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HERUM CRABTREE SUNTAG <br /> Steven A.Herum <br /> sherum@herumcrabtree.com <br /> September 25, 2023 <br /> BY ELECTRONIC-MAIL <br /> Ms. Alexis K. Stevens <br /> 500 Capital Mall <br /> Suite 1000 <br /> Sacramento, California 95814 <br /> astevens@somachlaw.com <br /> Re: San Joaquin County Use Permit Application No. PA-2100238 (UP) <br /> Dear Ms. Stevens: <br /> This office represents the applicant for the above referenced use permit application, <br /> which involves a Constitutionally protected right to exercise religious freedom. <br /> I have reviewed the numerous and repetitive letters you have submitted to the County <br /> Community Development department regarding this proposal and have been asked to <br /> respond at this time. <br /> Each letter clearly indicates you are writing on behalf of two special districts created under <br /> California law: Naglee Burke Irrigation District and Reclamation District 1007 (Districts). <br /> Accordingly, each District is created under and subject to state enabling statutes providing <br /> narrow and specific powers and duties to special districts. <br /> However, the CEQA and land use claims presented in the Districts' letters are extremely <br /> broad and ambulatory. At no point is any effort expended to correlate these claim to the <br /> narrow and specific duties of the Districts granted by superior enabling statutes. <br /> A brief review of the powers granted to an irrigation district and a reclamation district by <br /> the relevant state enabling statute confirms the absence of a relationship between the <br /> claim presented and the powers and purpose of each district. <br /> Division 11 of the California Water Code specifies the powers granted to irrigation <br /> districts. Specifically, the Water Code makes clear an irrigation district may do any act <br /> necessary to furnish sufficient water in the district for any beneficial use (§22075) or any <br /> act in order to put to any beneficial use any water under its control (§22076). While the <br /> Water Code affords irrigation districts broader powers, Naglee Burke's website makes <br /> 5757 PACIFIC AVENUE SUITE 222 STOCKTON,CA 95207 PH 209.472.7700 <br />