Yamamoto Farms

July 16, 2018

Board of Directors Fox Canyon Groundwater Management Agency 800 South Victoria Avenue Ventura, Ca. 93009-1610 c/o Ms. Keely Rayas via email: keely.royas@ventura.org

RECEIVED JUL 16 2018

POX CANYON GROUNDWATER MANA GEMENT AGENCY

Re: Baseline Period Determination and OPV Allocation Workshop

To the Board of Directors,

The purpose of this letter is to express our objection to the June 20, 2018 Baseline Period Allocation System (the "BPAS") proposed for Oxnard and Pleasant Valley Basins (the "OPV Basin"). lo_particular, the BP,£1.S_pt_oposal to create new allo_cations on existing wells will r_esult in our ranch essentially receiv ing zero water allocation. This re-allocation effect ively removes all water rights from us in a manner that is both unfair and illegal. The Fox Canyon Groundwater Management Agency (the "FCGMA") should instead be focusing its efforts in the implementation of a land-based allocation system that fairly and legally allocates water to all agricultural water users in the OPV Basin.

My family owns three parcels comprising 168 acres of farm land (located on Wood Road in the Oxnard plains) and has been farming in the area for more than half a century. We believe we have been good stewards of local farming resources and strong members of a very important community and industry. We have tried to be consistent in our approach and are proud ofthe contributions we have made to the local community.

We currently lease our ranch to a local farming company. Irrigation water for our ranch is supplied mostly by the Pleasant Valley County Water District ("PVCWD"). Our tenant farms a rotat ion of vegetable crops continuously throughout the year - much like the farming that occurs on neighboring properties. However, the BPAS will treat our ranch very differently than our neighbors. While they will get a full allocation of water rights for all the water applied to their ranch (because if came from a well), the BPAS will allocate no water to our ranch because our ranch applied PVCWD water. In other words, the BPAS will result in two ranches with similar app lied water rates ending up with completely opposite allocations - one would have a 100% allocation for applied water and the other would have a 0% allocation for applied water. Not only does thi s approach make no sense, it is patently unfair.

5884 Mulberry Ridge/ Camarillo/ California/ 93012 310.779.4678

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California law states that property owners are entitled to the reasonable and beneficial use of groundwater. This right does not go away nor can it be regulated away by the FCGMA. However, the BPAS will in effect do just that: it will take away our water rights by allocating the entire safe yield in the OPV Basin to other water users while leaving us with no allocation. This violates all doctrines of fairness. It is also an illegal taking of our water rights.

We were encouraged to use PVCWD water for various reasons including the fact PVCWD has access to surface water. Therefore, the water applied to our ranch would not be all pumped water; thereby, helping the OPV Basin be more sustainable for the long term. This form of conjunctive water use has long been part of the history of farming in Ventura County. Further, conjunctive use of water has been favored by the FCGMA and is supported by California law. However, the BPAS does not provide for an allocation to our ranch even though California law requires that PVCWD water be treated as equivalent to pumped water. Therefore, the BPAS must be rejected.

In addition, the SPAS will have a major effect on land values. Immediately upon passing the SPAS, our ranch (with a 0% allocation) will be worth considerably less than our neighbor's ranch (which will get a 100% allocation). What is a ranch with no water allocation worth? Surely, it is worth much, much less than a ranch with a 100% water allocation. This type of significant alteration of land values to benefit some and hurt others is a not a fair result. Clearly, the FCGMA shou ld be able to come up with an allocation plan that avoids this type of inequity. The SPAS will result in major winners and major losers. Those who get a 100% allocation for applied water will achieve a huge financial gain in both the value of their land and the operational opportunities for their ranches (apparently, they will even be allowed to sell their water allocation to others). Those of us who get a 0% allocation for applied water will be

. stricken with huge financial hardships. Values will drop, rental income will diminish and banks may have to alter our loans. In short, the SPAS may well be the end of our ranch.

Please consider a more fair and legal allocation plan.

Very truly yours,

GJ~a~'1:-Land Owner Yamamoto Farms

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