EXHIBIT 4
Figure 1 Figure 2 Figure 3
Table 1 Table 2 Table 3


MONTEREY PENINSULA WATER MANAGEMENT DISTRICT

MEMORANDUM

Date: October 20, 2000
To: Joe Oliver
From: Tom Lindberg

Subject: Update to May 1, 2000 Memo regarding Water Well Permit Tracking

The following paragraphs, tables and figures incorporate our latest information regarding the number of wells and well construction permits within the District, thereby updating the memo of May 1, 2000 on the same subject.

Since 1974, all property owners wishing to drill wells in Monterey County have been required to first obtain a permit from the Monterey County Health Department (MCHD), Division of Environmental Health. The MCHD maintains two offices, one in Salinas and one in Monterey. Beginning in 1981, copies of permits for wells known to be located within the boundaries of the Monterey Peninsula Water Management District (MPWMD) have been forwarded to the District. Table 1 summarizes all of the well construction permits received from MCHD between January 1, 1993 and October 18, 2000. The District categorizes well construction permits on the basis of their location within various production source areas of the District. The source areas are shown in Figure 1. For example, AS1, AS2, AS3 and AS4 represent the four aquifer subunits of the Carmel Valley Alluvial Aquifer (CVA). Of the total 406 permits received during this period, 90 were for wells located within the CVA (Table 1). The distribution of new well permits within and outside of the CVA is shown graphically in Figure 2. It should be noted, however, that Table 1 and Figure 2 refer only to permits for wells, not to wells actually completed and producing water. Therefore, these numbers can be misleading. Some of the other reasons that this information should be viewed with caution are discussed below.

In a typical year, a small number of well permits received may actually represent permits that were issued in an earlier year, but inadvertently were not forwarded to the District by MCHD. The worst case was in 1993, when 19 older permits were added to the District's list after it was discovered that permits in certain areas of the District had been issued out of the Monterey branch office of the Health Department without informing the District. On the other hand, in some years, 1996 for example, no older well permits were added to the District's list. Another note is that some of the permits issued in later years represent re-issues of permits that were granted in earlier years, but had expired (a permit to drill a well expires after one year). It should also be noted that property owners often obtain permits and subsequently drill wells that remain inactive (i.e., producing no water) for extended periods, often without having electrical power or a pump available at the well site. Accordingly, this may partially explain why the issuance of new well permits does not track closely with well production trends.

A better way of tracking the actual number of new wells producing water within the District is available from the "Annual Water Production Summary" reports, which document the amount of water produced by Cal-Am and non Cal-Am wells and diversions. Table 2 summarizes the number of active, non Cal-Am wells reporting production for the last eight Reporting Years (Reporting Years run from July 1 through June 30). This table shows that the number of wells reporting production has increased in each of the years, except 1995, with the largest increase occurring in 2000. There were 182 more wells reporting production in 2000 than in 1993. Although not shown in Table 2, there were 31 additional wells reported as "inactive" in 2000 compared to 1993. The overall number of reporting non Cal-Am wells (both active and inactive) has increased by 213 wells from 1993 to 2000.

Figure 3 presents the distribution of non Cal-Am water production categorized by Reporting Method for Reporting Years (RYs) 1986 through 2000. This figure contains several notable features. First, it can be seen that reported non Cal-Am water production had decreased over the RY 1986 to 1999 period, but has increased in 2000. It is surmised that the decrease between 1986 and 1999 is due largely to the effects of District Ordinance Nos. 48 and 56, which were first seen in the years following their implementation (i.e., RYs 1991 and 1993 respectively). Ordinance No. 48 required water meters on all "large" production wells (i.e., greater than 20 acre-feet per year). Ordinance No. 56 extended the water meter requirement to all new wells and "medium" production wells (i.e., greater than 5 acre-feet per year), and eliminated the "Power Consumption" reporting method, which tended to overestimate production. The District maintains that water meters form the most accurate and factual basis to measure well production. The combined effect of these ordinances and additional water saving efforts by several "large" pumpers, plus a more heightened awareness of the importance of water conservation, appears to be responsible for the decreases in reported production during this period. This is in spite of the documented increase in the number of wells reporting production from 1993 to 1999 (Table 2). The marked increase in the number of well permits issued since 1999 may be partially attributed to anticipated changes in District Rules (i.e., proposed Ordinance No. 96) that would require additional information and processing prior to approval of new well uses within certain areas of the District.

The second notable feature of Figure 3 is that the volume of water production reported by the "Land Use" reporting method has remained relatively constant over the last several years, while the amount of water reported by the "Water Meter" reporting method has fluctuated. The actual reported non Cal-Am production from each source area for RY 1993 through 2000 is shown on Table 3.

In summary, the total amount of calculated water production in any given year is, in part, a function of the amount of staff time and resources available to pursue cases where well owners or operators fail to respond to District requests for compliance with the reporting requirement. A more detailed discussion of historical production trends is available in Technical Memorandum 98-01, Review of MPWMD Annual Water Production Summaries: Reporting Years 1986 through 1997.


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