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MUNICIPAL SERVICE REVIEW AND SPHERE OF INFLUENCE UPDATE FOR THE: TURLOCK IRRIGATION DISTRICT Prepared By: Stanislaus Local Agency Formation Commission 1010 Tenth Street, Third Floor Modesto, CA 95354 Phone: (209) 525-7660 Adopted: September 28, 2022 STANISLAUS LOCAL AGENCY FORMATION COMMISSION COMMISSIONERS Vito Chiesa, County Member Terry Withrow, County Member (Chair) Mani Grewal, Alternate County Member Amy Bublak, City Member Richard O’Brien, City Member (Vice Chair) Javier Lopez, Alternate City Member Ken Lane, Public Member Bill Berryhill, Alternate Public Member STAFF Sara Lytle-Pinhey, Executive Officer Javier Camarena, Assistant Executive Officer Rob Taro, Commission Counsel Jennifer Vieira, Commission Clerk TABLE OF CONTENTS Introduction ..........................................................................................................1 Service Review Factors ...................................................................................................1 Sphere of Influence Update Process ............................................................................... 2 Service Review – Turlock Irrigation District ......................................................3 Authority ..........................................................................................................................3 Background .....................................................................................................................3 Purpose ...........................................................................................................................3 Governance .....................................................................................................................3 Formation ........................................................................................................................4 Location and Size ............................................................................................................4 Sphere of Influence .........................................................................................................4 Personnel ........................................................................................................................4 Classification of Services ................................................................................................. 4 Mission Statement ...........................................................................................................6 Partnership Agencies ......................................................................................................6 Funding Sources .............................................................................................................7 Service Review Determinations .........................................................................................8 Growth and Population Projections .................................................................................. 8 Location and Characteristics of Disadvantaged, Unincorporated Communities ............... 8 Present and Planned Capacity of Public Facilities, Adequacy of Public Services ............ 8 Financial Ability of Agencies to Provide Services ............................................................. 9 Status of, and Opportunities for, Shared Facilities ........................................................... 9 Accountability for Community Service Needs .................................................................. 9 Any Other Matter Related to Effective or Efficient Service Delivery ............................... 10 Sphere of Influence Update – Turlock Irrigation District ............................... 11 Sphere Determinations ..................................................................................................... 11 Present and Planned Land Uses ................................................................................... 11 Present and Probable Need for Public Facilities and Services ....................................... 12 Present Capacity of Public Facilities and Adequacy of Public Services ......................... 12 Communities of Interest in the Area ............................................................................... 12 Need for Facilities and Services in Disadvantaged Unincorporated Communities ......... 12 Turlock Irrigation District Summary Profile .......................................................................... 13 Map 1: Turlock Irrigation District Boundary & SOI .............................................................. 14 Map 2: Turlock Irrigation District Electrical Service Area ................................................... 15 Appendix B: References ........................................................................................................ 16 This page left blank intentionally. Municipal Service Review and Sphere of Influence Update For the Turlock Irrigation District Introduction The Cortese/Knox/Hertzberg Local Government Reorganization Act of 2000 Act (CKH Act) requires the Local Agency Formation Commission (LAFCO) to update the Spheres of Influence (SOI) for all applicable jurisdictions in the County. A Sphere of Influence is defined by Government Code 56076 as “a plan for the probable physical boundary and service area of a local agency, as determined by the Commission.” The Act further requires that a Municipal Service Review (MSR) be conducted prior to or, in conjunction with, the update of a Sphere of Influence (SOI). The legislative authority for conducting Service Reviews is provided in Government Code §56430 of the CKH Act. The Act states, that “in order to prepare and to update spheres of influence in accordance with §56425, the commission shall conduct a service review of the municipal services provided in the county or other appropriate area...” A Service Review must have written determinations that address the following factors: Service Review Factors to be Addressed 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 This Service Review will analyze the Turlock Irrigation District. The most recent Sphere of Influence (SOI) update for the Turlock Irrigation District was adopted in 2011 and proposed no changes to the District’s SOI. The current update serves to comply with Government Code Section 56425 and will reaffirm the SOI for the District. MSR & SOI Update – Turlock Irrigation District Page 1 Sphere of Influence Update Process A special district is a government agency that is required to have an adopted and updated Sphere of Influence. Section 56425(g) of the CKH Act calls for Spheres of Influence to be reviewed and updated every five years, as necessary. Stanislaus LAFCO processes the Service Review and Sphere of Influence Updates concurrently to ensure efficient use of resources. For rural special districts, which do not have the typical municipal level services to review, this Service Review will be used to determine what type of services each district is expected to provide and the extent to which they are actually able to do so. The Sphere of Influence will delineate the service capability and expansion capacity of the agency, if applicable. MSR & SOI Update – Turlock Irrigation District Page 2 Service Review – Turlock Irrigation District Authority The Turlock Irrigation District was organized under the provisions of the California Irrigation District Law (Division 11 of the Water Code, §20500 et. seq). In addition, the District is a “registered voter district”, as registered voters elect the board of directors from five geographical divisions within the District’s boundaries. Background Throughout the years, water and California have been linked. No resource is more vital to California than water, from the agricultural areas, urban centers, and industrial plants, to open space and recreational areas, the distribution of water has been critical to all land uses. In California, there are hundreds of special water districts with a great diversity of purposes, governance structures, and financing mechanisms. Some districts are responsible for one type of specific duty, while other districts provide multiple public services, as is the case for the Turlock Irrigation District. Purpose The specific powers that an irrigation district may exercise include: supply water for beneficial purposes; provide for any and all drainage made necessary by the irrigation provided for and by the district; purchase or lease electric power and provide for the acquisition, operation, and control of plants for the generation, transmission, and provision of electric power; provide, maintain and operate flood control works in districts having 200,000 acres or more; reclaim waste for beneficial use; sewage disposal if provided by majority at election; construct, maintain, and operate recreational facilities in connection with dams, reservoirs, or other work owned and constructed by the district. Water Code §22120 allows a district to sell, dispose of, and distribute electric power for use outside its boundaries. Irrigation districts that offered electric services to retail customers as of January 1, 1999, may not construct, lease, acquire, install, or operate facilities for the distribution or transmission of electricity to retail customers located in the service territory of an electrical corporation providing electric distribution services, unless the district has first applied for and received approval of the Public Utilities Commission (Public Utilities Code Section 9607). Governance A five member Board of Directors governs the District. Registered voters within a geographical area or “Division” of the District’s boundaries, elect the board members. Meetings are held every Tuesday at 9 a.m. in the District’s administrative office located at 333 E. Canal, Turlock, CA 95380. The District has established a website (www.tid.org), which is user-friendly and provides information such as: district news, services, education, board agendas, rates and fees, and annual reports. MSR & SOI Update – Turlock Irrigation District Page 3 Formation The Turlock Irrigation District (TID) was formed on June 6, 1887, and was the first special district to be formed in the State of California. Location and Size The District’s boundaries are comprised of approximately 196,499 acres the majority of which is located in southern Stanislaus County. A portion of the District is also located in northern Merced County, just north of the Merced River. The District also includes an electric service area of 423,500 acres. The District maintains approximately 250 miles of canals, which are operated on a gravity flow system. Sphere of Influence The District’s adopted Sphere of Influence (SOI) is somewhat larger than its boundaries, and reflects expansion areas for irrigation service (see Map 1, attached). The cities of Ceres, Hughson, Turlock, and a portion of the city of Modesto, as well as the unincorporated communities of Denair, Hickman, and Keyes are located within the District’s Sphere of Influence boundary. The District’s Sphere of Influence also reaches into several unincorporated communities in Merced County (e.g., Ballico, Delhi, and Hilmar). When the 1984 Sphere of Influence was adopted for the Turlock Irrigation District, two separate spheres were considered, one for irrigation and one for electricity. However, since the District did not need LAFCO approval for changes in its electrical service area, only a sphere of influence for irrigation services was adopted. The laws governing an irrigation district allow a district to provide electric power outside its boundaries. A map of the District’s electrical service area is attached for illustrative purposes (See Map 2). Personnel The District currently has 456 employees. Classification of Services As part of this service review, the District has provided a listing of the services provided within its boundaries. The District is authorized to provide the functions or classes of services (e.g. irrigation, domestic water, and electrical power) as identified in this report. Due to recent changes in the Cortese-Knox-Hertzberg Act, the District would have to seek LAFCO approval to exercise other latent powers (services) not currently provided. Water Resources and Delivery Since 1900, the Turlock Irrigation District has been diverting water from the Tuolumne River for delivery through a system of gravity-fed canals and laterals. The majority of the District’s water supply is derived from the spring snowmelt that flows into the Tuolumne River watershed and then impounded annually at the Don Pedro Reservoir. The District’s major source for storing irrigation water is Don Pedro Reservoir, located in the Sierra Nevada foothills. The District also meets its growers’ water needs by supplementing surface supplies with groundwater. MSR & SOI Update – Turlock Irrigation District Page 4 Irrigation Water The District maintains approximately 250 miles of canals and laterals in its service area, which serves nearly 7,500 parcels with irrigation water, and covering nearly 150,000 acres of farmland in Stanislaus and Merced counties. Each year, the district sets a water allotment for growers, based on anticipated runoff in the Tuolumne River watershed. The irrigation water season is for the duration of the “growing season” that traditionally runs from mid-March through mid-October, though weather conditions often change the start and finish dates. Although most of the land within TID is flood irrigated, the District also serves the needs of growers with drip and micro irrigation systems. Domestic Water The District, under an agreement dating back to 1921, provides water for domestic use in the unincorporated community of La Grange, which is located outside its irrigation service area boundary. The La Grange domestic water system is co-owned by TID and the Modesto Irrigation District, and serves approximately 68 connections. TID operates and maintains the water system. Electric Generation, Transmission, and Distribution TID owns and operates an electric system, which includes generation, transmission, and distribution facilities. Its generating facilities include hydroelectric, wind, gas-fired, and other facilities. The District currently has over 2,300 miles of distribution lines, which stretch from the Sierra Nevada foothills to the Santa Clara County line between the Tuolumne and Merced rivers. TID also purchases power and transmission service from other sources and participates in other utility arrangements. In December 2003, upon approval by the California Public Utilities Commission, the District began to provide electrical power to an approximate 237 square-mile service area in western Stanislaus County. The new service area includes the City of Patterson and the unincorporated communities of Crows Landing and Diablo Grande. This area was previously served by Pacific Gas & Electric (PG&E). The District currently supplies electricity to a population of approximately 240,000 within a 662 square-mile electric service area. The District also sells surplus energy on the open energy market. Don Pedro Dam In 1923, the District, in partnership with the Modesto Irrigation District (MID), constructed the original Don Pedro Dam and powerhouse. The ownership of the project was based upon the geographic size of the two districts. TID is the operating partner and owns 68.46% of the project. In 1971, a new larger Don Pedro Dam was completed, which inundated the original dam and enlarged the reservoir’s capacity seven times. The new powerhouse increased hydroelectric generation by nearly the same amount. Lake Don Pedro and Turlock Lake, which are a part of the District’s irrigation system, also serve as popular recreation areas for boaters, campers, anglers and water skiers. MSR & SOI Update – Turlock Irrigation District Page 5 The current Federal Energy Regulatory Commission (FERC) license for the Don Pedro Project expired in 2016. The Districts have been actively engaging in relicensing efforts since 2009 and will continue to operate under an annual license until a new license is issued by FERC. Projects The District has completed numerous projects to enhance and diversify its power supply, including completion of a fuel cell plant, the Walnut Energy Center, Westley Substation and Transmission Line, the Tuolumne Wind Project, the Almond 2 Power Plant, and the Hughson- Grayson 115kV Transmission Line and Substation Project. In 2015 the Lateral 8 Regulating Reservoir Project was completed. The reservoir captures, stores, and releases water into TID’s irrigation system. Other TID Services/Programs In accordance with state law, the District devotes a percentage of their electric revenue on public benefit programs, such as energy efficiency and conservation, low-income assistance, and public education and outreach. Assistance Programs: TID offers multiple assistance programs for low income and other qualifying customers. These programs include TID Cares, which offers reduced rates of up to a 15% for residential customers on fixed or low incomes, Medical Rate Assistance, Budget Billing, and a Weatherization Program. Energy Efficiency Program: The District offers cash rebates to residents and businesses that install energy efficient equipment within the District’s electrical service area. Qualifying equipment must be “energy-efficient rated” such as: clothes washers, refrigerators, air conditioners (room and central), whole house fans, window sunscreens and/or awnings. Public Education Programs: The District sponsors education programs relating to water safety (using a mascot named “Dexter Duck”), electrical safety, and energy efficiency. This includes presentations at local schools, community events, and a variety of publications. Mission Statement TID will provide reliable and competitively priced water and electric service, while being good stewards of our resources and providing a high level of customer satisfaction. Partnership Agencies The District maintains positive and collaborative relationships with other agencies, such as: the cities of Ceres, Hughson, Modesto, Patterson, and Turlock; Stanislaus and Merced Counties; the Merced, Modesto, Patterson, and South San Joaquin Irrigation Districts; Friends of the Tuolumne, San Joaquin Valley Air Pollution Control Board, San Joaquin River Group, Department of Water Resources, State Water Resources Control Board, Association of California Water Agencies (ACWA), California Energy Commission, California Public Utilities Commission, California Municipal Utilities Association, Transmission Agency of Northern California, Northern California Power Agency, and the Federal Energy Regulatory Commission. MSR & SOI Update – Turlock Irrigation District Page 6 Funding Sources The District’s source of revenue is derived from the following sources: retail and wholesale power sales (residential, commercial, and industrial), irrigation water, domestic water, interest earnings, other income including improvement district fees and customer fees. The District receives a very small share of the County property tax revenues. MSR & SOI Update – Turlock Irrigation District Page 7 Service Review Determinations: The following provides an analysis of the seven categories or components required by §56430 for a Service Review for the Turlock Irrigation District: 1. Growth and population projections for the affected area The District currently serves approximately 4,700 customers with irrigation water for agricultural purposes (covering approximately 150,000 acres of farmland) and 68 retail customers in La Grange with domestic water for residential purposes. The District also provides full electric service to a population of approximately 240,000. TID forecasts electricity demand for both number of customers and energy use. A number of customer conservation programs are utilized in order to promote efficient energy use. 2. The location and characteristics of any disadvantaged, unincorporated communities within or contiguous to the sphere of influence. Based on annual median household income, there are several areas identified as Disadvantaged Unincorporated Communities (DUCs) as defined in Section 56033.5 of the Cortese-Knox-Hertzberg Act of 2000. These communities include the town of Keyes, Cowan Tract, Monterey Park Tract, and the Parklawn, Shackelford, and Bystrum Neighborhoods. No additional DUCs have been identified within the District’s sphere of influence. There are several DUCs adjacent to the District’s boundaries. However, those areas are located within the Modesto Irrigation District’s boundaries. 3. Present and planned capacity of public facilities, adequacy of public services, and including 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. The District manages and operates 250 miles of canals and laterals channeling irrigation water to more than 1,660 miles of community and privately owned ditches and pipelines serving 150,000 acres. Nearly 90 percent of the District’s canals and laterals are concrete lined. The District continues to budget for various water operations improvement projects, including rehabilitation of the existing canal system (gunite resurfacing) over the next several years. With regards to electrical service, the District has prepared Electric Capital Plans, which were created to identify required capital projects, including available resources over a multi- year time period (5 to 10 years). The District also prepares electric resource plans to determine the most efficient and cost effective strategy to meet increasing electric demand. These plans are intended to assist TID in meeting its goal “to create maximum value for those we serve” by helping to keep the planned projects aligned to TID’s long-term vision and strategies. TID is not a provider of sewer, municipal water, or fire protection services to the areas previously identified as Disadvantaged Unincorporated Communities (DUCs) within or contiguous to its Sphere of Influence (SOI). MSR & SOI Update – Turlock Irrigation District Page 8 4. Financial ability of agencies to provide services The District’s overall annual budget process is designed to screen out unnecessary costs and is submitted to the Board of Directors for review and approval. Rates and charges for services are adjusted periodically based on a cost of service methodology. The District also participates in a variety of joint agency practices, which maximize cost avoidance opportunities (e.g., San Joaquin River Group, Don Pedro Recreation Agency, Walnut Energy Center Authority, Westside Power Authority, Northwest Public Power Agency, Transmission Agency of Northern California, Northern California Power Agency, and American Public Power Association). Overall, at the present time, the District appears to be in good financial shape and has the necessary resources to fund service to its customers. 5. Status of, and opportunities for, shared facilities The District has many jointly owned facilities with other public agencies and also participates in many joint powers agencies (JPAs) including:  Don Pedro Dam and Reservoir (68.46% TID, 31.54% MID).  Don Pedro Power Plant (68.46% TID, 31.54% MID).  La Grange Reservoir (50% TID, 50% MID).  Walnut Energy Center Authority (JPA with Merced County).  Westley-Parker-Walnut 230kV transmission line (50% TID, 50% MID).  Westley-Tracy 230kV substation original facilities (50% TID, 50% MID). In 2015 TID and the Stanislaus Regional Water Authority (SRWA), a Joint Powers Authority that includes the Cities of Turlock and Ceres, approved an agreement allowing TID to sell/ transfer Tuolumne River surface water (“Transfer Water”) to SRWA. In less than normal irrigation water years, SRWA would provide “Offset Water” to TID, which would be a mix of recycled water and non-potable well water. This Offset Water is to balance the reduced Tuolumne River water available to TID irrigators that comes as a result of the surface water transfer to SRWA. The agreement has a 50-year term, is limited to a maximum of 30,000 acre-feet of Transfer Water to SRWA per year, and will be priced at TID’s Tier 4 Irrigation Water rate. The SRWA is currently constructing a water treatment plant to service Turlock and Ceres for domestic water use that is expected to be completed in 2023. 6. Accountability for community service needs, including governmental structure and operational efficiencies A five member Board of Directors governs the District. Registered voters within a geographical area or “Division” of the District’s boundaries, elect the board members. The Board conforms to the provisions of the Brown Act requiring open meetings. The District maintains a website (www.tid.org) which provides information such as the history of the District, news, rates and consumer information. MSR & SOI Update – Turlock Irrigation District Page 9 The District has the necessary resources and staffing levels to operate in a cost-efficient and professional manner. It is reasonable to conclude that the District has the organizational capability to adequately serve the areas under its jurisdiction. 7. Any other matter related to effective or efficient service delivery, as required by commission policy Recent years have been severe and record breaking dry years for California. Due to such dry conditions, TID is operating in a conservative manner during the irrigation season. TID has implemented special water conservation rules to help utilize irrigation water as efficiently as possible. MSR & SOI Update – Turlock Irrigation District Page 10 Sphere of Influence Update for the Turlock Irrigation District In determining the Sphere of Influence (SOI) of each local agency, the Commission shall consider and prepare determinations with respect to each of the following factors pursuant to Government Code Section 56425: 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 they are relevant. 5. For an update of a sphere of influence of a city or special district that provides public facilities or services related to sewers, municipal and industrial water, or structural fire protection, the present and probable need for those public facilities and services of any disadvantaged unincorporated communities within the existing sphere of influence. This document proposes no changes to the District’s existing Sphere of Influence. Rather, it serves to reaffirm the existing SOI boundary. As part of this process, Staff researched the history of the establishment of the District’s SOI. A map of the current District boundary and Sphere of Influence is attached as Appendix “A”. The following determinations for the Turlock Irrigation District Sphere of Influence update are made in conformance with Government Code §56425 and Commission policy. Sphere Determinations: 1. The present and planned land uses in the area, including agricultural and open-space lands The land uses within the District boundaries (including its SOI) consist of agricultural, rural residential, suburban and urban land use areas. The District does not have the authority to make land use decisions, nor does it have authority over present or planned land uses within its boundaries. The responsibility for land use decisions within the District boundaries are retained by the cities of Ceres, Hughson, Modesto, and Turlock, and by Stanislaus and Merced Counties. Planned uses for the area are described in the general plans of the respective jurisdictions. MSR & SOI Update – Turlock Irrigation District Page 11 2. The present and probable need for public facilities and services in the area The District currently delivers irrigation water to approximately 7,500 parcels covering nearly 150,000 acres. The present and future public service needs within the District’s irrigation water boundaries are characteristic of agricultural areas. The types of public services needed in these areas are those which enhance the use of the land for agricultural purposes. Since 1923, the District has provided retail electric service and transmission services to the area. As a result of de-regulation, population growth, and energy demands, the present and probable need for these services are not expected to diminish. 3. The present capacity of public facilities and adequacy of public services that the agency provides, or is authorized to provide. Presently, the District has adequate capacity and/or plans to provide the necessary public facilities and services within its existing sphere of influence. For example, the District is budgeting funds to rehabilitate its canal system over the next several years. The District has also prepared Electric Capital Plans, which were created to identify required capital projects, including available resources over a multi-year time period (5 to 10 years). 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 following jurisdictions can be categorized as Communities of Interest in the area: the cities of Ceres, Hughson, Modesto (south of the Tuolumne River), and Turlock, and the unincorporated communities of Denair, Hickman, Keyes, and La Grange (in Stanislaus County), as well as, Hilmar, Delhi, and Ballico (in Merced County) 5. For an Update of a Sphere of Influence of a City or Special District That Provides Public Facilities or Services Related to Sewers, Municipal and Industrial Water, or Structural Fire Protection, the Present and Probable Need for Those Public Facilities and Services of Any Disadvantaged Unincorporated Communities Within the Existing Sphere of Influence There are several areas identified as disadvantaged unincorporated communities (DUCs) within the existing TID Sphere of Influence. These communities include the town of Keyes, Cowan Tract, Monterey Park Tract, and the Parklawn, Shackelford, and Bystrum Neighborhoods. No additional DUCs have been identified within the District’s sphere of influence. There are several DUCs adjacent to the District’s boundaries. However, those areas are located within the Modesto Irrigation District’s boundaries. Although the District provides a limited amount of domestic water service connections, the District’s water supply is mainly for irrigation use. The District does not provide services related to sewers or structural fire protection. MSR & SOI Update – Turlock Irrigation District Page 12 DISTRICT SUMMARY PROFILE District: TURLOCK IRRIGATION DISTRICT (TID) Formation: June 6, 1887 Location: The District’s boundary includes certain acreage between the San Joaquin and Tuolumne Rivers in Stanislaus County, and acreage north of the Merced River in Merced County. TID also has an electrical service area that extends beyond this boundary to the east and west, including approximately 662 square miles. Service Area: Irrigation: 196,499+/- acres (307 sq. miles) Electrical: 423,500+/- acres (662 sq. miles) Turlock Irrigation Customers: 4,780 irrigation accounts District 240,000 population served (electrical) Land Use: Agricultural, rural residential, suburban and urban District Services: Distribution of water for STANISLAUS irrigation and domestic COUNTY purposes, and provision of electricity Enabling Act: California Water Code, Division 11: Irrigation Districts, §20500-29978 Governing Body: Five Board of Directors, elected by the registered voters within five geographic divisions of the District’s boundaries Administration: 458 employees Budget: $403.1 Million (2022 Calendar Year) Revenue Sources: Retail and wholesale power sales, water sales, and County property tax appropriations MSR & SOI Update – Turlock Irrigation District Page 13 MSR & SOI Update – Turlock Irrigation District Page 14 :1 PAM TCIRTSID NOITAGIRRI KCOLRUT ECNEULFNI FO EREHPS DNA YRADNUOB MSR & SOI Update – Turlock Irrigation District Page 15 :2 PAM TCIRTSID NOITAGIRRI KCOLRUT AERA ECIVRES LACIRTCELE REFERENCES 1. Association of California Water Agencies (ACWA) (www.acwanet.com). 2. California Department of Water Resources (www.dwr.water.ca.gov). 3. California State Water Resources Control Board (www.swrcb.ca.gov). 4. Don Pedro Project Relicensing website (www.donpedro-relicensing.com) 5. Previous MSR/SOI Update for the Turlock Irrigation District, Adopted by Stanislaus LAFCO on April 26, 2017. 6. PricewaterhouseCoopers LLP, “Report of Independent Auditors”, April 16, 2010. 7. Stanislaus County Draft 2015-2023 Housing Element Update, April 2016. 8. Stanislaus Regional Water Authority (www.stanrwa.com) 9. State of California Legislative Analyst’s Office Report – “Water Special Districts: A Look at Governance and Public Participation, March 2002”. 10. Timothy J. Durbin, Inc., “Assessment of Future Groundwater Impacts Due to Assumed Water-Use Changes – Turlock Groundwater Basin, California”, September 11, 2008. 11. Turlock Groundwater Basin Association, “Groundwater Management Plan”, March 18, 2008. 12. Turlock Irrigation District website (www.tid.org). 13. U.S. Bureau of Reclamation (www.usbr.gov). MSR & SOI Update – Turlock Irrigation District Page 16