................... 1-1
Table 2-1: IBWD Profile .............................................................................................................................. 2-1
Table 2-2: IBWD Board of Directors ........................................................................................................... 2-6
Table 2-3: IBWD Financial Summary ........................................................................................................ 2-15
Table 2-4: IBWD Cash Accounts ............................................................................................................... 2-16
Table 2-5: IBWD Revenues and Expenditures .......................................................................................... 2-16
Table 2-6: Assets and Liabilities ............................................................................................................... 2-17
Table 2-7: IBWD Net Position .................................................................................................................. 2-17
Table 2-8: Connection Fees ...................................................................................................................... 2-18
Table 2-9: MHI Data ................................................................................................................................. 2-26
Table 3-1: IBWD Historic Total Annual Water Demand ............................................................................. 3-3
Table 3-2: Summary of Source Capacity .................................................................................................... 3-3
Table 3-3: IBWD Water Storage Facilities .................................................................................................. 3-7
Table 3-4: Proposition 218 Projects Preliminary Plan.............................................................................. 3-11
Table 7-1: Mendocino County RHNA Allocations ...................................................................................... 7-4
ACRONYMS
AB Assembly Bill
ACS American Community Survey
ADU Accessory Dwelling Unit
AF Acre-feet
AMI Area Median Income
AOI Area of Interest
APN Assessor Parcel Number
APR Annual Progress Report
AWDF Alternative Water Development Fund
CAL FIRE California Department of Forestry and Fire Protection
CALAFCO California Association of Local Agency Formation Commissions
CCR Consumer Confidence 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
CPI Consumer Price Index
CRWA California Rural Water Association
CSDA California Special Districts Association
DUC Disadvantaged Unincorporated Community
DWR California Department of Water Resources
ECWD Elk County Water District
ELEC California Elections Code
EPA United States Environmental Project Agency
FPPC Fair Political Practices Commission
FY Fiscal Year
GC California Government Code
GHG Greenhouse Gas
Gpd Gallons Per day
Gpm Gallons Per minute
HCD California Department of Housing and Community Development
HSC California Health and Safety Code
IBWD Irish Beach Water District
ILG Institute for Local Government
IRWM Integrated Regional Water Management
JADU Junior Accessory Dwelling Unit
LAFCo Local Agency Formation Commission
LCP Local Coastal Plan
MCOG Mendocino Council of Governments (MCOG)
MG Million gallons
MHI Median Household Income
MND Mitigated Negative Declaration
MPO Metropolitan Planning Organization
MSR Municipal Service Review
NCRP North Coast Resource Partnership
OPR California Governor’s Office of Planning and Research
RHNA Regional Housing Needs Allocation
RTP Regional Transportation Plan
SAFER Safe and Affordable for Equity and Resilience
SB Senate Bill
SDUC Severely Disadvantaged Unincorporated Community
SDWA Safe Drinking Water Act of 1974
SDWIS Safe Drinking Water Information System
SOI Sphere of Influence
SWRCB State Water Resources Control Board
USPS United States Postal Service
WAT California Water Code
WDR Waste Discharge Requirement
WTP Water Treatment Plant
INTRODUCTION 1-1
1 INTRODUCTION
1.1 Local Agency Formation Commission
Local Agency Formation Commissions (LAFCos/Commissions) are quasi-legislative, independent local
agencies established by State legislation in 1963 to oversee the logical and orderly formation and
development of local government entities 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 (GC) Section (§) 56000 et seq., 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. 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 website.1
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 organization they represent, if they are an alternate, and
the date their term expires.
Table 1-1: Current Mendocino LAFCO Commissioners, 2025
Commissioner Name Position Representative Agency Term Expires
Madeline Cline Commissioner County 2028
Gerardo Gonzalez Commissioner City 2026
Candace Horsley Commissioner Special Districts 2026
Susan Mahoney Commissioner Special Districts 2028
Maureen Mulheren Chair County 2026
Mari Rodin Commissioner City 2025
Gerald Ward Vice-Chair/Treasurer Public 2026
Douglas Crane Alternate City 2025
John Haschak Alternate County 2027
Raghda Zacharia Alternate Public 2027
Vacant Alternate Special District 2026
1 The Mendocino LAFCo Policies and Procedures Manual can be found here: Policies & Procedures Manual.
Irish Beach Water District | 2025 Municipal Service Review and Sphere of Influence Update
INTRODUCTION 1-2
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).3 This review is intended to provide Mendocino LAFCo with the necessary and relevant
information related to the services provided by Irish Beach Water District (IBWD/District).
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.
MSRs 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 and the administrative supervision of septic systems provided by IBWD. 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
in Chapter 3.3. LAFCo is the sole authority regarding approval or modification of any determinations,
policies, boundaries, SOIs, reorganizations, and provision of services. This MSR/SOI study makes
determinations in each of the seven mandated areas of evaluation for MSRs.
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;
2 GC §56430 (2024) can be found here: California Government Code § 56430 (2024) :: 2024 California Code :: US Codes and
Statutes :: US Law :: Justia.
3 Assembly Committee on Local Government, “Guide to the Cortese-Knox-Hertzburg Local Government Reorganization Act of
2020.” December 2023.
Irish Beach Water District | 2025 Municipal Service Review and Sphere of Influence Update
INTRODUCTION 1-3
• Evaluate governance options and financial information;
• 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 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).4
When reviewing an SOI for a municipal service provider, under GC §56425(e)5, 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 an SOI 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) 5 on or after July 1, 2012, the present and probable need for those public facilities
and services of any Disadvantaged Unincorporated Communities (DUCs) within the existing SOI.
SOI 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 Senate Bill 215
Senate Bill (SB) 215 (Wiggins) requires LAFCo to consider regional transportation plans and sustainable
community strategies developed pursuant to SB 375 before making boundary decisions. SB 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 Plan and Vision
4 GC §56076 (2024) can be found here: California Government Code § 56076 (2024) :: 2024 California Code :: US Codes and
Statutes :: US Law :: Justia.
5 GC §56425 (2024) can be found here: California Government Code § 56425 (2024) :: 2024 California Code :: US Codes and
Statutes :: US Law :: Justia.
Irish Beach Water District | 2025 Municipal Service Review and Sphere of Influence Update
INTRODUCTION 1-4
Mendocino 2030 Blueprint Plan. The 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.
Irish Beach Water District | 2025 Municipal Service Review and Sphere of Influence Update
AGENCY OVERVIEW 2-1
2 AGENCY OVERVIEW
Table 2-1: IBWD Profile
Agency Name: Irish Beach Water District
General Manager General Manager Position Vacant
Water System Manager Brant O’Dell
Office Location: 15401 Forest View Road, Manchester, CA 95459-0067
Mailing Address: PO Box 67
Manchester, CA 95459-0067
Phone Number: (707) 882-2892 or (707) 913-9708
Website: https://www.ibwd.org
Email: General.Manager@IBWD.org or IBWD.Operations@IBWD.org
Date of Formation: February 8, 1967
Agency Type: California Water District
Enabling Legislation California Water District Law: Water Code Section 34000 et seq.
Board Meeting Schedule: The Board meets on the second Saturday of every odd month at
10:00 AM at the Rex Dunning Firehouse, also known as the Irish
Beach Fire House.
2.1 History
2.1.1 Formation
The Irish Beach Water District (IBWD/District) is an independent special district established on February
8, 1967 for the primary purpose of providing water to the Irish Beach Subdivision (Subdivision) (Local
Agency Formation Commission (LAFCo/Commission) Resolution No. 67-2). On April 4, 1967, the
Mendocino County Board of Supervisors adopted Resolution No. 67-57 certifying the election process that
formed the IBWD and establishing the Board of Directors under California Water Code (WAT) Section (§)
34000 et seq.6 In 1980, under California Health and Safety Code (HSC) §6955 et seq.,7 the District added
a wastewater disposal zone to its purview and currently provides administrative overview of existing and
future private and community septic systems.
2.1.2 Boundary
The District is located on State Highway 1, approximately four miles north of Manchester and seven miles
south of Elk in the unincorporated area of Mendocino County’s south coast region. There are 450 parcels
within the District boundary, covering an area of 1,294 acres or 2.02 square miles. Of those 450 parcels,
the District serves 207 parcels, three of which are undeveloped. The remaining 243 lots are vacant and
not connected to the District’s water system.
2.1.2.1 BOUNDARY CHANGE HISTORY
The District originally consisted of the Irish Beach Subdivision, which consisted of 460 parcels totaling 220
acres when it was formed in 1967 (LAFCo Resolution No. 67-2). In 1972, the Moore’s Annexation added
6 WAT §34000 et seq. can be found here: Codes: Code Search (ca.gov).
7 HSC §6955 et seq. can be found here: Codes Display Text (ca.gov).
Irish Beach Water District | 2025 Municipal Service Review and Sphere of Influence Update
AGENCY OVERVIEW 2-2
400 acres to the District (LAFCo Resolution No. 72-7) and a second Moore’s Annexation added an
additional 720 acres in 1975 (LAFCo Resolution No. 75-14).
The last completed boundary change was the Arnold Detachment, which removed 112.23 acres from the
District in December 1988 (LAFCo Resolution No. 88-9).
The change in the number of parcels is also the result of landowner-initiated parcel mergers over the years
as well as litigation that redefined several parcels as dedicated open space in the Subdivision. In 2021,
several parcels were merged per litigation settlement and transferred to the Irish Beach Cluster Homes
Association as dedicated open space. The cluster homes are located on Hillcrest Drive in the Subdivision.
2.1.3 Services
The IBWD provides water supply, treatment, and distribution services to residents within the Irish Beach
Subdivision. Additionally, the District is obligated to provide water services to two undeveloped parcels
located outside of the District service area referred to as the “Inn Site”. The District also supplies treated
water to licensed water haulers with private customers outside of the District.
In addition to water services, the District provides administrative overview of private and community
septic systems, which was acknowledged in the 2014 Municipal Service Review (MSR) for the District.
For more information regarding these services, refer to Chapter 3.
2.1.4 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 or authorized by LAFCo.
Division 13 of California Water District Law (WAT §34000 et seq.)8 identifies the following potential
powers available to the District:
a) WAT §35401: 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.
b) WAT §35412: The Irish Beach Water District may acquire, construct, and operate facilities for
providing fire protection to the district and its inhabitants, including buildings, engines, hose, hose
carts, or carriages, and other appliances and supplies for the full equipment of a fire company or
department. The Irish Beach Water District for the purpose of providing fire protection services
may exercise any of the powers, functions, and duties which are vested in, or imposed upon, a fire
protection district pursuant to the Fire Protection District Law of 1987, Part 3 (commencing with
Section 13800) of Division 12 of the Health and Safety Code.
If the district includes any part of a city, fire protection district, or other local agency which
provides fire protection service to any territory in the district, or if the Department of Forestry and
Fire Protection provides fire protection service to any territory in the district, the district shall have
no authority pursuant to this section regarding the prevention and suppression of fires in these
8 WAT §34000 – 38501 can be found here:
https://leginfo.legislature.ca.gov/faces/codes_displayexpandedbranch.xhtml?tocCode=WAT&division=13.&title=&part=&cha
pter=&article=&nodetreepath=12.
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territories, unless the district has obtained the consent of the city, fire protection district, other
local agency, or the Department of Forestry and Fire Protection.
The provisions of this section are necessary because of the great need for fire protection services
within the area of the Irish Beach Water District. There is no other local governmental entity willing
to provide this service to the people of the district. This problem is not common to all districts
formed under this division. It is therefore hereby declared that a general law cannot be made
applicable and that the enactment of this section as a special law is necessary for the solution of
problems existing in the Irish Beach Water District.
c) WAT §35500: Collection, treatment, and disposal of sewage, waste, and stormwater.
The California Health and Safety Code (HSC §6955 et seq.),9 under which the wastewater disposal zone
was added in 1980, identifies the following potential powers:
a) To collect, treat, reclaim, or dispose of wastewater without the use of communitywide sanitary
sewers or sewage systems and without degrading water quality within or outside the zone.
b) To acquire, design, own, construct, install, operate, monitor, inspect, and maintain on-site
wastewater disposal systems, not to exceed the number of systems specified pursuant to either
Section 6960 or Section 6960.1, within the zone in a manner which will promote water quality,
prevent the pollution, waste, and contamination of water, and abate nuisances.
c) To conduct investigations, make analyses, and monitor conditions with regard to water quality
within the zone.
d) To adopt and enforce reasonable rules and regulations necessary to implement the purposes of
the zone. Such rules and regulations may be adopted only after the board conducts a public
hearing after giving public notice pursuant to Section 6066 of the Government Code.
Any expansion of services would necessitate prior approval from LAFCo through an application for
activation of latent powers, which generally follows the normal Commission proceedings for a change of
organization or reorganization (California Government Code (GC) §56650 et seq.). 10
For a regional map of Mendocino County’s water and sanitation districts and companies, refer to Figure
2-2.
9 HSC §6955 et seq. can be found here: Codes Display Text.
10 GC §56650 et seq. can be found here: Codes: Code Search (ca.gov).
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Figure 2-1: Irish Beach Water District Boundary
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Figure 2-2: Mendocino County Water and Sanitation Districts and Companies
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2.2 Government Structure
2.2.1 Governing Body
The District is governed by a five-member Board of Directors elected by landowners within the District
boundaries. The directors are normally elected at-large in staggered four-year terms. Board members,
positions, and term expiration dates are shown in Table 2-2.
Eligible Board candidates must be registered voters residing within the District boundaries. If the number
of candidates is equal to, or fewer than, the number of Board vacancies, District Board members may be
appointed in lieu of election by the County Board of Supervisors per California Elections Code (ELEC)
§10515.11 New Board members take office at noon on the first Friday in December following their election.
The process for appointment of Board of Directors seats vacated prior to the scheduled term expiration
date is governed by GC §1780-1782.12 The Board of Directors has 60 days to appoint an interested and
qualified individual to a vacant seat if proper noticing 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.
Four of the Board members have served the District for consecutive terms, which can be a significant
benefit in establishing long-standing positive working relationships in the community, understanding the
history and unique aspects of the organization, and maintaining institutional knowledge. However, much
of the District is comprised of vacation homes or short-term rentals with a small number of full-time
residents who would qualify to sit on the District Board. This is a common problem for other small service
providers within the region and throughout rural areas of California.
Table 2-2: IBWD Board of Directors
Name Office/Position Term Expiration Length of Term
Susan Israel President December 2025 4 Years
Danielle Hohos Vice President December 2027 4 Years
Heather Hackett Secretary December 2027 4 Years
Tom Ottoboni Treasurer December 2027 4 Years
Mel Kimsey Director December 2025 4 Years
Source: IBWD 2024a.
The Board currently has no vacancies. While the District experienced a period of frequent changes in the
composition of the Board of Directors, the Board stabilized in 2021 with a slate of knowledgeable
committed directors.
11 ELEC §10515 (1994) can be found here: California Code, ELEC 10515.
12 GC §1780-1782 (2008) can be found here: California Code, GOV 1780.
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2.2.2 Public Meetings
Regularly scheduled meetings are held on the second Saturday of every odd numbered month at 10:00
AM. Meetings are held at the Rex Dunning Firehouse, also known as the Irish Beach Fire House, which is
owned by the District.
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.
The District regularly maintains a website,13 which hosts current agendas and meeting packets, past
meeting minutes, budgets, audits, water reports, and District information. Regular Board meetings,
records, annual budgets, and financial audits are kept current and maintained by the Board president and
Board secretary.
2.2.3 Standing Committees
Committees assist in carrying out various functions of local government. The District currently has one
standing committee: the Budget and Finance Committee. In addition, the District has several ad hoc
committees, including the Grant Committee, the Proposition (Prop) 218 Committee, the Communications
and Outreach Committee, the Litigation Committee, and the Organizational Structure Committee.
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. The District’s website
contains information about the District, its governance, finances, meetings, projects, and other relevant
information benefiting the public. The District keeps residents informed of District requirements and
activities through word-of-mouth and during public meetings. In addition, the District maintains a
Facebook page, posts information in community kiosks, and sends communications through the United
States Postal Service (USPS) as well as email distribution lists. The District is encouraged to review
Appendix B – Website Compliance Handout for a full list of SB 929 compliance requirements.
2.2.5 Complaints
Customers may file complaints via the general manager’s email address listed on the District’s website.
The Board secretary currently manages the email address as the general manager position is vacant.
Complaints are then brought to the Board of Directors for action. The full procedure for how complaints
are handled can be found in the District’s Policy Handbook.14
The District has not received any formal complaints in the last five years. The District periodically receives
customer inquiries about billing issues or during operational emergencies; however, these are routine
customer communications which are addressed in compliance with IBWD Policy 1030.
2.2.6 Transparency and Accountability
The IBWD Bylaws were originally approved on July 11, 1972, and were first amended in 1977, and then
again in 1987. The Bylaws serve as the legal guidelines of the organization by providing written rules that
13 The IBWD Website can be found here: www.ibwd.org.
14 The IBWD Policy Handbook (November 2023) can be found here: IBWD_POLICY_MANUAL.pdf.
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control internal affairs. They define the group's official name, purpose, requirements for membership,
officers’ titles and responsibilities, how offices are to be assigned, how meetings should be conducted,
and how often meetings will be held.
The District also maintains a policy handbook which was last updated in November 2023 and contains
policies related to operations, personnel, conflicts of interest, and financial matters. The policy handbook
is posted on the District’s website.
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.15 The District currently maintains a Conflict-of-
Interest Code which can be found in the District’s policy handbook.
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 §87203.16 The District informed LAFCo staff that the Board’s five
directors are current on their required Form 700 filings. Although the general manager position is
currently vacant, the District shares that the previous water system manager/acting general manager was
up to date on their Form 700 filing.
According to Assembly Bill (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. In addition, the agency must
establish a written policy on reimbursements pursuant to GC §53235.17 The District currently has five
Board of Directors who are required to attend ethics training every two years; all officials have attended
ethics training within the last two years. In addition, the District reports that the previous water system
manager/acting general manager attended ethics training in the last two years.
Refer to Appendix A – Open Government Resources for a brief list of educational resources regarding
open government laws.
2.3 Operational Structure
2.3.1 Management and Staffing
Up until September 2024, daily operations of the District were managed by the water system
manager/acting general manager who oversaw three part-time employees who serve as operators that
run the District’s water system. The water system manager/acting general manager retired from the IBWD
in September 2024, and an interim water system manager was appointed in October 2024. The District
anticipates changing it to a permanent appointment later in the year. At the time of this study, there is a
vacancy for the general manager position, and the District is in the process of recruiting for an interim or
permanent hire (IBWD 2024c, pg. 2). The interim water system manager currently manages the daily
operations of the District water system and oversees the three part-time operators.
15 GC §87300 et seq. (2011) can be found here: Codes Display Text (ca.gov).
16 GC §87203 (2022) can be found here: California Code, GOV 87203.
17 GC §53235 (2023) can be found here: California Code, GOV 53235.
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The water system manager/acting general manager was responsible for managing District infrastructure
by performing preventative maintenance and carefully evaluating the most cost-effective methods for
repairs and improvements. In addition, the water system manager/acting general manager and the Board
evaluated federal and state resources, such as grants and technical assistance, using such resources when
available (LAFCo 2024b).
Additional staff for the District include a staff assistant who takes care of the District’s administrative
affairs including billing, arranging for hookups, and other duties related to administrative oversight of the
private septic systems. In addition, the District has a special assistant who is responsible for assisting the
Board. The District also maintains one on-call employee who provides extra help when necessary. Refer
to Figure 2-3 for the District’s organizational chart.
The District performs evaluations of overall agency performance, including benchmarking, budget
execution reviews, and grant project status reporting.
Figure 2-3: IBWD Organization Chart
Source: IBWD 2024d.
2.3.1.1 CONTRACT STAFFING AND SERVICES
The District maintains contracts for several services, including legal counsel, financial audits, information
technology support, administrative support for the Board treasurer, and a notetaker (IBWD 2024d).
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2.3.2 Agency Performance
A component of monitoring agency performance is routinely evaluating staff productivity. The District has
indicated during this MSR process that it is planning to implement written performance evaluations in the
near future (LAFCo 2024b). District staff identify areas in need of improvement and take corrective action
when feasible and appropriate through the normal course of business or inform the Board when further
direction is needed.
Historically, the District water system manager/acting general manager and the Board of Directors shared
the responsibility of monitoring and evaluating agency operations through regulatory reporting and
review of District databases and records. However, while the general manager position is vacant, these
responsibilities are overseen by the Board of Directors.
2.3.2.1 CHALLENGES
The District faces several challenges including aging infrastructure, drought conditions, and the
identification and development of water sources for future development.
Some of the District’s crucial water system components date as early as 1965 and have met the end of
their useful lifespan, requiring urgent repair and replacement to continue providing sufficient water
supplies to its customers. Sourcing adequate funds for capital funds is and will remain a challenge as
current revenue is limited and the system is within a limited customer base. Additionally, the rising costs
of maintenance and repairs continue to rise.
Another significant and common challenge for many water agencies in the County and throughout the
state is cyclical and emergency drought conditions. The fluctuating availability of water resources due to
declining annual rainfall levels poses a challenge to the delivery of safe, affordable, and efficient water
supplies. Although the District was able to provide water services to its existing customers during the most
recent 2021-2022 drought emergency, 2021 was the first year the Irish Gulch fell below the level necessary
to draw and treat water. The conditions reduced surface water flow to a level that temporarily stopped
water distribution sales to licensed water haulers outside of the District.
Beyond the planning horizon of this document, the District will need to develop additional water sources
to support the buildout of undeveloped lots. In addition, the slow pace of buildout has left the cost of
running the system on a customer base that is less than half of the number of customers envisioned when
the development was approved. Historically on average, the District gains one to two new customers per
year.
2.3.2.2 DISTINGUISHED SERVICES
District staff have managed the aging infrastructure on a limited budget by scheduling replacements at
the point that it becomes inefficient to manage the facility through emergency repairs. In 2020, the District
completed a project to install smart water meters, which provided the opportunity to identify leaks more
quickly, and dramatically reduced the volume of water losses. In recent years, the District has increased
outreach activities and has succeeded in engaging more of the community in participating in Board
meetings resulting in greater transparency. Moreover, in 2022, the District secured $400,000 in grant
funding from the California Department of Water Resources (DWR) Small Community Drought Relief
Program to complete three major infrastructure projects, successfully managing grant funding and
construction activities with in-house staff. For more information regarding these projects, refer to Section
3.2.3.2.
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2.3.2.3 STRATEGIC OR SUCCESSION PLANNING
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
support planning related to the future of the District, and transparency to customers and residents of the
District and members of the public.
In lieu of these documents, the Board considers progress and setbacks over the prior year and plans for
the coming year during the annual budget development process.
LAFCo staff recommend that the District consider preparing a strategic plan when the resources to do so
are readily available.
2.3.3 Regional and Service Specific Collaboration
The District does not participate in any formal interagency collaborative arrangements or mutual aid
agreements. However, the District does maintain an informal collaborative arrangement with the Elk
County Water District (ECWD) for shared staffing, operating resources, and best management practices.
The ECWD is a small water service provider located approximately 7.8 miles north of IBWD along State
Highway 1. The IBWD and ECWD employ three individuals who work for both districts, and up until
September 2024, the districts shared a water system manager/acting general manager. Shared staffing
has facilitated the exchange of operational knowledge and coordination between the two agencies. The
districts continue to share information regarding equipment, vendor and consultant services, and staffing
resources for large emergency projects.
The District works with Mendocino County on a variety of issues and routinely coordinates with the State
Water Resources Control Board (SWRCB). IBWD is an active member of the California Special Districts
Association (CSDA), which provides sample policies, training, updates on changing regulations, and a
forum for discussing industry standards and best practices. In addition, the District is a member of the
California Rural Water Association (CRWA), which provides technical assistance, as well as training
resources addressing both administrative and operational issues. Moreover, the District benchmarks
similarly situated water districts in Northern California.
LAFCo staff recommends that the District consider 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 agencies or organizations.
2.3.4 Shared Service Delivery
2.3.4.1 ADJACENT PROVIDERS
There are no adjacent local agencies providing water and/or wastewater services. The nearest public
provider is the City of Point Arena which provides wastewater services within the city boundaries. The
City of Point Arena is located approximately 7.4 miles south of the District. Approximately 7.8 miles north
of the District is ECWD which provides water services.
There are a few private water service providers in the region that are located within at least 10 miles of
the IBWD:
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• Point Arena Water Works (CA2310013) – community water system,18 202 connections,
approximately 7.6 miles south;
• Point Arena Lighthouse (CA2300845) – transient water system,19 two connections, approximately
six miles south; and
• Lighthouse Point (CA2300653) – transient water system, 51 connections, approximately three
miles south.
GC §56375(r)20 authorizes LAFCo to approve, with or without amendment, wholly, partially, or
conditionally, or disapprove the annexation of territory served by a mutual water company that operates
a public water system into the jurisdiction of a city, a public utility, or a special district, with the consent
of the respective public agency or public utility and mutual water company.
IBWD does not currently participate in any shared collaborations with adjacent private water service
providers and given its isolation, there are no opportunities for shared collaborations identified as part of
this MSR process.
18 Community water systems are defined by the State Water Board as entities like cities, counties, regulated utilities, regional
water systems, and smaller water companies and districts where people live. The people they serve obtain all or much of their
water from this type of public water system because they reside or regularly spend time in the system.
19 Transient water systems are defined as entities like rural gas stations, restaurants, and State and National parks that provide
their own potable water source. Most people that consume the water neither reside nor regularly spend time there. Source:
https://www.waterboards.ca.gov/drinking_water/certlic/drinkingwater/documents/waterpartnerships/what_is_a_public_w
ater_sys.pdf.
20 GC §56375(r) (2023) can be found here: California Code, Government Code - GOV § 56375 | FindLaw.
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Elk County Water District
Irish Beach Water District
Lighthouse Point
Point Arena Lighthouse
Point Arena Water Works
Figure 2-4: Adjacent Private Water Service Providers
Source: SWRCB 2024b.
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2.3.4.2 SHARED SERVICES AND FACILITIES
The District does not currently own any facilities or services with other agencies. The District supplies the
California Department of Forestry and Fire Protection (CAL FIRE) and the Redwood Coast Fire Protection
District (which serves the District area) with water and hydrants for fire protection.
2.3.4.3 DUPLICATION OF SERVICES
The District does not currently have any formal overlap, duplication, or redundancy of services with local
government agencies, non-profit organizations, or private businesses nearby because of its isolated
location.
2.3.4.4 INTERAGENCY COLLABORATION
The District does not participate in any interagency collaborative arrangements or mutual aid agreements.
However, as previously mentioned, the District informally shares staffing, operating resources, and best
management practices with the ECWD, such as equipment, vendor and consultant services, and
employees for large emergency projects. The IBWD and ECWD employ three staff members who work for
both districts, and until September 2024, the districts shared a water system manager/acting general
manager. As such, there is potential for further collaboration between the two.
As previously noted, the District coordinates with CAL FIRE and the Redwood Coast Fire Protection District.
With respect to emergency drought conditions, the District collaborates informally with neighboring
water service providers and answers calls for assistance when appropriate (LAFCo 2024b).
2.3.4.5 REGIONAL AND SERVICE-SPECIFIC PARTICIPATION
As previously noted, the District is an active member of CSDA and CRWA.
It is recommended that the District continue 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.
The District does not participate in the North Coast Resource Partnership (NCRP) Integrated Regional
Water Management (IRWM) Program. Participation in this type of joint planning activities often offers
opportunities to pursue joint grant applications and to leverage other community resources, and it may
be beneficial to the District to consider participation in future IRWM efforts.
2.3.5 Government Structure and Community Needs
2.3.5.1 ENHANCED SERVICE DELIVERY OPTIONS
The District is the only agency providing water services to the Irish Beach Subdivision. The IBWD does not
share services or facilities with other districts apart from those listed in Section 2.3.4.2 above. Fire
protection for properties within IBWD is provided by Redwood Coast Fire Protection District. Wastewater
services within the IBWD are provided by on-site septic systems. In 1980, the District included a
wastewater disposal zone to its purview and currently provides administrative supervision of existing and
future private and community septic systems
No opportunities for the District to achieve organizational or operational efficiencies were identified
during the preparation of this MSR.
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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 District operates as a water enterprise fund, meaning that charges for services are intended to pay
for the costs of providing such services. The water enterprise fund is the main source of revenue for
operation and maintenance purposes. The District has reported to LAFCo staff that current financing levels
are adequate for delivery of services.
Revenues for the District consist primarily of charges for water services. The District Board of Directors
annually adopt a budget and has an independent audit performed each year. Annual audits for Fiscal Year
(FY) 2018 through FY 2021 were provided by the District for this MSR. Audits were prepared by an
independent Certified Public Accountant (CPA), Rich Bowers, CPA. The District utilizes an economic
resources measurement focus and an accrual basis of accounting for its financial statements. Table 2-3
below provides a summary of the audits provided.
The District reports it is behind on its audit schedule. The financial statement audit for the FY ending
September 30, 2022, is in progress and should be published soon. The audit for the FY ending September
30, 2023, will commence once the audit for FY 2022 has been completed (LAFCo 2024b).
Table 2-3: IBWD Financial Summary
FY 18 ($) FY 19 ($) FY 20 ($) FY 21($)
Beginning Net Position 1,155,268 1,128,646 953,263 951,298
Ending Net Position 1,128,646 953,263 951,298 935,383
Operating Revenue
Water Usage 35,419 33,588 44,709 52,479
Water Availability 160,374 168,924 188,694 206,127
Late Fees 2,335 1,478 2,310 3,620
Other Income 2,662 1,877 400 500
Total Operating Revenues 200,790 205,867 236,113 262,726
Operating Expenses
Source of Supply (4,981) (6,699) (15,251) (9,976)
Transmission and Distribution (20,057) (40,808) (30,532) (39,552)
Water Treatment (23,487) (19,883) (23,692) (54,494)
Customer Accounts (5,360) (8,568) (15,209) (6,407)
Meter Installations - (51,740) - -
General and Administrative (81,552) (76,835) (59,331) (105,171)
Legal Fees (61,612) (149,131) (64,264) (31,399)
Depreciation (35,916) (35,916) (34,325) (34,888)
Total Operating Expenses (232,965) (389,130) (242,604) (281,887)
Operating Income/(Loss) (32,175) (183,263) (6,491) (19,161)
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Table 2-3: IBWD Financial Summary
FY 18 ($) FY 19 ($) FY 20 ($) FY 21($)
Non-Operating Revenues (Expenses)
Investment Earnings 6,302 8,383 6,942 6,810
Interest Income (72) (36) (1,662) (2,407)
Other Expense (677) (467) (754) (1,157)
Total Non-Operating Revenue
5,553 7,880 4,526 3,246
(Expenses)
Change in Net Position from Prior FY (26,622) (175,383) (1,965) (15,915)
Source: Rich Bowers, CPA 2021 and 2023.
Cash accounts for the District are summarized below in Table 2-4:
Table 2-4: IBWD Cash Accounts
FY 18 ($) FY 19 ($) FY 20 ($) FY 21($)
Cash in Checking and Savings 59,254 33,221 20,682 80,856
Capital Asset Assessments –
247,597 224,663
Redwood Credit Union
503,364 466,913
Capital Asset Assessments –
366,298 372,092
Mendocino County
Total Cash and Cash
673,149 629,976 524,046 547,769
Equivalents
Source: Rich Bowers, CPA 2021 and 2023.
In the District's FY 2020 and FY 2021 financial statement audits, the auditor reported all Capital Asset
Assessments into a single line. It should be noted that the District has Capital Asset funds in both Redwood
Credit Union and Mendocino County Treasury accounts.
2.4.1.1 REVENUES AND EXPENDITURES
The District primarily generates operating revenue through water service charges (water usage, water
availability, late fees, and other income). Non-operating revenues include investment earnings. The
increase in revenue for FY 2019 from water availability charges of $8,550 reflected a user fee rate increase
that took effect halfway through the year.
However, expense costs are steadily rising and outpacing revenues. Expenses for the District vary by year.
Legal fees represent a large amount of the expenses during years of litigation as shown in FY 2019.
Operating loss in FY 2019 is also the result of $51,740 in operating expenses for the electronic meter
replacement project and a $20,000 increase in Transmission and Distribution due to the increasing
occurrence of leaks and repairs in the aging water system (Rich Bowers, CPA 2021, pg. 6). Despite the
gradual increase in operating income, operating income was a net loss in both FY 2020 and 2021.
Table 2-5: IBWD Revenues and Expenditures
FY 18 ($) FY 19 ($) FY 20 ($) FY 21($)
Revenue 207,092 214,250 243,055 269,536
Expenditures 233,713 389,633 245,020 285,441
Source: Rich Bowers, CPA 2021 and 2023.
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2.4.1.2 ASSETS AND LIABILITIES
Assets and liabilities for the District are shown in Table 2-6. Assets include current assets, restricted
assets, and capital assets. Current assets include cash and cash equivalents, accounts receivable,
assessments receivable, and prepaid insurance. Restricted assets account for cash and cash equivalents,
due from operations, and interest receivable. Capital assets account for property, the water treatment
plant (WTP), and equipment with the net of accumulated depreciation.
Table 2-6: Assets and Liabilities
FY 18 ($) FY 19 ($) FY 20 ($) FY 21($)
Assets 1,491,558 1,439,011 1,396,796 1,432,077
Liabilities (362,912) (485,748) (445,498) (496,694)
Source: Rich Bowers, CPA 2021 and 2023.
2.4.1.3 NET POSITION
As shown in Table 2-3, expenses have exceeded revenues from FY 2018 through 2021, indicating that
the District’s net position is steadily decreasing over time (see Table 2-7).
Table 2-7: IBWD Net Position
FY 18 ($) FY 19 ($) FY 20 ($) FY 21($)
Net Position – End of Year 1,128,646 953,263 951,298 935,383
Source: Rich Bowers, CPA 2021 and 2023.
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 February 2024, reserve funds
totaled $547,916.
2.4.2.2 OUTSTANDING DEBT/COST AVOIDANCE
Safe Drinking Water Loan
The District’s Safe Drinking Water Loan was paid in full as of 2024 (LAFCo 2024b).
Litigation
In November of 2009, a local developer-initiated court proceedings for inverse condemnation, claiming
the District trespassed and inversely condemned private property for the drilling of a well.
On February 26, 2024, a final judgment was issued by the Mendocino County Superior Court in litigation
entitled Moores v. Irish Beach Water District. The judgment ended a long-standing litigation, which took
place in three phases:
• Phase One concerned the Moores' inverse condemnation liability claims against the District;
• Phase Two concerned the damages attributable to the finding of liability in Phase One; and
• Phase Three concerned all remaining claims of the Moores, including issues as to the Prop 218
assessment, declaratory and injunctive relief, trespass, unjust enrichment, and breach of contract.
The judgement also addressed various attorney fees, costs, expert fees, and interest awards.
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The Court found in favor of the Moores for Phase One and Phase Two. The Phase Two judgment awarded
Moores $25,000 plus some fees and costs. Regarding Phase Three, the parties partially settled these
claims in 2016.
As to the remaining claims, the Court reviewed four components of the Prop 218 special assessments:
System Wide; Mallo Pass; Capital Replacements (greater than 40 years); and Loan Replacements. The
Moores' claims concerned all but loan replacements. The Court found in favor of the Moores regarding
the System Wide and Mallo Pass assessments and in favor of the District regarding the Capital
Replacement assessment. The Court also found in the District's favor regarding the Moores’ claims of
trespass, unjust enrichment, and breach of contract (IBWD 2024h). Plaintiffs sought $632,470.00 in
attorney’s fees related to taking of T5 Well easement. The Trial Court awarded Plaintiffs $48,614.00 in
attorney’s fees on July 8, 2024. Plaintiffs sought to recover trial-related costs in the amount of
$206,875.52. On July 8, 2024, the Trial Court awarded Plaintiffs their trial-related costs in the amount of
$16,984.00 (IBWD 2024j).
2.4.2.3 RATE RESTRUCTURING
The District charges fees for parcels connected to the water system. Each year the Board reviews water
rates in conjunction with the annual budget and adjusts as required to assure that the water rates
accurately reflect the needs of the approved budget including consideration of inflationary adjustments
tied to the Consumer Price Index (CPI) as of January of each succeeding year with a maximum annual
adjustment not to exceed three percent.
The current rate structure was adopted on September 14, 2024 under IBWD Resolution No. 2024-7 and
reflects the following:
• Usage Rate (per 100 gallons) $0.83
• Availability Charge / 1 month $108.56
• Availability Charge / 2 months $217.13
In May of 2022, the District increased the service connection fee to cover the estimated reasonable cost
of materials and labor necessary to make connections to the District’s water system. The District’s current
connection fees are listed below in Table 2-8.
Table 2-8: Connection Fees
¾ inch 1 inch
Materials & Equipment (Meter, EMR Upgrade, Pipes & Fittings, Backhoe) $338 $1,138
Labor (Workers, Admin., Manager, Benefits) $187 $398
Indirect Costs $75 $75
Total Connection Fee $600 $1,611
Source: LAFCo 2024b.
Prop 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, Prop 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 (O’Malley 1996).
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The District currently collects two annual assessments from parcel owners to fund the maintenance of
and improvement of existing facilities. The 2002 District-wide Capital Improvement Assessment was
suspended in 2017 pending the outcome of litigation. In February of 2024, the Court found in favor of the
District for the Capital Replacement component of the Prop 218 assessment. On March 9, 2024, the Board
voted to reinstate the Capital Replacement portion of the 2002 District-wide Capital Improvement
Assessment effective with FY 2024 - 2025 at the rate of $72 per parcel, regardless of connection to the
water system, which would yield approximately $32,197 per year (IBWD 2024i, pg. 2).
In April of 2024, the District contracted with SCI Consulting Group to prepare an independent study and
engineering report related to conducting the Prop 218 process to approve assessments necessary to fund
the maintenance, replacement, and/or improvement of the facilities that have been identified as part of
this Prop 218 process. On August 10, 2024, the Board approved the preliminary Irish Beach Water District
2024 Water System Upgrade and Sustainability Assessment and moved to provide for the notice of
hearing and the mailing of assessment ballots (IBWD Resolution No. 2024-5 and 2024-6). The public
hearing was held on October 5, 2024, and parcel owners voted to pass the 2024 Prop 218 assessment.
The Board of Directors adopted the final engineering report and ordered to levy the assessment under
IBWD Resolution No. 2024-8, effective FY 2024 – 2025 at a rate of $258 per year for developed properties
connected to the water system and a rate of $98.04 per year for bare land vacant lots.
The assessment rate can increase in future years based on the annual change in the Engineering News
Record Construction Cost Index 20-city average as of January of each succeeding year, with the maximum
annual adjustment not to exceed four percent in one year. If the annual adjustment for a year is below or
not equal to the four percent cap, the difference can be added to a future maximum allowed adjustment
increase.
The assessment will be invoiced and mailed to landowners for FY 2024-2025 and will appear on annual
property tax bills in subsequent years. The estimated amount to be collected for the 2024 assessment in
FY 2024-2025 is $76,750 (IBWD 2024f, pgs. 1-2).
2.4.2.4 CAPITAL IMPROVEMENT PLAN
In 2023, the District recognized the need for a comprehensive assessment of its potable water system and
engaged Hazen & Sawyer, Water Quality and Supply Engineers to prepare the report. The subsequent
assessment, utilizing the existing asset pipeline inventory, identified a Capital Improvement Plan (CIP) for
the rehabilitation and replacements of potable pipes within the District over the next 25 plus years,
including the replacement of over 3,000 feet of pipe and other infrastructure within one to five years. The
complete technical memorandum from Hazen & Sawyer is available as Exhibit A of the 2024 Water System
Upgrade and Sustainability Assessment.
During the February 2024 Board of Director’s meeting, the Board voted to use the remaining funds from
the Capital Replacement portion of the 2002 District-wide Capital Improvement Assessment to implement
high priority projects identified during the 2024 Prop 218 study. As of February 2024, the District’s Capital
Replacement Fund had a balance of $101,557.
The two annual assessments will provide a stable and reliable source of revenue for long-term capital
improvement planning for the District.
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2.5 Growth
2.5.1 History
The Irish Beach Subdivision was originally a large sheep ranch purchased in the early 1960s by Bill Moores,
Senior, a lumberman from Ukiah, California, whose ambition was to establish a second home
development on the coast (Irish Beach Rental Agency 2024). The Subdivision was developed in 1967 and
includes a total of 450 lots, 204 of which are currently developed.
2.5.2 Present and Planned Land Use and Development
The IBWD boundary is 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 adopted General Plan and Zoning Code regulations. The IBWD 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 (LCP) as approved by the Coastal Commission. Any proposed changes to the
land use or development patterns of the District area must also be approved by the Coastal Commission.
2.5.2.1 LAND USE
The specific land use designations within the District according to the County’s adopted General Plan are
primarily rural residential uses with two open space parcels, and rangeland and forestland uses located
north, east, and south of the Subdivision. The designations include the following:
• Rural Residential, 10 acre minimum (RR10);
• Rural Residential, one acre minimum, (RR1);
• Rural Residential, one acre minimum: Planned Development, one acre minimum 1 (RR1:PD);
• Rural Residential, five acre minimum: Planned Development, five acre minimum (RR5:PD5);
• Suburban Residential Planned Development (SR:PD);
• Rangeland, 160 acres minimum (RL160);
• Forestland, 160 acres minimum (FL160); and
• Open Space (OS).
Refer to Figure 2-5 for the Mendocino County General Plan land use map.
Two parcels located within the District’s SOI are currently designated Rangelands (RL) with a Visitor
Accommodation and Services Combining District (VAS) for hotel, inn, or motel use types (*2C) up to 20
units. These parcels, identified as the “Inn Site”, are currently undeveloped and the property owner has
an agreement with the District to provide services should the property ever be developed. However, given
the constraints of the parcels, only a small portion of which is developable, it is unlikely that an inn of the
maximum size would be feasible.
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Figure 2-5: Mendocino County General Plan Land Use Map
Source: Mendocino County 2024.
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Figure 2-6: Mendocino County Zoning Map
Source: Mendocino County 2024.
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2.5.2.2 DEVELOPMENT
Future growth and development of the District is subject to the Mendocino County land use regulations.
The County has adopted plans and policies to regulate growth, including a General Plan and a Zoning Code.
The County’s Zoning Code contains three major geographical zones: Inland, Coastal, and Mendocino
Town. The Irish Beach Subdivision is included in the Coastal Zone (County of Mendocino 2021). As shown
in Figure 2-6, the zoning map designates most of the Irish Beach Subdivision as single-family residential
apart from two open space parcels. The surrounding parcels within the District boundary include Timber
production (TP) and Rangeland (RL).
2.5.3 Existing Population
The limits of the District include the Irish Beach Subdivision, which consists of primary homes, secondary
homes, and short-term vacation rentals owned and occupied primarily by retirees. The nearest
community is Manchester, which is a Census Designated Place (CDP) with a population of 153. Irish Beach
is located within Census Block Group 1, Tract 111.02 in Mendocino County, which has a population of
1,108 (476 households; 273.2 square miles) and an MHI of $66,300 (U.S. Census Bureau 2022a).
The number of water connections that the District serves (207; three of which are undeveloped) does not
change throughout the year; however, demand for service increases seasonally. As previously mentioned,
the District consists of a mixture of primary residences, second homes, and short-term vacation rental
properties, though the exact number of each is unknown (LAFCo 2024b).
2.5.4 Projected Growth
The District’s population is limited to residents within the Irish Beach Subdivision. Currently, 204 of the
450 lots in the Irish Beach Subdivision are developed. The anticipated growth of the District is limited to
the development of the additional 246 lots. Currently, a population of approximately 254 people reside
in Irish Beach year-round, which fluctuates with seasonal residents at various times of the year. Assuming
the County’s average of 2.46 people per household, full buildout of the Subdivision would result in an
estimated population of 1,107 residents. However, while the District’s original application for formation
estimated a buildout population of 1,200, the District has since undergone several annexations, and the
District has experienced little development within the remaining undeveloped areas. Historically on
average the District has added one to two new connections per year (LAFCo 2024b).
The District anticipates little growth in resident population within the near-term (five years) and long-
term (20 years) planning horizons. 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 (California Department of Finance (DOF) 2024). Fluctuating water availability also plays
a role in the future development of the District. As it currently stands, the District has enough supply to
provide water to 141 future connections (LAFCo 2024b). Given that the projected population trends
countywide predict an overall decline in population and the existing number of undeveloped lots in the
Subdivision, there is more than sufficient land for the District to accommodate any future development.
However, changes to California housing laws could result in a slight increase in development and density
within the District beyond 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)
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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 §65852.150,21 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 Needs Allocation (RHNA) in housing element updates, and a housing element
program to incentivize and promote ADUs that can be offered at affordable rents.
As the state continues to pass legislation to help tackle the ongoing housing crisis, the inevitable impacts
on service providers because of development will continue to mount. It is imperative that small districts
such as IBWD stay up to date on legislative changes.
For additional information and data on housing legislation see Appendix 7.3.
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 services22. 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 United
States American Community Survey (ACS) 2022 1-Year Estimates, the statewide MHI for California was
$91,551 (U.S. Census Bureau 2022d). Thus, the MHI DUC threshold is $73,240 and the threshold for
severely disadvantaged unincorporated communities (SDUCs) (less than 60 percent of the State MHI) is
$54,930.
Disadvantaged unincorporated communities 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 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.
21 GC §65852.150 (2023) can be found here: California Government Code § 65852.150 (2023) :: 2023 California Code :: US Codes
and Statutes :: US Law :: Justia.
22 Technical advisory on SB 244 can be found here: https://opr.ca.gov/docs/SB244_Technical_Advisory.pdf.
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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 differs from
those common to the local agency and the public. Some entities, such as Sonoma County LAFCo and
Stanislaus County, utilize CDPs to help provide usable geographies for DUC boundaries, but even then,
mapping and data challenges persist. Median household income 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. Senate Bill 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 SOI, is an island within a city boundary, or is geographically isolated and has
existed for more than 50 years; and
• Has an MHI that is 80 percent or less than the statewide MHI
• For this analysis, per the California Association of Local Agency Formation Commissions
(CALAFCO) recommendation, calculated the “MHI Threshold” i.e. 80 percent of the statewide MHI
as $73,240, per the ACS MHI data (the MHI for the State of California is $91,551) (U.S. Census
Bureau 2022d).
• Income data was sourced from the 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.
The smallest geographic unit with publicly available data that includes the District is a Census Block Group
(Block Group 1). A Census Block Group is a smaller subdivision of a Census Tract, offering more detailed
demographic information about an area. However, it is important to consider that Census Block Groups
are generally geographically expansive in rural areas. Block Group 1 has a population of 1,108 (476
households; 273.2 square miles) and a MHI of $66,300 which is lower than the MHI DUC threshold of
$73,240 (U.S. Census Bureau 2022a). For further comparison, the Census Tract that Block Group 1 is
located within (Census Tract 111.02) has a population of 4,827 (1,968 households; 320.8 square miles)
and a MHI of $83,135 which is higher than the MHI DUC threshold (U.S. Census Bureau 2022b).
The Irish Beach Subdivision is a mixture of primary homes, second homes, and short-term vacation rentals
located immediately on the coastline. The District and surrounding areas have a notable amount of
seasonal homes that are only occupied a portion of the year. As such, these high earning households tend
to skew the data thus making it even more difficult to get an accurate representation of the District’s
representative MHI. Table 2-9 below summarizes the Census Tract and block group the District is in, as
well as those adjacent to the District’s boundary.
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Table 2-9: MHI Data
Median
Census Block Number of
Census Tract Population Household
Group Households
Income (MHI)
110.01 1 762 463 $42,428
110.01 2 1,127 523 $30,393
111.02* 1** 1,108 476 $66,300
111.02 2 1,853 649 $91,806
111.02 3 1,866 843 $79,596
1543.08 1 935 463 $86,806
* Census Tract IBWD is located within.
** Census Block Group IBWD is located within.
Data sourced from Census Reporter which utilized the ACS 2022 Estimates.
Source: U.S. Census Bureau 2022a and 2022e.
The residents within District receive adequate services with respect to water as provided by IBWD, and
fire services which are provided by Redwood Coast Fire Protection District.23 Wastewater services are
provided by on-site septic systems with administrative oversight by the District. No service issues were
brought to the attention of LAFCo staff during the preparation of this study.
23 The 2018 Mendocino LAFCo Multi-District Fire Protection Services SOI can be 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 Sphere of Influence (SOI) Update
process and assist the Local Agency Formation Commission (LAFCo/Commission) 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 Chapter 3.4
This is the second MSR prepared for the District; the first was adopted by the Commission in October
2014.
3.1 Service Overview
3.1.1 Services
The District provides water services and administrative supervision of the on-site septic systems to lot
owners within the Irish Beach Subdivision.
3.1.2 Service Areas
The District serves the Irish Beach Subdivision located along the coast of Mendocino County,
approximately four miles north of Manchester. There are 450 lots within the Subdivision. Of those lots,
the District provides water services to 207 connections, three of which are undeveloped parcels. The
remaining 243 parcels in the District are vacant and not connected to the District’s water system.
3.1.3 Outside Agency Services
The District is obligated to serve the “Inn Site” through a 2002 settlement agreement (Mendocino County
Superior Court Case No. SCUK-CVG-0083930) with the current property owner. This group of parcels,
which are currently undeveloped, are located north of the District consists of approximately 17 acres and
was included in the District’s SOI in 1994. As part of this agreement, water services are to be provided by
the District to two lots; assessor parcel numbers (APNs) 131-110-04 and 131-110-36 located within the
Inn Site. The agreement indicates that the District will provide the equivalent of 10 hook-ups at the rate
of 500 gallons per day (gpd) per hook-up appurtenant to the two lots (LAFCo 2024b). The District does not
provide wastewater services to the Inn Site and is not obligated to provide wastewater services in the
future.
3.2 Water
3.2.1 Service Overview
The District’s water supply is regulated by the State Water Resources Control Board (SWRCB) Division of
Drinking Water. The District has two permitted appropriative water rights for surface water diversion;
SWRCB Permit No. 15580 for the Irish Gulch Upper Diversion access point and Permit No. 20443 for the
Irish Gulch Lower Diversion access point (LAFCo 2014, pg. 66). The District has five sources of water supply
regulated under the State Division of Drinking Water (Water System No. CA2310012).
The District has three wells, two water diversion access points (Upper Irish Gulch and Lower Irish Gulch),
as well as an option to divert from Moores Creek / Pomo Lake. Infrastructure includes five water storage
tanks, a pipeline network totaling 10.8 miles ranging from one to six inches in diameter, a hydrant system
consisting of 41 hydrants, a small-scale water treatment plant (WTP), and a large-scale WTP all of which
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are located on District-owned land, or property on which the District has an existing easement. The five
water tanks are strategically located throughout the District as shown in Figure 3-2.
The District’s primary water source is Irish Gulch, which is fed by the adjacent Irish Creek located within
District boundaries. There are two supply diversions in the Irish Gulch: the Upper Diversion and the Lower
Diversion. Water is gravity fed from two intake sites to the District’s large-scale WTP. Additionally, the
District also has three deep wells connected to a one-million-gallon (three acre-feet) aquifer in the hills
east of the development. One well can pump out 11 gallons per minute (gpm), the second well can pump
9 gpm, and the third pumps 5 gpm, which is an ample amount for the District. The wells are only utilized
for emergency conditions, when surface water supplies are not adequate.
The water sources used by the District are as follows:
• Irish Gulch Upper Diversion
• Irish Gulch Lower Diversion
• Unit Well 9 (located east of the main Subdivision)
• Tank 5 Well (located southeast of Storage Tank 5)
• Tank 2 Well (located east of Tank 2; activated in 2024 and obtained SWRCB permitting on October
8, 2024)
The District supplies an average of approximately 8,422,857 gallons annually to 204 residential lots, three
of which are undeveloped but connected to the District’s water system. Average daily use for the District
is estimated at 23,076 gpd (111 gallons per residence per day on average), with an average peak day
demand at 34,680 gpd (170 gallons per residence). The system is operating at approximately 31 percent
capacity.
The District is currently in the process of identifying water supply sources for future growth. Development
of water sources for future growth is contingent on District funding. As previously mentioned, in October
2024, the Board ordered the levy of assessments for the Irish Beach Water District 2024 Water System
Upgrade and Sustainability Assessment effective with Fiscal Year (FY) 2024-2025. The 2024 assessment
includes tentative plans for two new wells. Refer to Table 3-4 for more information regarding the tentative
capital improvement plans that will receive funding from the assessments.
3.2.2 Service Adequacy
Based on information provided by the District regarding facilities, management practice and
accountability, and financing, IBWD’s water supply, treatment, and distribution service appears to be
adequate for its current customers and existing development.
The current water system serves 204 developed lots and three undeveloped lots, operating at 31 percent
capacity. It is anticipated that the system could support the buildout of an additional 141 lots. The
development of additional water sources and infrastructure improvements would be necessary to support
the full buildout of the 246 vacant lots. However, the pace of development has been much slower than
originally projected when the Irish Beach Subdivision development was first established, adding an
average of one to two new connections per year. Moreover, the DOF reports that the County’s projected
population growth will trend downward over the next five years, suggesting that buildout of the vacant
lots will likely not occur until well beyond the planning horizon of this document.
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It is noted that current revenue is limited and insufficient for addressing long-term maintenance and
replacement needs and ongoing operation. Sourcing adequate funding is a challenge, and the District has
taken adequate measures to increase revenue streams. In 2024, the District Board reinstated the Capital
Replacement portion of a 2002 District-wide Capital Improvement Assessment and adopted the 2024
special benefit assessment through the Proposition (Prop) 218 process (Irish Beach Water District 2024
Water System Upgrade and Sustainability Assessment). These assessments will help increase funding
towards the urgent repairs and upgrades identified in the recently prepared capital improvement
assessments, one prepared by Hazen and the other prepared by SCI Consulting Group.
3.2.2.1 WATER DEMAND AND CAPACITY
On average, the District supplies approximately 8,422,857 gallons annually to 207 lots, three of which are
undeveloped but connected to the District’s water system. Average daily use for the District is estimated
at 23,076 gpd (111 gallons per residence per day on average), with an average peak day demand at 34,680
gpd (170 gallons per residence). See Table 3-1 for a summary of annual water demand over the past eight
years.
Table 3-1: IBWD Historic Total Annual Water Demand
2016 2017 2018 2019 2020 2021 2022 2023
Million gallons 9.3 6.05 8.78 12.24 9.64 8.9 7.77 5.58
(MG)
Acre-feet (AF) 28.54 18.58 26.96 37.58 29.6 27.31 23.85 17.13
Source: LAFCo 2024b.
As previously stated, the District’s system is currently operating at approximately 31 percent capacity. The
District maintains that the current water system capacity is adequately sized for existing development
with some room for growth. Current capacity estimates an adequate water supply for 379 homes at 300
gpd per home.
Table 3-2: Summary of Source Capacity
Water Source Permit No. Capacity as of 2024 (gpm)
Irish Gulch Upper Diversion 2310012-002-002 12
Irish Gulch Lower Diversion 2310012-001-001 35
Unit 9 Well 2310012-004-004 9
Tank 5 Well 2310012-008-008 11
Tank 2 Well WW21351 5
Total 72 gpm or 103,690 gpd
Source: LAFCo 2024b.
The District’s primary water source is the Irish Gulch Upper Diversion, which diminishes in the fall,
especially during drought conditions. When the Irish Gulch Upper Diversion supply gets too low, the Irish
Gulch Lower Diversion source is brought online.
A Mitigated Negative Declaration (MND) prepared in 2007 for an extension of time for SWRCB Permit No.
15580 concluded that there will be insufficient water in Irish Gulch for the District, even if the entire
stream flow is utilized. In response to these determinations, the SWRCB added mitigation limiting the
diversions in Irish Gulch to 56.7 gpm at the Upper Diversion and 40.8 gpm at the Lower Diversion.
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The District supplements its Irish Gulch water diversions with three groundwater wells. These wells are
anticipated to have enough water to supplement the loss of stream flow during drought conditions.
3.2.2.2 DROUGHT CONTINGENCY PLANNING
The District does not have a formal drought contingency plan; however, the water system manager
reviews operating and drought conditions with the Board at each meeting. The District updates policies
and restrictions as needed based on current conditions. For further information, refer to the “Drought
Information” web page on the IBWD website.
In the time since the last MSR/SOI report was prepared for the District, cyclic drought conditions
throughout the state have occurred, the most serious and recent being the 2021-2022 severe drought
emergency, which has had significant impact on many of the County’s water agencies.
Annual stream flows for the Irish Gulch have been dropping over time owing to reduced annual rainfall, a
trend that has been improving in recent years. Historically, the stream has maintained sufficient flows for
District diversions through the summer/fall until the rainy season and full stream flows return. While
summer/fall flows have been reducing over time, 2021 was the first year the stream fell below the level
necessary to draw and treat water.
The District noted that the IBWD and the Elk County Water District (ECWD) have collectively supplied
approximately 45,000 gallons of water per day to licensed water haulers serving homes and coastal
communities that lack sufficient water resources. The District averages 25,000 – 30,000 gallons of treated
water per day during peak periods. The District sells to individual licensed water haulers that haul District
drinking water to tanks north and south of the District; the District does not have records of the water
delivery locations but has archived water sale records as far back as 2006 (LAFCo 2024b).
At the end of August 2021, drought conditions reduced surface water flow to a level that precluded sales
to these coastal Mendocino County residents, which severely impacted water purchasers facing
increasingly dire drought conditions and with no affordable place to purchase water. The District has
recently had sufficient surface water flow to allow sales to resume (LAFCo 2024b).
If treated water is being hauled and it started post-2001, LAFCo must review and approve outside agency
services according to GC §56133(c)24 and Mendocino LAFCo Policy 12.2.
The District has taken various measures over the years to ensure an adequate water supply is available.
In November of 2000 the District adopted IBWD Resolution No. 2000-7, which enacted a moratorium on
the drilling of groundwater wells within District boundaries indefinitely. This resolution was extended in
2016 until at least 2021 and has not been rescinded or modified to date.
In July of 2015, the District adopted Resolution 2015-02, which established limits on outdoor watering. In
July of 2016, the District adopted Resolution 2016-02 in response to strict State-mandated drought
regulations, which determined that the District had adequate water supply to provide service to its
present users for the next three years with reasonable voluntary drought conservation measures. Such
measures include extending the well drilling moratorium and an overall reduction in water use by 15
24 GC §56133(c) (2017) can be found here: Codes Display Text.
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percent, among other things. Since that time, the District has had sufficient water supply for the existing
population during the drought conditions, including the severe drought of 2021-2022.
Based on past concerns and the likelihood of drought conditions to occur in the future, LAFCo
recommends that, given the volatility of water resources throughout the state and the District’s reliance
on groundwater, the District develop a drought contingency plan within the next five years.
3.2.2.3 REGULATORY PERMITS AND COMPLIANCE HISTORY
The Safe Drinking Water Act (SDWA) requires states to report drinking water information periodically to
the United States Environmental Protection Agency (EPA). 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 SDWIS, IBWD appears to be in compliance with state monitoring
requirements.
There are eleven individual sampling sites tested as part of the SDWIS monitoring for IBWD:
• Irish Gulch Lower Diversion Intake –Last sampled – 12/21/2021; next sample date due now/no
further data available for monitoring schedule;
• Irish Gulch Upper Diversion Intake – Last sampled - 9/26/2023; next sample date due 9/2024;
• Unit 9 Well –Last sampled – 9/23/2022; next sample due date 9/2025;
• Treatment Plant – Irish Beach Treated – Last sampled - 9/26/2023; next sample date due 9/2024;
• DBP 1502 – Last sampled – 9/24/2024; next sample date due 9/2025;
• Tank 5 Well – Last sampled 10/02/2024; Next sample due date 10/2027;
• Treatment Plant Tank 5 Well – Last sampled 12/12/2017; no data available for monitoring
schedule;
• Tank 2 Well – Last sampled 03/20/2023; next sample due date 6/2023;
• Treatment Plant Tank 2 Well – Last sampled 10/29/2024; next sample date due 11/2024;
• Irish Gulch Combined – no data available; and
• Lead and Copper – Last sampled 12/31/2023; next sample due date 9/30/2026.
Source: SWRCB 2024.
There have been no recent violations, and seven individual violations noted. The most recent violation
was in 2018 and has been resolved. No site visits are reported on SDWIS. The 2018, 2019, and 2022
Consumer Confidence Reports (CCRs) for the District are available on SDWIS. The last six years of CCRs
can be found on the District’s website.
The SWRCB has developed the Safe and Affordable for Equity and Resilience (SAFER) Dashboard to assess
the risk drivers of California public water systems by using data from the SWRCB, the California
Department of Water Resources (DWR), and the Office of Environmental Health Hazard Assessment.
For IBWD, the SAFER status and risk assessment results are “not at-risk” for system failure. Although many
of the risk category thresholds score as “no risk”, it is worth noting that the SAFER Dashboard identified
several thresholds in the accessibility and affordability categories as low, medium, and high risk. The
threshold for drought and water shortage risk for small and rural communities was scored as “low risk”
(top 25 percent of systems most at risk of drought and water shortage). The indicator for drinking water
customer charges that meet or exceed 150 percent of statewide average drinking water charges at six
hundred cubic feet level of consumption scored as “medium risk”. Further, the household socioeconomic
burden score (combined score of 0.25 – 0.5) were scored as “medium risk”. The percentage of median
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household income (MHI) relative to the annual system-wide average residential water bill for six hundred
cubic feet score (2.5 percent or higher) was indicated as “high risk”. Lastly, the absence of an intertie was
scored as “high risk” under the accessibility risk level.
3.2.2.4 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 sufficient for the current population and customers. The District is
continuing to upgrade its facilities, with the recent replacement of Tank 5, improvements to Tank 2, and
the activation of the Tank 5 Well through grant funding obtained from the DWR. However, the District
system has an estimated useful life that varies by type:
• Storage Tanks = 1 - 52 years; estimated useful lifespan: 30 – 60 years
• Pipelines = 3 - 56 years old; estimated useful lifespan: 40 years;
• Wells = 16 - 54 years old; estimated useful lifespan: 25 - 35 years; and
• Water Treatment Plant = 49 years old; estimated useful lifespan: 10 – 15 years
As such, much of the system is therefore in need of replacing and sourcing adequate funds for capital
improvements are and will remain a challenge. It follows that the District may not be able to provide
sufficient water supplies to existing residents in the future unless substantial funding for infrastructure is
obtained. Maintaining the small system is an ongoing challenge and with such a limited customer base
and small number of registered voters.
3.2.3 Facilities and Assets
The District has five water storage facilities, a pipeline network, a hydrant system, and two WTPs, all of
which are located on District-owned land, or on easements of property owned by others.
The District’s large-scale WTP is comprised of three stages:
1) A flocculation stage where polymer is injected into the flow and allowed to mix in a serpentine
chamber;
2) 2) Backwashable sand and mixed media filtration tanks with 2,000 square inches of surface,
followed by;
3) 3) A disinfection stage where sodium hypochlorite is injected before being sent into a 210,000-
gallon clearwater holding tank.
The large-scale WTP is located next to Tank 1. The 2024 Water System Upgrade and Sustainability
Assessment, prepared by SCI Consulting Group, identifies that the large-scale WTP was acquired in FY
1985 and requires the replacement of filters and equipment within the next one to five years (see Table
3-4).
The small-scale WTP is located next to Tank 2 and Tank 2 Well. It provides ozonation treatment to the
groundwater supply from the Tank 2 Well for iron and manganese content.
The District’s storage facilities consist of five water tanks of varying capacity of which have been upgraded
or replaced in recent years (see Table 3-3):
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Table 3-3: IBWD Water Storage Facilities
Source Construction Year Installed Capacity (gallon)
Tank 1 Bolted steel 2013 210,000
Tank 2 In-ground gunite with metal roof 1972; new roof in 2023 60,000
Tank 3 Bolted steel 2010 84,000
Tank 4 In-ground gunite with wooden truss 1989 125,000
cover.
Tank 5 Bolted steel 2023 11,000
Source: LAFCo 2024b.
The distribution system consists of approximately 10.8 miles (or 57,238 feet) of pipeline ranging from one
to six inches in diameter. Parts of the District’s distribution system date from 1965, with sections added
over the years, the newest of which was installed in 2021. In 2021, the District replaced approximately
250 linear feet of PVC pipeline with three-inch fused HDPE pipeline and one three-inch gate valve. Over
83 percent of the District’s distribution and transmission system is more than 40 years old and has reached
the end of its useful life span. See Section 2.4.2.3 to learn how the District is addressing aging
infrastructure needs.
Figure 3-1: Distribution and Transmission Pipelines By Age, 2014
Source: LAFCo 2014, pg. 70.
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Figure 3-2: IBWD Well Activation and Tank Replacement Project Locations
Source: IBWD 2021, pg. 18.
3.2.3.1 SYSTEM HISTORY
The District’s Unit 9 Well was originally built by a developer in the 1970s before the Unit 9 area was
annexed to the District (LAFCo Resolution No. 75-14). The well was transferred to the District in 1988
(LAFCo 2024b).
The District at one point held a permit for stream diversion from Mallo Pass Creek (Permit No. 16622) to
ensure adequate water supply for undeveloped portions of the Irish Beach Subdivision. The permit was
originally issued to an individual in 1974 and was assigned to the District by that individual in 1988. The
permit’s issuance included a condition that the project be completed within a specific time period, to
which several extensions of time had been granted by the SWRCB. However, due to the slow pace of
development and ongoing litigation, the project was not completed and on March 11, 2009, the SWRCB
revoked the permit, finding that the water was not being put to ‘beneficial use.’ In September of 2009,
the Board of Directors adopted Resolution 2009-1 officially abandoning the Mallo Pass Creek project and
transferred assessment monies from that project to the new Alternative Water Development Fund
(AWDF).
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As a result, in 2008 the District built two new wells in addition to the existing Unit 9 Well; the Tank 5 Well,
which is still in use, and the Tank 2 Well, which was built on an easement of a private lot. The Tank 2 Well
was activated in 2024 and obtained SWRCB permitting approval on October 8, 2024 (LAFCo 2024b).
No further history of services was provided to LAFCo staff.
3.2.3.2 SYSTEM IMPROVEMENTS
The District’s distribution system dates from 1965 and is almost 60 years old, while other sections have
been improved over the years with the newest pipelines were installed in 2021. Approximately 83 percent
of the District’s distribution and transmission system is more than 40 years old. The District’s oldest
pipelines have reached their useful life expectancy, which suggests that replacement or upgrades to the
distribution system should be prioritized.
The District’s most recent improvements to the system are summarized below.
Raw Water Line
In 2016 the District replaced a nearly 4,000-foot-long, above-ground raw water line from the Irish Gulch
Upper Diversion point to the water treatment plant at the Rex Dunning Firehouse. The heavy-duty, three-
inch polyethylene pipe was fused together and pulled into place with a portable winch to replace an old
three-inch PVC line that was brittle and prone to failure (IBWD 2016).
O’Rorey’s Roost Pipe Replacement
In 2016 the District replaced 1,630 feet of PVC pipe that has been the greatest source of leakage and
emergency repairs in the District. The PVC pipe was replaced with C-900 and has a lifespan of 75 years
(IBWD 2016).
Storage Tanks
As previously noted, water for the District is pumped from existing wells and stored in five water tanks. In
recent years, the District has replaced two large storage tanks with modern epoxy-coated steel on
concrete, free-standing water tanks; Tank 3 (84,000-gallon capacity) was installed in 2010, and Tank 1
(210,000-gallon capacity) was installed in 2013.
Additionally, in 2022 the District was awarded a Small Community Drought Relief Program grant from the
DWR totaling $400,000. The projects were completed in FY 2023-2024 and included the following
components:
a) Tank 5 - Installation of an 11,000-gallon, epoxy-coated bolted steel water storage tank on concrete
foundation to increase well staging capacity ($120,000);
b) Tank 2 Well – Equipment, including the small-scale WTP, and connection of Tank Well 2 to the
water system ($100,000); and
c) Tank 2 - Replacement of the containment roof on an existing 60,000-gallon in ground gunite water
tank with an engineered metal roof so it can return to service ($175,000).
Planned capital improvement projects were contingent on approval of the Prop 218 initiative. A list of
tentative capital projects from the 2024 Water System Upgrade and Sustainability Assessment is included
below as Table 3-4. In October 2024, property owners voted to pass the assessment, and the District Board
of Directors approved the final engineering report and levying of the 2024 assessment (IBWD Resolution
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No. 2024-8). The assessment will fund capital projects, which will be scheduled as part of the annual
budgeting process.
3.2.3.3 ENGINEERING REPORTS
As previously noted, in 2023, the District engaged Hazen & Sawyer, Water Quality and Supply Engineers
to prepare a District assessment, utilizing the existing asset pipeline inventory which identified a Capital
Improvement Plan (CIP). Subsequently, in April of 2024 the District contracted with SCI Consulting Group
to prepare an independent study and engineering report relative to conducting a Prop 218 process to
approve assessments necessary to fund the maintenance, replacement, and/or improvement of the
facilities that have been identified as part of this Prop 218 process. The District Board of Directors
approved the preliminary engineering report in August 2024. In October 2024, the Board approved the
final engineering report.
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Table 3-4: Proposition 218 Projects Preliminary Plan
Source: SCI Consulting Group 2024, pg. 47.
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3.3 Wastewater Services
3.3.1 Service Overview
In 1980, under California Health and Safety Code (HSC) Section (§) 6950-6982 et seq.,25 the District added
a wastewater disposal zone to its purview and currently provides maintenance oversight of existing and
future private and community septic systems, which are regulated under SWRCB Waste Discharge
Requirements (WDRs) Order No. 93-10. The District provides administrative/monitoring services for 204
private septic systems within the District boundary. The on-site septic systems are regulated by the
Mendocino County Department of Environmental Health.
When formed, the District estimated wastewater quantity was 25,000 gpd from 150 residences with
projected quantities reaching 80,000 gpd from 400 residences (buildout of District). At this time, the total
buildout is expected to potentially decline based on parcel mergers and current average water use; the
District expects wastewater to reach approximately 55,000 gpd at total buildout (LAFCo 2024b).
The District’s wastewater responsibilities are limited to maintaining individual wastewater disposal
system records including date of installation, as-built plans of installed systems, and service records of
individual systems. The District also sends new owners and owners of new systems information regarding
maintenance practices that should be followed and local contractors that provide such services. To
enforce this, IBWD passed Resolution No. 93-5, which requires that all septic tanks be inspected and/or
pumped if necessary every five years by a registered sanitarian or a septic tank operator.
3.3.2 Service Adequacy
The District’s responsibilities are limited to monitoring and maintenance records for on-site septic
systems. There appears to be adequate staffing to provide the administrative functions of this service;
therefore, the District’s wastewater service appears to be adequate.
3.3.3 Facilities and Assets
The District does not own, lease, operate, or maintain any wastewater facilities or collection systems.
3.3.3.1 SYSTEM HISTORY
In 2011, the Board of Directors determined that it was necessary and proper, given the lack of existing
status quo, to adopt a resolution establishing a discharge limit with respect to the disposal of waste or
activity which might contaminate the waters of the state flowing through the IBWD (Resolution No. 2011-
2). This action was not in response to any contamination.
25 HSC §6955 et seq. can be found here: Codes Display Text (ca.gov).
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Figure 3-3: IBWD Facilities
Source: SCI Consulting Group 2024, pg. 5.
3.3.3.2 SYSTEM IMPROVEMENTS
Because the District does not own or operate any wastewater system facilities or components, no system
improvements have been identified.
3.3.3.3 ENGINEERING REPORTS
The District reported that there is no history of any engineering reports being prepared to analyze
wastewater services (LAFCo 2024b).
3.4 Determinations
This section presents the required MSR determinations pursuant to GC §56430(a) for the District.26
3.4.1 MSR Review Factors
3.4.1.1 GROWTH
Growth and population projections
26 GC §56430(a) (2024) can be found here: California Government Code § 56430 (2024) :: 2024 California Code :: US Codes and
Statutes :: US Law :: Justia.
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1. Of the 450 lots in the District, 204 are developed with residences. The District is currently at 45
percent of total buildout.
2. A population of approximately 254 people reside in the Irish Beach Subdivision year-round, which
fluctuates with seasonal residents at various times of the year.
3. The District consists of a mixture of primary homes, second homes, and short-term vacation rental
properties.
4. The number of water connections that the District serves (207, three of which are undeveloped
parcels) does not change throughout the year, but demand for service increases seasonally.
5. As it currently stands, the District has enough supply to provide water to 141 future connections.
Given that the projected population trends Countywide predict an overall decline in population
and the existing number of undeveloped lots in the Subdivision, there is more than sufficient land
for the District to accommodate any future development.
3.4.1.2 DISADVANTAGED UNINCORPORATED COMMUNITIES
The location and characteristics of any disadvantaged unincorporated communities (DUCs) within or
contiguous to the SOI
6. The District is wholly located in a Census Block Group. Because the MHI of the block group is lower
than the statewide MHI DUC threshold of $73,240, by this measure, it would meet the income
threshold to qualify as a DUC. However, the District and surrounding areas have a notable amount
of seasonal homes that are only occupied a portion of the year; as such, these high earning
households tend to skew the data, making it difficult to get an accurate representation of the
District’s representative MHI.
7. The residents of the Irish Beach Subdivision are receiving the essential municipal services of fire,
water, and limited wastewater. Water services provided by the District could be improved by
addressing aging infrastructure needs which it is actively meeting. With respect to wastewater
services, customers within the District utilize individual septic tanks for their wastewater needs
for which the District provides administrative oversight over.
3.4.1.3 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
8. The District was established in 1967 to provide water collection, treatment, and distribution
services to the Irish Beach Subdivision.
9. Of the 450 lots in the Subdivision, the District provides water services to 204 developed lots and
three undeveloped lots. The remaining 243 are vacant and not connected to the District water
system.
10. The IBWD system has sufficient water supply and capacity to serve existing connections as well as
141 future connections; however, the District does not currently have sufficient capacity for the
complete buildout of the Subdivision.
11. The District is obligated to provide water service to an out-of-agency area known as the “Inn Site”
per a 2002 settlement agreement; APNs 131-110-04 and 131-110-36 which are currently
undeveloped and consist of approximately 17 acres.
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12. The District’s water supply is regulated by the SWRCB Division of Drinking Water Permits No.
15580 and 20443.
13. The District has five sources of water, consisting of both surface and groundwater resources. The
District’s primary water source is the Irish Gulch, which is fed by the adjacent Irish Creek. There
are two access diversions in the Irish Gulch: the Upper Diversion and the Lower Diversion. The
District also utilizes three active wells (Unit 9 Well, Tank Well 2, and Tank 5 Well).
14. The District supplies an average of approximately 8,422,857 gallons annually to 207 lots, three of
which are undeveloped but connected to the District’s water system. Average daily use for the
District is estimated at 23,076 gpd (111 gallons per residence per day on average), with an average
peak day demand at 34,680 gpd (170 gallons per residence).
15. The system is operating at approximately 31 percent capacity.
16. The District provides adequate water services to its customers despite fluctuating drought
conditions. However, the District should establish a drought contingency plan within the next five
years to ensure adequate supplies for its customers in future drought conditions.
17. The District noted that the IBWD and Elk County Water District (ECWD) have collectively supplied
approximately 45,000 gallons of water per day to licensed water haulers serving homes and
coastal communities located north and south of the District that lack sufficient water resources.
The IBWD supplies approximately 25,000 – 30,000 gallons of treated water per day during peak
demand. The District sells to individual licensed water haulers that haul District drinking water to
tanks north and south of the District; IBWD does not have records of the water delivery locations
but has archived water sale records as far back as 2006. If treated water is being hauled and it
started post-2001, LAFCo must review and approve outside agency services according to GC
§56133(c)27 and Mendocino LAFCo Policy 12.2.
18. Parts of the District’s distribution system date from 1965, with sections added over the years, the
newest of which was installed in 2021. A total of over 83 percent of the District’s distribution and
transmission system is more than 40 years old.
19. In 1980, under HSC §6955 et seq.,28 the District added a wastewater disposal zone to its purview
and currently provides maintenance and administrative oversight of existing and future private
and community septic systems. The District monitors, ensures maintenance and repair, and
informs and maintains records of individual septic systems.
20. There are currently 204 septic systems being monitored within the District boundaries.
21. The District does not own or operate any wastewater collection, treatment, or disposal facilities.
3.4.1.4 FINANCIAL ABILITY OF AGENCY
Financial ability of agencies to provide services
22. The IBWD is funded through service charges, fees, and special tax assessments.
23. The District is currently behind on its required financial audits, and it is recommended that the
District prioritize catching up to the current fiscal year.
24. The District continues to research various funding options for development of additional water
sources and implementation of capital improvements.
27 GC §56133(c) (2017) can be found here: Codes Display Text.
28 HSC §6955 et seq. can be found here: Codes Display Text.
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25. In 2023, the District contracted Hazen & Sawyer, Water Quality and Supply Engineers to prepare
an assessment, utilizing the existing asset pipeline inventory, which identified a CIP for the
rehabilitation and replacements of potable pipes within the District over the next 25 plus years,
including the replacement of over 3,000 feet of pipe and other infrastructure within one to five
years.
26. During the February 2024 Board of Director’s meeting, the Board voted to use the remaining funds
from the 2002 District-wide Capital Improvement Assessment to implement high priority projects
identified during the 2024 Proposition 218 study.
27. As of February 2024, the District’s Capital Replacement Fund had a balance of $101,557.
28. As of February 2024, the District’s reserve funds totaled $547,916.
29. In October 2024, parcel owners voted to approve the Irish Beach Water District 2024 Water System
Upgrade and Sustainability Assessment, and the Board passed a motion to approve the
engineering report and order the levying of the assessment. This assessment, along with funds
from the reinstated 2002 assessment (Capital Replacement portion), will provide a stable and
reliable source of revenue for long-term capital improvement planning for the District.
3.4.1.5 SHARED SERVICES AND FACILITIES
Status of, and opportunities for, shared facilities
30. The District holds in-person meetings at the Rex Dunning Firehouse, also known as the Irish Beach
Fire House, which is owned by the District.
31. The District supplies water and hydrants to the California Department of Forestry and Fire
Protection (CAL FIRE) and the Redwood Coast Fire Protection District (which serves the District
area) for firefighting services.
32. The District informally shares operating resources such as equipment, vendor and consultant
services, and staffing for large emergency projects with the Elk County Water District (ECWD) to
the north of the IBWD, which streamlines communication and coordinating efforts.
33. No further opportunities for facility sharing were identified.
3.4.1.6 ACCOUNTABILITY, STRUCTURE AND OPERATIONAL EFFICIENCIES
Accountability for community service needs, including governmental structure and operational
efficiencies
34. The District demonstrated accountability through its disclosure of information requested by LAFCo
for preparation of this MSR.
35. The IBWD follows standard accounting procedures and practices cost reduction through careful
purchasing, bidding processes, and other mechanisms.
36. The District maintains a policy handbook that guides the activities and operations of the Board,
which is posted on the District website.
37. The District does not currently have a strategic plan that outlines its mission statement, vision
statement, and goals and objectives. Such a strategic plan could help the District improve upon 1)
planning efforts, 2) accountability and transparency, and 3) plan for and prioritize facilities and
system upgrades.
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38. The District provides accountability to its constituents through holding Board meetings at the Rex
Dunning Firehouse, maintaining current meeting records and notices on its website, posting
notices and reports in suitable public places, and preparing annual reports.
39. To ensure compliance with Senate Bill (SB) 929 website compliance requirements for local
governments, the District should review Appendix B – Website Compliance Handout of this report
and implement outstanding items.
3.4.1.7 OTHER SERVICE DELIVERY MATTERS
Any other matter related to effective or efficient service delivery, as required by Commission policy
40. There are no other matters related to service delivery required by Mendocino LAFCo policy.
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SPHERE OF INFLUENCE
4 SPHERE OF INFLUENCE
The Local Agency Formation Commission (LAFCo/Commission) prepares a Municipal Service Review (MSR)
prior to or in conjunction with the Sphere of Influence (SOI) Update process. An SOI Update considers
whether a change to the SOI, or probable future boundary, of a local government agency is warranted to
plan the logical and orderly development of that agency in a manner that supports Cortese-Knox-
Hertzberg Local Government Reorganization Act of 2000 (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 Update. This chapter presents the SOI Update and required
determinations pursuant to California Government Code (GC) Section (§) 56425(e)29.
4.1 Mendocino LAFCo Policies
In 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
LAFCo policies.
The following SOI policies are from the Mendocino LAFCo Policies and Procedures Manual30, adopted
November 5, 2018.
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.
10.1.2 Definitions
The Commission incorporates the following definitions:
a) an “establishment” refers to the initial development and determination of a sphere of influence by
the Commission;
b) an “amendment” refers to a limited change to an established sphere of influence typically initiated by
a landowner, resident, or agency; and
29 GC §56425(e) (2023) can be found here: California Government Code § 56425 (2023) :: 2023 California Code :: US Codes and
Statutes :: US Law :: Justia.
30 The Mendocino LAFCo Policies and Procedures Manual can be found here: http://www.mendolafco.org/policies.html.
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c) an “update” refers to a comprehensive change to an established sphere of influence typically initiated
by the Commission.
10.1.3 Sphere Updates
In updating spheres of influence, the Commission’s general policies are as follows:
a) The Commission will review all spheres of influences every five years for each governmental agency
providing municipal services. Municipal services include water, wastewater, police, and fire protection
services.
b) Sphere of influence changes initiated by any agency providing a municipal service generally require
either an updated or new service review unless LAFCo determines that a prior service review is
adequate.
c) Spheres of influence of districts not providing municipal services including, but not limited to,
ambulance, recreation, hospital, resource conservation, cemetery, and pest control shall be updated
as necessary.
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
The Commission may adopt a “zero” SOI encompassing no territory for an agency. This occurs if LAFCo
determines that the public service functions of the agency are either nonexistent, no longer 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 SOI unless the area’s exclusion would impede
the planned, orderly, and efficient development of the area. In addition, LAFCo may adopt an SOI 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
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SPHERE OF INFLUENCE 4-3
would be jeopardized by inclusion within an agency’s sphere. Exclusion of these areas from an agency’s
SOI 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 SOI (GC §56375.5).31
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 SOI, 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 SOI 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; and
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.
10.1.11 Memorandum of Agreements (For City Sphere Amendments and Updates)
Prior to submitting an application to LAFCo for a new city SOI or a city SOI 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
§5642532. If an agreement is reached between the city and County the agreement shall be forwarded to
LAFCo. The Commission shall consider and adopt an SOI for the city consistent with the policies adopted
31 GC §56375.5 (2023) can be found here: California Code, Government Code - GOV § 56375 | FindLaw.
32 GC §56425(e) (2024) can be found here: California Government Code § 56425 (2024) :: 2024 California Code :: US Codes and
Statutes :: US Law :: Justia.
Irish Beach Water District | 2025 Municipal Service Review and Sphere of Influence Update
SPHERE OF INFLUENCE 4-4
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 SOI as an Area of Interest (AOI) to
any local agency.
a) an AOI 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; and
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 Irish Beach Water District’s (IBWD/District) SOI was last updated in 2016 and is coterminous with the
inclusion of an area adjacent to the northwest corner of the District known as the “Inn Site” (assessor
parcel numbers (APNs) 131-110-04 and 131-110-36), which consists of approximately 17 acres.
The District considers the current SOI to be appropriate (LAFCo 2024b).
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;
• 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;
and
• 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 AOI to earmark
areas for enhanced interagency coordination or for future SOI consideration.
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SPHERE OF INFLUENCE 4-5
There are no study areas in or immediately surrounding the District.
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 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 IBWD (LAFCo 2024b).
4.3 Proposed Sphere of Influence
There are no proposed changes to the SOI at the time.
The District considers its SOI to be appropriate and does not provide services to any properties outside
the SOI boundary.
Additionally, as previously noted, there is an existing relationship between the District and Elk County
Water District (ECWD) in which the two share operational resources such as equipment, vendor and
consultant services, and staffing resources for large emergency projects. The two districts shared a water
system manager/acting general manager until September 2024, and currently share three employees,
which facilitates operational knowledge, communication, and coordination efforts. As such, there is
potential for further collaboration between the two.
4.4 Consistency with LAFCo Policies
Mendocino LAFCo has established local policies to implement its duties and mandates under the CKH Act.
This section identifies potential inconsistencies between the proposed SOI and LAFCo policies.
The proposed District SOI is consistent with Mendocino LAFCo policies (refer to Section 1.4 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).33 These factors are as follows:
1. The present and planned land uses in the area, including agricultural and open space lands;
33 GC §56425(e) (2024) can be found here: California Government Code § 56425 (2024) :: 2024 California Code :: US Codes and
Statutes :: US Law :: Justia.
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SPHERE OF INFLUENCE 4-6
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; 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 on State Highway 1, approximately four miles north of Manchester
and seven miles south of Elk in coastal unincorporated Mendocino County. The primary uses of the coastal
zone are rural residential and agricultural uses. Future development in the District is limited to buildout
of the remaining 246 residential lots within the Irish Beach Subdivision, however the IBWD system has
sufficient water supply and capacity to serve existing connections as well as 141 future connections. 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 this area
The District provides water services to 207 residential connections, three of which are undeveloped, and
provides wastewater oversight services to 204 lots. The District is obligated to provide outside agency
water service to the “Inn Site” which are currently undeveloped and consist of approximately 17 acres
(assessor parcel numbers (APNs) 131-110-04 and 131-110-36) per a settlement agreement. The service
area is limited to the boundaries of the Irish Beach Subdivision located immediately east 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). While there are currently 246 undeveloped lots it is anticipated the
District can accommodate 141 lots of 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 utilizes five main sources of water. The District’s primary water source is the Irish Gulch, which
is fed by the adjacent Irish Creek. There are two access diversions in the Irish Gulch: the Upper Diversion
and the Lower Diversion. The District also utilizes three active wells (Unit 9 Well, Tank 2 Well, and Tank 5
Well) to supply water to the system when surface water is reduced or not available during winter/spring
storms and during times of high-water runoff turbidity. The District supplies an average of approximately
8,422,857 gallons annually to 207 lots, three of which are undeveloped but connected to the District water
system. Average daily use for the District is estimated at 23,076 gallons per day (gpd) (111 gallons per
residence per day on average), with an average peak day demand at 34,680 gpd (170 gallons per
Irish Beach Water District | 2025 Municipal Service Review and Sphere of Influence Update
SPHERE OF INFLUENCE 4-7
residence). The system is operating at approximately 31 percent capacity. The current water system
capacity appears to be adequately sized for existing development with some room for growth. Given the
low anticipated growth rate, the District should have sufficient water supply and service capability for the
planning horizon of this document. On March 9, 2024, the Board voted to approve reinstatement of the
Capital Replacement portion of the 2002 District-wide Capital Improvement Assessment effective with
Fiscal Year (FY) 2024-2025. In addition, on October 5, 2024, the Board approved the 2024 Water System
Upgrade and Sustainability Assessment and ordered the levy of assessments effective with FY 2024-2025.
Combined, these assessments will ensure that the District is positioned to provide water services for the
foreseeable future.
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 IBWD serves the Subdivision of Irish Beach which is the primary community of interest for this SOI
Update. There are no other communities identified in the immediate area.
The District is located within the unincorporated coastal zone of Mendocino County just south of the
community of Elk and north of the community of Manchester. Most of the coastal area 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. However, given the
existing relationship between the District and ECWD in which the two share staffing, operational
resources, and best management practices, there is potential for further collaboration between the two.
4.5.5 The present and probable need for public facilities and services of any disadvantaged
unincorporated communities
The District is wholly located in a Census Block Group. Because the median household income (MHI) of
the block group is lower than the statewide MHI disadvantaged unincorporated community (DUC)
threshold of $73,240, by this measure, it would meet the income threshold to qualify as a DUC. However,
the District and surrounding areas have a notable number of seasonal homes that are only occupied a
portion of the year; as such, these high earning households tend to skew the data, making it difficult to
get an accurate representation of the District’s representative MHI.
Residents of the Irish Beach 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
monitored by the District and regulated by the Mendocino County Department of Environmental Health.
No health or safety issues have been identified.
4.6 Recommendation
Pursuant to California Water Code (WAT) §34000 et seq., and California Health and Safety Code (HSC)
§6955, the Commission does hereby establish the functions and classes of services provided by the IBWD
as limited to providing water and wastewater monitoring and maintenance services. Based upon the
information contained in this report, it is recommended that the District Service Area Boundary and SOI
for all services remain unchanged and coterminous with the added inclusion of the 17-acre “Inn Site”.
Irish Beach Water District | 2025 Municipal Service Review and Sphere of Influence Update
5-1
REFERENCES
5 REFERENCES
Assembly Committee on Local Government Honorable Juan Carrillo, Chair. Guide to the Cortese-Knox-
Hertzberg Local Government Reorganization Act of 2000. 2023.
California Department of Finance (DOF). Demographic Research Unit. Report P-2A: Total Population
Projections, California Counties, 2020-2070 (Baseline 2023 Population Projections; Vintage 2024
Release). Sacramento: California. September 2024. P2A_County_Total.xlsx (live.com).
California Department of Housing and Community Development. “Housing Element Annual Progress
Report (APR) Data by Jurisdiction and Year”. California Open Data Profile. October 8, 2024.
Housing Element Annual Progress Report (APR) Data by Jurisdiction and Year - Dataset - California
Open Data.
California Water Boards. "What Is a Public Water System?" California Water Boards, Accessed February 7,
2025.
https://www.waterboards.ca.gov/drinking_water/certlic/drinkingwater/documents/waterpartn
erships/what_is_a_public_water_sys.pdf.
County of Mendocino. County of Mendocino General Plan. August 2009. Current General Plan |
Mendocino County, CA.
----. County of Mendocino General Plan Coastal Element. November 9, 2021.
mendocinocounty.gov/home/showpublisheddocument/56978/638167184738370000.
Irish Beach Rental Agency. "Real Estate." Irish Beach Rental Agency, 2024. Real Estate - Northern California
Real Estate | Irish Beach Rental Agency.
Irish Beach Water District (IBWD). Small Community Drought Relief Program, Irish Beach Water District
(IBWD) – Well Activation & Tank Restoration Project. October 19, 2021.
----. Irish Beach Water District Policy Handbook. November 2023. IBWD_POLICY_MANUAL.pdf.
----a. “About Us”. Accessed October 10, 2024. Irish Beach Water District (ibwd.org).
----b. Irish Beach Water District Board of Directors Regular Meeting Minutes. March 9, 2024,
IBWD_MAR_9_2024_minutes.pdf.
----c. Irish Beach Water District Board of Directors Special Meeting Minutes. October 5, 2024.
IBWD_SPCL_MTG_MINUTES_OCT_5_2024.pdf.
----d. Irish Beach Water District Meeting Packet. May 11, 2024. IBWD_May_11_2024_packet.pdf.
----e. Irish Beach Water District Meeting Packet. November 9, 2024. IBWD_PACKET_NOV_9_2024.pdf.
----f. Irish Beach Water District 2024 Assessment Ballot Procedure Questions and Answers. 2024.
ibwd_prop_218_qt.pdf.
----g. Irish Beach Water District, 2024 Water System Upgrade and Sustainability Assessment: Proposition
218 Assessment. August 10, 2024. 2024 Irish Beach Water System Upgrade and Sustainability
Assessment.pdf.
Irish Beach Water District | 2025 Municipal Service Review and Sphere of Influence Update
REFERENCES 5-2
----h. Judgement Summary. 2024. IBWD_judgement_summary_2024.pdf.
----i. Resolution of the Board of the Irish Beach Water District Documenting The Approval of the District’s
FY2024-2025 Operating Budgets for Water, Resolution No. 2024-7. September 14, 2024.
IBWD_BUGET_FY_2024_2025_Approved_2024.pdf.
----j. Summary of Costs and Attorney’s Fees Awarded Under CCP Section 1036 Following the T5 Well
Judgement. 2024. IBWD_VS_MOORES_SUMMARY_FINAL_FEE_COSTS_2024.pdf.
Mendocino County. "Mendocino County Zoning Map" [Web Map]. Scale Not Given. "County of
Mendocino, California". Mendocino County Zoning Map (arcgis.com) (June 20, 2024).
Mendocino County Local Agency Formation Commission (LAFCo). Municipal Service Reviews - Water and
Wastewater Districts, October 4, 2014. MUNICIPAL SERVICE REVIEWS (specialdistrict.org).
----. Irish Beach Water District Sphere of Influence Update, May 2, 2016. SOI Update_Template
(mendolafco.org).
----a. Multi-District Fire Protection Services Sphere of Influence Update, May 7, 2018. Resolution No. 2017-
18-07. Microsoft Word - Multi-District Fire SOI Update Adopted FINAL (mendolafco.org).
----b. Mendocino Local Agency Formation Commission, Policies & Procedures Manual, November 5, 2018.
Resolution No. 2018-19-03. Policies & Procedures Manual.
----a. "Commission." Mendocino LAFCo. Accessed February 5, 2025.
https://mendolafco.specialdistrict.org/commission.
----b. Request for Information – Irish Beach Water District Response, September 24, 2024.
----. Request for Information – Irish Beach Water District Response, January 13, 2025.
O'Malley, Marianne. "Understanding Proposition 218." Legislative Analyst's Office. Legislative Analyst's
Office, December 1, 1996. Understanding Proposition 218 (ca.gov).
Rick Bowers, CPA. Irish Beach Water District Financial Statements and Required Supplementary
Information Years Ended September 30, 2019 and 2018. February 17, 2021.
Rick Bowers, CPA. DRAFT Irish Beach Water District Financial Statements and Required Supplementary
Information Years Ended September 30, 2021 and 2020. January 23, 2023.
Safe Drinking Water Information System (SDWIS)a. "Monitoring Results for Individual Sampling Points,
Water System No. CA2310012." Public Drinking Water Watch - California. Safe Drinking Water
Information System, Drinking Water Branch, 2024. Monitoring Schedules (ca.gov).
----b. "Site Visits, Water System No. CA2310012." Public Drinking Water Watch - California. Safe Drinking
Water Information System, Drinking Water Branch, 2024. Site Visits (ca.gov).
----c. "Violations, Water System No. CA2310012." Public Drinking Water Watch - California. Safe Drinking
Water Information System, Drinking Water Branch, December 31, 2018. Violations (ca.gov).
SCI Consulting Group. Fiscal Year 2024 – 25, Engineer’s Report, Irish Beach Water District, 2024 Water
System Upgrade and Sustainability Assessment. June 2024. Engineers Report.pdf (ibwd.org).
Irish Beach Water District | 2025 Municipal Service Review and Sphere of Influence Update
REFERENCES 5-3
State Water Resources Control Board (SWRCB) 2024a. "SAFER Dashboard – Irish Beach Water District."
California Water Boards. State Water Resources Control Board, October 23, 2024.
https://www.waterboards.ca.gov/drinking_water/certlic/drinkingwater/saferdashboard.html.
----b. "System Area Boundary Layer (SABL) Look-up Tool" [Web Map]. Scale Not Given.
https://gispublic.waterboards.ca.gov/portal/apps/webappviewer/index.html?id=272351aa7db1
4435989647a86e6d3ad8 (October 10, 2024).
U.S. Census Bureau a. “American Community Survey 5-year Estimates.” Census Reporter Profile Page for
BG 1, Tract 111.02, Mendocino, CA. 2022. BG 1, Tract 111.02, Mendocino, CA - Profile data -
Census Reporter.
----b. "American Community Survey 5-year Estimates." Census Reporter Profile Page for Census Tract
111.02, Mendocino, CA. 2022. https://censusreporter.org/profiles/14000US06045011102-
census-tract-11102-mendocino-ca/.
----c. “American Community Survey 5-year Estimates.” Census Reporter Profile Page for Manchester, CA.
2022. Manchester, CA - Profile data - Census Reporter.
---d . "Income in the Past 12 Months (in 2022 Inflation-Adjusted Dollars)," 2022. American Community
Survey, ACS 1-Year Estimates Subject Tables, Table S1901, 2022, accessed on October 27, 2024,
S1901: Income in the Past 12 Months ... - Census Bureau Table.
---e. "Median Household Income in the Past 12 Months (in 2022 Inflation-Adjusted Dollars)," 2022.
American Community Survey, ACS 5-Year Estimates Detailed Tables, Table B19013, 2022, accessed
on October 25, 2024, B19013: Median Household Income in ... - Census Bureau Table.
----a. “Profile – Albion CDP.” United States Census Bureau, 2023. Albion CDP, California - Census Bureau
Profile.
----b. "Profile - Mendocino County, California." United States Census Bureau. United States Census Bureau,
2023. https://data.census.gov/profile/Mendocino_County,_California?g=050XX00US06045.
Irish Beach Water District | 2025 Municipal Service Review and Sphere of Influence Update
6-1
ACKNOWLEDGEMENTS
6 ACKNOWLEDGEMENTS
6.1 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
Jen Crump, Analyst
6.2 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.
Heather Hackett, District Board Secretary
Irish Beach Water District
Brant O’Dell, Water System Manager
Irish Beach Water District | 2025 Municipal Service Review and Sphere of Influence Update
APPENDICES 7-1
7 APPENDICES
7.1 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 Local Agency
Formation Commission (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 (GC) Section (§) 6250 et seq.), (2) Political Reform Act – Conflict-of-
Interest regulations (GC §81000 et seq.), (3) Ethics Principles and Training (Assembly Bill (AB) 1234 and
GC §53235), (4) Brown Act – Open Meeting regulations (GC §54950 et seq.), and (5) Online Compliance
regulations (Section 508 of the US Rehabilitation Act and GC §11135).
Refer to the State of California Attorney General website for information regarding public access
o
to governmental information and processes at the following link: https://oag.ca.gov/government.
Refer to the State of California Attorney General website for information regarding Ethics Training
o
Courses required pursuant to AB 1234 at the following link: https://oag.ca.gov/ethics.
The Fair Political Practices Commission (FPPC) is primarily responsible for administering and
o
enforcing the Political Reform Act. The website for the FPPC is available at the following link:
http://www.fppc.ca.gov/.
Refer to the California Department of Rehabilitation website for information regarding §508 of
o
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.
Refer to the Institute for Local Government (ILG) website to download the Good Governance
o
Checklist form at the following link: www.ca-ilg.org/post/good-governance-checklist-good-and-
better-practices.
Refer to the ILG website to download the Ethics Law Principles for Public Servants pamphlet at
o
the following link: www.ca-ilg.org/node/3369.
Refer to the ILG website for information regarding Ethics Training Courses required pursuant to
o
AB 1234 at the following link: http://www.ca-ilg.org/ethics-education-ab-1234-training.
Refer to the California Special Districts Association (CSDA) website for information regarding
o
online and website compliance webinars at the following link:
http://www.csda.net/tag/webinars/.
Irish Beach Water District | 2025 Municipal Service Review and Sphere of Influence Update
APPENDICES 7-2
7.2 Appendix B – Website Compliance Handout
Irish Beach Water District | 2025 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
California 2024 Web Accessibility Checklist
UpdatedMay1,2024.Downloadthelatestatgetstreamline.com/ada
Congratulationsonyourcommitmenttoensuringthatyourdistrict’swebsiteisaccessibletoyourentirecommunity,
includingthosewithdisabilities.ThischecklistwillhelpyouensurecompliancewithTheUnruhActandAB434.
Before you begin
Performaninitialscantocheckforknownissuesusingcheckmydistrict.orgoranothertool
Haveyourwebsiteprovider'scontactinformationtoreportanyissues
One-time actions
-examplesavailableathttps://getstreamline.com/accessibility-policy
1. Designateanaccessibilityofficer-Wehavedesignatedonestaffmemberastheaccessibilityofficerwho
willbethego-tocontactforaccessibilityissues.
2. Approveanaccessibilitypolicy-Ourboardhasapprovedanaccessibilitypolicythatincludesthelevelof
accessibilityyouareadheringto,likeWCAG2.1AA.
3. Createandpostanaccessibilitypage-Wehavecreatedadedicatedaccessibilitywebsitepagetohouse
allaccessibility-relatedcontent,includingthepolicyandplan.Ifwehavecomponentsthatarenotyet
compliant,wehaveaddedinformationaboutourremediationplanandtimelinetogetcompliant.
4. Createaprocessforcommunityconcerns-Wehaveaprocessinplacewhereacommunitymembercan
submitaconcernviaform,phonenumber,and/oremailaddress.
5. Enableclosedcaptionsonyourvideos-Ourvideosallhaveclosedcaptions,andwehaveaprocessfor
includingclosedcaptionsinfuturevideos.(YouTubeincludesthisforfreewhenenabled.Learnhow.Itis
importantthatahumanverifiesthegeneralaccuracyofthecaptions.)
Ongoing actions
-recommendedoncepermonth
6. Scanyourwebsitepageseachmonth-Wehavescannedeverypageofourwebsite,everypagehasa
scoreandlistofissuestoremediate. Freetoolsincludecheckmydistrict.org,GoogleChromeLighthouse
(F12willactivate),andwave.webaim.org.Demandyourwebdeveloperaddressanyissuesthatarise.
7. Checkyourattachments.Wehavecheckedallofourattachmentsandwehaveremovedoraddeda
writtenadisclaimerforanythird-partyattachmentsthatweareunabletoremediate.
8. Performremediations-Wehavetakenactiontofixissuesdetectedbyascan/reportedbyourcommunity
Other actions to consider
● Third-partyADAaudit-largerdistrictsshouldconsiderhiringanoutsidefirmtoconductanaudit.Manual
testingbyuserswithdisabilitiesisthegoldstandardtoensureaccess.
● Indemnification-Choosingaplatformorinsurancethatindemnifiesorinsuresyouagainsttheriskoffines
*Remember,Streamlineisonlyasoftwarecompany,andStreamline'stemplatesandguidesarenotasubstituteforgettingyourown
competentlegaladvice.
APPENDICES 7-3
7.3 Appendix C – Housing Legislation Trends and Results
Mendocino County and ADUs
In response, the County of Mendocino has taken a series of steps to facilitate Accessory Dwelling Unit
(ADU) construction and operation in an attempt to address the local housing crisis. This includes adopting
an ADU ordinance which outlines specific development standards. Another County General Plan update
was adopted on November 9, 2011, which amended the Coastal Zoning Code component of the Local
Coastal Plan (LCP) to establish and revise standards for ADUs in the Coastal Zone.
Because Irish Beach is in the County Coastal Zone, 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 (JADUs), which are accessory structures
typically limited to 500 square feet in an existing space, are exempted from this cap. Any change to the
cap on the number of ADUs shall require a Local Coastal Program amendment.
Per Section (§) 20.458.040 of the Public Health and Safety Requirements in the County’s Municipal Code,
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 in a service district
(such as Irish Beach), 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. Some of the most pertinent requirements can be found in
§20.458.045 of the County’s Municipal Code.
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 California Governor’s Office of Planning and Research (OPR) and the California
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 Regional Housing Needs Allocations (RHNAs).
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. This small 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 kind of development
could very slightly increase demand for wastewater services provided by IBWD in Irish Beach. However,
any new development requires written approval from the service provider to authorize services.
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
Irish Beach Water District | 2025 Municipal Service Review and Sphere of Influence Update
APPENDICES 7-4
Mendocino County, the Mendocino Council of Governments (MCOG) adopted a Regional Housing Needs
Plan in 2018.
Although MCOG does not typically deal with 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
considered different allocation factors for the methodology. Throughout the process, each member
jurisdiction provided statements of constraints to HCD which detailed the land constraints that challenge
residential development in unincorporated Mendocino County. Water resources and availability were
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
August 15, 2019, and August 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 7-1: Mendocino County RHNA Allocations
Projection Total
RHNA Period - Units to Total Remaining
Income Level 2019 2020 2021 2022
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
*Progress toward extremely low-income housing need, as determined pursuant to GC §65583(a)(1).
Irish Beach Water District | 2025 Municipal Service Review and Sphere of Influence Update
APPENDICES 7-5
Extremely
Low-
145 15 26 21 62 83
Income
Units*
Source: HCD 2023.
With respect to how RHNA requirements may affect Irish Beach, the State continues to push for more
housing across the state including in communities located on the coast such as Irish Beach. While these
coastal communities are subject to additional regulation and governing bodies (i.e. the Coastal
Commission), housing mandates can affect these areas just the same as more inland communities. While
there is not currently much left to develop under current regulations in Irish Beach, evolving legislation
could allow for increased development potential that supports the State’s housing goals.
Additional Recent State Housing Legislation
While the state legislator has made a concerted effort to progress ADU development throughout the
state, there have been numerous other housing bills passed in recent years aimed at addressing the
housing affordability crisis.
• Senate Bill (SB) 9 - 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. Senate Bill 9 also mandates that local agencies approve
development projects that meet specified size and design standards.
• SB 10 - 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 January 1, 2021, and January 1, 2029, and is exempt from the California
Environmental Quality Act (CEQA).
• SB 35 - Applies in cities that are not meeting their RHNA goal for construction of above-
moderate income housing and/or housing for households below 80 percent Area Median
Income (AMI). Senate Bill 35 amends California Government Code (GC) §65913.434 to require
local entities to streamline the approval of certain housing projects by providing a ministerial
approval process.
34 GC §65913.4 (2024) can be found here: California Code, GOV 65913.4.
Irish Beach Water District | 2025 Municipal Service Review and Sphere of Influence Update
7-6
APPENDICES
7.4 Appendix D – District Financial Audits
Irish Beach Water District | 2025 Municipal Service Review and Sphere of Influence Update
IRISH BEACH WATER DISTRICT
ANNUAL FINANCIAL REPORT
With
INDEPENDENT AUDITOR’S REPORT THEREON
SEPTEMBER 30, 2022 AND 2021
IRISH BEACH WATER DISTRICT
ANNUAL FINANCIAL REPORT
SEPTEMBER 30, 2022 and 2021
INDEX
PAGE
Independent Auditor’s Report............................................................................................................1 – 3
Management’s Discussion and Analysis............................................................................................4 - 8
Basic Financial Statements
Statements of Net Position.................................................................................................................9
Statements of Revenues, Expenses and Changes in Net Position...................................................10
Statements of Cash Flows................................................................................................................11
Notes to Financial Statements....................................................................................................12-18
FECHTER
& COMPANY
Craig R. Fechter, CPA, MST
Certified Public Accountants (1976 - 2022)
INDEPENDENT AUDITOR’S REPORT
Board of Directors
Irish Beach Water District
Manchester, California
Opinions
We have audited the accompanying financial statements of the business-type activities of the Irish
Beach Water District, as of and for the year ended September 30, 2022, and the related notes to the
financial statements, which collectively comprise the Irish Beach Water District’s basic financial
statements as listed in the table of contents.
In our opinion, the financial statements referred to above present fairly, in all material respects, the
respective financial position of the business-type activities of the Irish Beach Water District, as of
September 30, 2022, and the respective changes in financial position and, cash flows thereof for the
year then ended in accordance with accounting principles generally accepted in the United States of
America.
Basis for Opinions
We conducted our audit in accordance with auditing standards generally accepted in the United
States of America Our responsibilities under those standards are further described in the Auditor’s
Responsibilities for the Audit of the Financial Statements section of our report. We are required to
be independent of the Irish Beach Water District, and to meet our other ethical responsibilities, in
accordance with the relevant ethical requirements relating to our audit. We believe that the audit
evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinions.
Other Matters
The financial statements of Irish Beach Water District as of September 30, 2021, were audited by
other auditors whose report dated January 23, 2023, expressed an unmodified opinion on those
statements.
1
3445 American River Drive, Suite A | Sacramento, California 95864
phone 916-333-5360 | fax 916-333-5370 | www.fechtercpa.com
Board of Directors
Irish Beach Water District
Manchester, California
Responsibilities of Management for the Financial Statements
Management is responsible for the preparation and fair presentation of the financial statements in
accordance with accounting principles generally accepted in the United States of America, and for
the design, implementation, and maintenance of internal control relevant to the preparation and fair
presentation of financial statements that are free from material misstatement, whether due to fraud or
error.
In preparing the financial statements, management is required to evaluate whether there are
conditions or events, considered in the aggregate, that raise substantial doubt about the Irish Beach
Water District’s ability to continue as a going concern for twelve months beyond the financial
statement date, including any currently known information that may raise substantial doubt shortly
thereafter.
Auditor’s Responsibilities for the Audit of the Financial Statements
Our objectives are to obtain reasonable assurance about whether the financial statements as a whole
are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report
that includes our opinions. Reasonable assurance is a high level of assurance but is not absolute
assurance and therefore is not a guarantee that an audit conducted in accordance with generally
accepted auditing standards will always detect a material misstatement when it exists. The risk of
not detecting a material misstatement resulting from fraud is higher than for one resulting from error,
as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of
internal control. Misstatements are considered material if there is a substantial likelihood that,
individually or in the aggregate, they would influence the judgment made by a reasonable user based
on the financial statements.
In performing an audit in accordance with generally accepted auditing standards, we:
• Exercise professional judgment and maintain professional skepticism throughout the audit.
• Identify and assess the risks of material misstatement of the financial statements, whether due
to fraud or error, and design and perform audit procedures responsive to those risks. Such
procedures include examining, on a test basis, evidence regarding the amounts and
disclosures in the financial statements.
• Obtain an understanding of internal control relevant to the audit in order to design audit
procedures that are appropriate in the circumstances, but not for the purpose of expressing an
opinion on the effectiveness of the Irish Beach Water District’s internal control. Accordingly,
no such opinion is expressed.
• Evaluate the appropriateness of accounting policies used and the reasonableness of
significant accounting estimates made by management, as well as evaluate the overall
presentation of the financial statements.
• Conclude whether, in our judgment, there are conditions or events, considered in the
aggregate, that raise substantial doubt about the Irish Beach Water District’s ability to
continue as a going concern for a reasonable period of time.
We are required to communicate with those charged with governance regarding, among other
matters, the planned scope and timing of the audit, significant audit findings, and certain internal
control-related matters that we identified during the audit.
2
Board of Directors
Irish Beach Water District
Manchester, California
Required Supplementary Information
Accounting principles generally accepted in the United States of America require that the
management’s discussion and analysis be presented to supplement the basic financial statements.
Such information is the responsibility of management and, although not a part of the basic financial
statements, is required by the Governmental Accounting Standards Board, who considers it to be an
essential part of financial reporting for placing the basic financial statements in an appropriate
operational, economic, or historical context. We have applied certain limited procedures to the
required supplementary information in accordance with auditing standards generally accepted in the
United States of America, which consisted of inquiries of management about the methods of
preparing the information and comparing the information for consistency with management’s
responses to our inquiries, the basic financial statements, and other knowledge we obtained during
our audit of the basic financial statements. We do not express an opinion or provide any assurance
on the information because the limited procedures do not provide us with sufficient evidence to
express an opinion or provide any assurance.
Fechter & Company
Certified Public Accountants
Sacramento, California
November 4, 2024
3
IRISH BEACH WATER DISTRICT
MANAGEMENT DISCUSSION AND ANALYSIS
SEPTEMBER 30, 2022 and 2021
The following Management's Discussion and Analysis (MD&A) provides a narrative overview and
analysis of the financial performance of the Irish Beach Water District during the fiscal year ended
September 30, 2022 and 2021. Please read this analysis in conjunction with the District's Basic Financial
Statements and accompanying notes immediately following this section.
Overview of the Financial Statements
The District operates under California Irrigation District Law as a utility enterprise. As such, the District
presents its financial statements using the economic resources measurement focus and the full accrual
basis of accounting, similar to methods used by private sector companies. These financial statements are
designed to provide readers with a broad overview of the finances and also present changes in cash
balances, and information about both short-term and long-term activities of the District. There are three
required components to these statements: the MD&A, the Financial Statement s, and the Notes to the
Financial Statements. As an enterprise fund, the District's Financial Statements include four
components .
Statements of Net Position present information on all of the District's assets and liabilities with
the difference between the two reported as net position. The Statements of Net Position provide
the basis for evaluating the capital structure of the District and assessing its liquidity and financial
flexibility. Overtime, increases or decreases in net position may serve as a useful indicator of
whether the financial position of the District is improving or deteriorating.
Net position is displayed in three categories:
• Net investment in Capital Assets;
• Restricted for Capital Projects, and
• Unrestricted
Statements of Revenues, Expenses, and Changes in Net Position present information which
show how the District's net position changed during the year. All of the current year's revenues
and expenses are recorded on an accrual basis, meaning when the underlying transaction occurs
regardless of the timing of the related cash flows. These statements measure the success of the
District's operations over the past year and determine whether the District has recovered its costs
through water sales (usage charges on water bills and contract water sales), user fees (availability
charges on water bills), and other charges.
Statements of cash flows provide information regarding the District's cash receipts and cash
disbursements during the year. These statements report cash activity in three categories:
Operating; Capital and Related Financing Activities; and Investing. These statements differ from
the Statements of Revenues, Expenses, and Changes in Net Position in that they account only for
transactions that result from cash receipts and cash disbursements. As in the past, the Statements
of Cash Flows continue to reconcile the reasons why cash from operating activities differ from
operating income.
4
IRISH BEACH WATER DISTRICT
MANAGEMENT DISCUSSION AND ANALYSIS
SEPTEMBER 30, 2022 and 2021
Notes to the Basic Financial Statements provide a description of the accounting policies used to
prepare the financial statements and present material disclosures required by generally accepted
accounting principles that are not otherwise present in the financial statements. The Notes are
located immediately following the Financial Statements.
Financial Highlights
During the years ended September 30, 2022 and 2021, the District's operating income was $153,119 and
($15,914) respectively. Net income in the current year vs net losses in the prior years, demonstrating the
results if the Board's actions of increasing user fee and maintaining cost control. Occurrence of leaks and
repairs to our aging water system continue. The District Board asked voters for another Prop 218 Capital
Projects Assessment which would be assessed on all 459 home and lot owners to begin in fiscal year 21-
22. However, the measure failed by a narrow margin. Another prop 218 capital project assessment is
planned for fiscal year 22-23. This time with special benefit assessment to the 207 developed lots. The
increase of revenue from availability charges and user charges reflects continued rate increases as
reflected in chart on page 4.
Financial Analysis of the District
Statements of Net Position - The District's net position increased between fiscal year ended
September 30, 2021 and 2022 from $935,384 to $1,088,503. The change can be seen in the condensed
Statement of Net Position below as a $153,119 increase in net position. There was an increase in capital
assets of $84,138 which can be explained by approximately $35,000 depreciation expense offset by
construction in process of $119,138 funded with grant revenues. Current assets increased by $61,642.
Restricted assets increased 4,966 which is the due to expenditure of replacement reserve funds. Current
liabilities decreased by 2,372.
Condensed Statements of Assets, Liabilities, and Net Position
2022 2021 Change
Current Assets $ 194,296 $ 132,654 $ 61,642
Restricted assets 595,040 590,074 4,966
Capital assets 793,488 709,350 84,138
Total Assets 1,582,824 1,432,078 150,747
Current liabilities 180,717 183,089 (2,372)
Deferred revenues 313,605 709,350 (395,745)
Total liabilities 494,322 892,439 (398,117)
Net investment in capital assets 793,488 709,350 84,138
Restricted 276,469 276,469 -
Unrestricted 18,546 (50,435) 68,981
Total net position $ 1,088,503 $ 935,384 $ 153,119
5
IRISH BEACH WATER DISTRICT
MANAGEMENT DISCUSSION AND ANALYSIS
SEPTEMBER 30, 2022 and 2021
Changes in Revenues, Expenses, and Net Position - The District's income before capital improvement
assessments increased $169,035 as a result of a $105,958 grant, and increase of $41,338 of non-operating
revenues offset by a slight increase of $28,302 of expenses.
The change in net position that resulted can be seen in the table below, which summarizes the Statement
of Revenues, Expenses, and Changes in Net Position.
Condensed Statements of Revenues and Expenses
2022 2021 Change
Operating Revenues:
Water Usage $ 41,715 $ 52,479 $ (10,764)
Water Availability 265,929 206,127 59,802
Grant revenues 105,958 - 105,958
Late Fees 2,933 3,620 (687)
Meter connections 750 500 250
Total Operating Revenues 417,285 262,726 154,559
Non-Operating Revenues 48,148 6,810 41,338
Total Revenues 465,433 269,536 195,897
Operating Expenses 310,189 281,886 28,303
Non-Operating Expenses 2,125 3,564 (1,439)
Total Expenses 312,314 285,450 26,864
Income (loss) before Contributions 153,119 (15,914) 169,033
Capital Contribution Assessments - - -
Change in Net Position $ 153,119 $ (15,914) $ 169,033
6
IRISH BEACH WATER DISTRICT
MANAGEMENT DISCUSSION AND ANALYSIS
SEPTEMBER 30, 2022 and 2021
Economic Factors and Prospective Information
The District's Board of Directors has increased rates as necessary to ensure that the District's costs be
covered by revenues. Following is a table of approved rates for the last seven years. 2017-18 is last year
for collections of prop 218 assessments. Availability and Usage rates are based on operating budgets
approved each year, and may change from year to year. The Court ordered the Mallo Pass portion of the
assessment discontinued in 16-17. The increase in availability charges in November of 2021 was for the
purpose, in part, of building an unrestricted Board Reserve for unfunded capital improvements and
contingencies.
Economic Factors and Prospective Information
Year Ended Availability Usage
September 30: Assessments Charge Charge
2016 $ 242.03 $66.49/200 $0.51/100gal
2017 $ 157.90 $66.49/202 $0.51/100gal
2018 $ - $66.49/202 $0.51/100gal
2019 $ - $73.14/202 $0.57/100gal
2020 $ - $78.87/202 $0.58/100gal
2021 $ - $85.50/202 $0.65/100gal
2022 $ - $108.56/207 $0.67/100gal
2023
The District, by way of the Proposition 218 balloting process, was authorized to impose a special
assessment for capital improvement to the water system. The assessment was levied annually and
collected by Mendocino County Treasurer by placing these assessments on the property tax bills at a cost
of 2%. Unfortunately, the 2002 assessment ended in fiscal year 2016/17 and voters (parcel owners) have
not approved a new capital projects assessment.
Until 2008, the Irish Beach Water District had three developed sources of water: 1) The Upper Diversion
on Irish Gulch, 2) Well #9 located east of the main subdivision; and 3) the Lower Diversion on Irish
Gulch. Over the years, the Unit 9 well has been diminishing in production volume. Two new wells were
drilled in 2008 to provide additional water source capacity to existing parcels and future homes yet to be
built. (Ground water can be held in future reserve where surface water cannot.). One was drilled, by
agreement on a parcel owners, near Tank 2. This well has not been connected to the system because of
current litigation preventing the utility connection to that well. A second well was drilled on an easement
granted to the District near Tank 5 in the Unit 9 area. The existing Unit 9 well is on that same easement.
The new T5 Well was tested for recovery rate, water quality, and was licensed for use by the State
Department of Public Health. In 2009, Willam and Tonya Moores filed suit against the District in
Superior Court regarding liability for inverse condemnation for the drilling of the T5 Well. The court
ruled against the District as to liability for inverse condemnation as to the T5 Well in a decision dated
June 20, 2012. In a second phase of the litigation in 2015, the court found that the Moores’ were entitled
7
IRISH BEACH WATER DISTRICT
MANAGEMENT DISCUSSION AND ANALYSIS
SEPTEMBER 30, 2022 and 2021
to $401,000 in compensation and $734,000 in attorney fees and costs. The district appealed this
judgement and in 2021 to the Court of Appeal of the State of California reversed these lower court’s
findings with respect to compensation and related costs. The case was remanded back to the Superior
Court to determine an appropriate value for the inverse condemnation of the small plot of land where the
well was drilled.
The third phase of this litigation sought to invalidate certain prop 218 assessments, seek damages for
road maintenance and an alleged breach of a 2002 settlement agreement. The trial court ruled that, after
adjusting for certain disallowed expenditures, the remaining balance of the Mallo Pass assessment fund
and the Systemwide assessment fund be returned to parcel owners and that that fund ceiling of Capital
Replacement Assessment Fund be lowered. The adjustment of the Capital Replacement Assessment Fund
was also appealed Court of Appeal of the State of California and the Superior Court Judgment was
overturned. Actions regarding the disposition of the Mallo Pass and Systemwide funds are pending
court’s final judgment, expected in late 2023 or early 2024.
Well Moratorium -The District continues to enforce a new well drilling moratorium. However,
exemptions from the moratorium are considered on case-by-case basis by board of directors.
Projects in Process - On May 2, 2022, the District accepted a $400,000 grant from the California
Department of Water Resources to renovate Tank 2, activate Well 2, and replace the temporary Tank 5
with a permanent bolted steel tank. Construction activities commenced in May 2002 by the end of fiscal
year 2021/2022, the grading and drainage site preparation, concrete work and framing for the structures
secure ozonator/filter enclosure at Well 2 and the secure appurtenance enclosure at Tank 2 were
complete. The custom metal cover for Tank 2 had been ordered and scheduled for installation by the end
of the calendar year.
The District requested reimbursement for a total of $113,444.09 for grant project related costs during the
period May 2022 through August 2022, and had incurred another $6,882.33 in grant-related costs for
September 2022. At the end of fiscal year 2021/2022 the District was awaiting reimbursement from the
State and had not yet received any grant funds.
Contacting the District's Management
This financial report is designed to provide our citizens, rate payers, and creditors with a general
overview of the District's finances and to demonstrate the District's accountability for the financial
resources it manages. If you have questions about this report or need additional information, please
contact the District.
Irish Beach Water District
P.O. Box 67
Manchester, California 95459
8
IRISH BEACH WATER DISTRICT
STATEMENTS OF NET POSITION
September 30, 2022 and 2021
2022 2021
ASSETS
Current Assets
Cash in banks $ 14,514 $ 80,856
Accounts receivable 63,769 36,737
Taxes receivable - 5,006
Grants receivable 105,958
Prepaid insurance 10,055 10,055
Total Current Assets 194,296 132,654
Restricted Assets
Cash and cash equivalents 478,592 466,913
Interest receivable 44 761
Due from operations 116,404 122,400
Total Restricted Assets 595,040 590,074
CAPITAL ASSETS
Property, plant and equipment - net 793,488 709,350
Total Assets 1,582,824 1,432,078
LIABILITIES
Current Liabilities
Accounts payable 1,121 4,265
Accrued Payroll and Taxes 1,846 11,735
Due to Restricted Assets 116,404 122,400
Due to Redwood Coast Fire 61,345 44,689
Total Current Liabilities 180,716 183,089
Long-term Liabilities
Deferred revenue -Water Source Development 313,605 313,605
Total Liabilities 494,321 496,694
NET POSITION
Net Investment in Capital Assets 793,488 709,349
Restricted for Capital Projects 276,469 276,469
Unrestricted Deficit 18,546 (50,434)
TOTAL NET POSITION $ 1,088,503 $ 935,384
See accompanyimng notes to financial statements
9
IRISH BEACH WATER DISTRICT
STATEMENTS OF REVENUES, EXPENSES AND CHANGES IN NET POSITION
For the Years Ended
September 30, 2022 and 2021
2022 2021
Operating Revenues
Water Usage $ 41,715 $ 52,479
Water Availability 265,929 206,127
Late Fees 2,933 3,620
Meter connections 750 500
Total Operating Revenues 311,327 262,726
Operating Expenses
Source of Supply 4,888 9,976
Transmission and Distribution 30,686 39,552
Water Treatment 45,224 54,494
Customer Accounts 6,133 6,407
General and Administrative 122,559 105,170
Legal Fees 65,699 31,399
Depreciation 35,000 34,888
Total Operating Expenses 310,189 281,886
Operating Income (Loss) 1,138 (19,160)
Non-Operating Revenues (Expenses)
Investment Earnings 4,922 6,810
Grant Revenue 105,958 -
Other Revenue, Fund Transfer 43,226 -
Interest Expense (1,520) (2,407)
Other Expense (605) (1,157)
Total Non-Operating Revenues (Expenses) 151,981 3,246
Change in Net Position 153,119 (15,914)
Net Position - Beginning of Year 935,384 951,298
Net Position - End of Year $ 1,088,503 $ 935,384
See accompanyimng notes to financial statements
10
STATEMENTS OF CASH FLOWS
For the Years Ended
September 30, 2022 and 2021
2022 2021
Cash Flows from Operating Activities
Cash Received from Customers $ 2 84,295 $ 2 59,419
Payments to Suppliers (221,797) (110,836)
Payments for Employees and Taxes (49,769) (87,245)
Net Cash Provided by Operating Activities 1 2,729 61,338
Cash Flows from Capital and Related Financing Activities
Capital Expenditures (119,138) (40,101)
Interest Expense (1,520) (2,407)
Other Revenue (Expense) 4 7,627 (1,157)
Net Cash Used by Capital and Related Financing Activities (73,031) (43,665)
Cash Flows from Investing Activities
Investment Income 5 ,639 6 ,050
Net Increase (Decrease) in Cash and cash equivalents (54,663) 2 3,723
Cash and Cash Equivalents - Beginning 5 47,769 5 24,046
Cash and Cash Equivalents - End of Year
$ 4 93,106 $ 5 47,769
Components of Cash and Cash Equivalents
Cash in Checking and Savings $ 1 4,514 $ 8 0,856
Restricted Cash and Cash Equivalents:
Capital Asset Assessments -
Redwood Credit Union 4 78,592 4 66,913
Mendocino County
Total Cash and Cash Equivalents $ 4 93,106 $ 5 47,769
Reconciliation of Operating Loss to Net Cash
Provided (Used) by Operating Activities
Operating Income (Loss) $ 1 ,138 (19,161)
Depreciation and Amortization 3 5,000 3 4,888
Net Changes in Assets and Liabilities:
Accounts Receivable (27,032) (3,307)
Prepaid Insurance - 1 22
Accounts Payable (3,144) 3 ,410
Accrued Payroll and Taxes (9,889) 2 ,777
Due to Redwood Coast Fire 1 6,656 4 2,609
Net Cash Provided (Used) by Operating Activities $ 1 2,729 $ 6 1,338
See accompanyimng notes to financial statements
11
IRISH BEACH WATER DISTRICT
NOTES TO FINANCIAL STATEMENTS
SEPTEMBER 30, 2022 and 2021
NOTE 1 SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES
Reporting Entity
The Irish Beach Water District (the District) was formed in 1967 under the provisions of the Water Code
of the State of California for the purpose of providing water to properties within the District, which
include the subdivision known as Irish Beach along the southern Mendocino County coast line.
The District started providing Fire protection services in 1978 which were subsequently taken over by the
Redwood Coast Fire Protection District as part of an annexation of that department. The fire department
is not a component unit of the District.
Criteria used in determining the scope of the reporting entity includes financial interdependency,
selection of governing authority, designation of management, ability to significantly influence operations,
and accountability for fiscal matters. The reporting entity consists of the District as the primary, and sole,
reporting entity.
Measurement Focus, Basis of Accounting, and Financial Statement Presentation
The financial statements of the District are prepared in conformity with accounting principles generally
accepted in the United States of America, as defined by the' Government Accounting Standards Board
(GASB), the independent and ultimate authoritative accounting and financial reporting standard-setting
body for state and local governments. The District's reporting entity applies all relevant GASB
pronouncements. Enterprise, or proprietary, funds apply Financial Accounting Standards Board (FASB)
pronouncements and Accounting Principles Board (APB) opinions issued on or before
November 30, 1989, unless those pronouncements conflict with or contradict GASB pronouncements, in
which case GASB prevails.
The District is accounted for as an enterprise fund (proprietary fund type). A fund is an accounting entity
with a self-balancing set of accounts established to record the financial position and results of operations
of a specific governmental activity. Proprietary funds are accounted for on the flow of economic
resources measurement focus and use the accrual basis of accounting. Under this method, revenues are
recorded when earned and expenses are recorded at the time liabilities are incurred.
The activities of enterprise funds closely resemble those of business entities in which the purpose is to
conserve and add to basic resources while meeting operating expenses from current revenues. Enterprise
funds account for operations that provide services on a continuous basis and are substantially financed by
revenues derived from user charges.
The District distinguishes operating revenues and expenses from non-operating items. Operating
revenues include revenues derived from services for usage and availability of water, and related
activities. Operating expenses include all expenses applicable to the furnishing of these activities. Non-
operating revenues and expenses include revenues and expenses not associated with the District's normal
business of providing water services.
When both restricted and unrestricted resources are available for use, it is the District's policy to use
restricted resources first, then unrestricted resources as they are needed.
12
IRISH BEACH WATER DISTRICT
NOTES TO FINANCIAL STATEMENTS
SEPTEMBER 30, 2022 and 2021
NOTE 1 SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (continued)
Budgetary Accounting
An annual budget is adopted by the Board of Directors each fiscal year. The budget may be revised
during the year to reflect unanticipated revenues or expenses. The budget is used for operating
management and internal accounting control purposes, and is prepared on the modified cash basis of
accounting.
Cash and Cash Equivalents
Cash and cash equivalents include amounts in demand deposits and with the county treasury, as well as
short-term highly liquid investments with maturities of three months or less. State statutes authorize the
District to invest in obligations of the U.S. Treasury, commercial paper, corporate bonds, and repurchase
agreements.
Accounts Receivable
Accounts receivable represent amounts due for water services. All amounts are considered to be
collectible, and no allowance for doubtful accounts has been recorded. Liens are placed on properties
with outstanding balances. If accounts receivable are considered uncollectible, losses are recognized
when the amounts become determinable.
Prepaid Expenses
Payments made to vendors for services that will benefit periods beyond the fiscal year-end are recorded
as prepaid assets.
Restricted Assets
Assessments for capital improvements are considered restricted because their use is limited to future
developments within the water system.
Capital Assets
Capital assets are recorded at cost. Major improvements and additions are charged to the related capital
asset accounts. Improvements and additions which do not significantly improve or extend the life of the
asset are charged against earnings in the period incurred. Donated capital assets are recorded at their
estimated fair market value on the date received.
13
IRISH BEACH WATER DISTRICT
NOTES TO FINANCIAL STATEMENTS
SEPTEMBER 30, 2022 and 2021
NOTE 1 SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (continued)
Depreciation
Depreciation is charged to expense for all capital assets; except land, right of ways, and any projects in
progress. Projects in progress are considered depreciable upon completion of the related project.
Depreciation is calculated using the straight-line method over the estimated useful lives of the related
assets. The estimated useful lives are as follows:
Improvements and Infrastructure Equipment and Vehicles
Office Equipment and Furniture
20 - 40 years
5 - 15 years
5 - 10 years
Net Position
Net position represents the difference between assets and liabilities. The District's net position is
classified as follows:
Net Investment in Capital Assets - This represents the District's total investment in capital assets,
net of accumulated depreciation, and reduced by any outstanding debt obligations related to those
capital assets.
Restricted Net Position - Restricted net position represents resources which are legally or
contractually obligated to be spent in accordance with restrictions imposed by external third
parties.
Unrestricted Net Position - Unrestricted net position represents the net amount of assets and
liabilities that is not included in the determination of the net investment in capital assets or
restricted components of net position. Prepaid insurance is considered a non-spendable net
position.
Measurement Uncertainty
The preparation of financial statements in conformity with generally accepted accounting principles
requires management to make estimates and assumptions that affect certain reported amounts and
disclosures. Accordingly, actual results could differ from those estimates.
14
IRISH BEACH WATER DISTRICT
NOTES TO FINANCIAL STATEMENTS
SEPTEMBER 30, 2022 and 2021
NOTE 2 CASH AND CASH EQUIVALENTS
Cash and cash equivalents consist of the following at September 30, 2022 and 2021:
2022 2021
Checking Accounts $ 14,514 $ 80,856
Restricted- Money Market $ 478,592 $ 466,913
Total $ 493,106 $ 547,769
District deposits are fully insured or collateralized with securities held by the District or its agent in the
District's name. The California Government Code requires California banks and savings and loan
associations to secure local agency deposits by pledging government securities as collateral. The market
value of pledged securities must equal at least 110% of a local agency's deposits.
NOTE 3 CAPITAL ASSETS
Following is a summary of changes in capital assets for the years ended September 30, 2022 and 2021:
September 30, 2022
September 30, 2021 Additions Disposals Reclassifications September 30, 2022
Non-depreciating assets:
Land $ 519,810 $ - $ - $ - $ 519,810
Construction in progress 40,101 119,139 - - 159,240
Total non-depreciable assets 559,911 119,139 - - 679,050
Depreciating assets:
Buildings and improvements 378,758 - - - 378,758
Equipment 22,208 - - - 22,208
Vehicles 585,903 - - - 585,903
Total depreciating assets at cost 986,869 - - - 986,869
Accumulated depreciation (837,431) (35,000) - - (872,431)
Net depreciating assets 149,438 (35,000) - - 114,438
Net capital assets $ 709,349 $ 84,139 $ - $ - $ 793,488
15
IRISH BEACH WATER DISTRICT
NOTES TO FINANCIAL STATEMENTS
SEPTEMBER 30, 2022 and 2021
NOTE 3 CAPITAL ASSETS (continued)
September 30, 2020 Additions Disposals Reclassifications September 30, 2021
Non-depreciating assets:
Land $ 519,810 $ - $ - $ - $ 519,810
Construction in progress - 40,100 - - 40,101
Total non-depreciable assets 519,810 40,100 - - 559,911
Depreciating assets:
Buildings and improvements 378,758 - - - 378,758
Equipment 22,208 - - - 22,208
Vehicles 585,903 - - - 585,903
Total depreciating assets at cost 986,869 - - - 986,869
Accumulated depreciation (802,543) (34,888) - - (837,431)
Net depreciating assets 184,326 (34,888) - - 149,438
Net capital assets $ 704,136 $ 5,212 $ - $ - $ 709,349
Depreciation expense for the years ended September 30, 2022 and 2021 is $35,000 and $34,888,
respectively..
NOTE 4 DEFERRED REVENUE
Water Source Development deferred revenue represents with a balance of $313,605 represents
assessments through September 30, 2016. The Court ordered a stop to collection of assessments for
future water development. It is anticipated that when any appeals are final, the full amount of the water
development funds will be returned to the property owners. See commitments and contingencies below
for continued discussion.
NOTE 5 COMMITMENTS AND CONTINGENCIES
Alternate Water Source Development and Litigation
The District had a permit from the State Water Resources Control Board (SWRCB) to divert surface
water from Mallo Pass Creek. The permit was originally issued to an individual in 1974 and was assigned
to the District by that individual in 1988.
The permit was issued with a requirement that the project be completed within a specified period of time,
to which several extensions had been granted by the SWRCB. Due to litigation and other factors the
project was not completed, and the SWRCB has denied any additional extensions and revoked the
permit. The District retained legal counsel for this issue, and, after numerous appeals and discussions, it
was determined that the revocation will stand, in large part because the District cannot control rate of
development needed to support the project.
16
IRISH BEACH WATER DISTRICT
NOTES TO FINANCIAL STATEMENTS
SEPTEMBER 30, 2022 and 2021
NOTE 5 COMMITMENTS AND CONTINGENCIES (continued)
In November of 2008 the District passed a resolution officially abandoning the project. It was determined
by the District that the funds originally accumulated for this project could be held as restricted for other
water source developments. This contention was challenged in a legal suit filed in 2009. A landowner in
the District brought this action among numerous causes of action, and included the District's four
Proposition 218 Assessments.
Proposition 218, which was approved by the voters in November 1996, amended Article 13 of the State
Constitution, regulates the District's ability to impose, increase, and extend taxes, assessments, and fees.
New, increased, or extended taxes, assessments, and fees are subject to the provisions of Proposition 218.
This decision was upheld and broadly interpreted to include water rates and charges in the recent court
decision of Bighorn-Desert View Water Agency vs. Virgil which states "an agency may not adopt a rate
increase if written protests against the proposed fee or charge are presented by a majority" of the affected
property owners. In addition, the District's ability to finance the services for which the taxes,
assessments, and fees are imposed in the future may be impaired. However, management believes it will
be able to maintain its current level of service due to slow development rate.
The Court found that the District's Mallo Pass I Alternative Water Supply Assessment ended in 2009
when the Mallo Pass permit was rescinded. The entire fund was ordered by the Court to be refunded to
all landowners in the District. The District is appealing the judgement, but anticipates returning the full
funding. Total legal expenses paid out of the Mallo Pass I Alternative Water Supply Assessment of
$80,810 that were not allowed by the court ruling were paid back out of operating cash.
Continued Litigation
In addition to the above, additional combined actions by the same plaintiff have been brought against the
District for (1) inverse condemnation, (2) various allegations surrounding alleged violations of a 2002
settlement agreement and (3) deficiencies in the District' s share of road maintenance fees. On August 18,
2014, the trial for inverse condemnation was held and the District was found liable for $401,000 in
damages. The District has appealed, and the Plaintiffs are currently seeking approximately $734,000 in
attorney' s fees and costs. The District presently believes there is a good likelihood of prevailing on
appeal.
The third phase of this trial was completed in 2016. In this third phase of trial, Plaintiffs alleged the
invalidity of certain of the District's assessments, seek damages for alleged road maintenance issues, and
allege the District breached a 2002 Settlement Agreement between the parties. The trial resulted in an
award of breach of contract against the District for $133,649. The Court also ordered various refunds of
the District's Proposition 218 assessment funds totaling an amount greater than $2,000 in the aggregate.
This judgement has also been appealed.
To date the District has incurred over $695,000 in legal fees on these and other issues. Legal fees for the
years ended September 30, 2022 and 2021 were $65,699 and $31,399, respectively. The ultimate
outcome of this litigation cannot presently be determined. Judgements are being appealed. Accordingly,
adjustments, if any, that might result from the resolution of these matters have not been reflected in these
financial statements .
17
IRISH BEACH WATER DISTRICT
NOTES TO FINANCIAL STATEMENTS
SEPTEMBER 30, 2022 and 2021
NOTE 6 COVID-19
In March 2020, the World Health Organization declared the outbreak of the novel coronavirus, COVID-
19, a pandemic. The spread of COVID-19, and the resulting work and travel restrictions, have not
negatively impacted the District from its primary business of supplying water to local residences and
businesses within its jurisdiction.
NOTE 7 SUBSEQUENT EVENTS
Management has evaluated subsequent events through November 4, 2024, which is the date the financial
statements were available to be issued. No material subsequent events have occurred since
September 30, 2022 that would require recognition or disclosure in the financial statements.
18