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<br />expressed in regard to possible impacts on farm workers and businesses providing <br />supplies and services to agriculture. <br /> <br />The recommendation to the District's board is that no particular measures be <br />implemented to address possible impacts on non-parties to the interruptible supply <br />contracts. One reason for this is that it is not clear that the District has the legal power <br />to act on behalf of third parties by interfering in allottees' private business transactions <br />beyond that degree of intervention necessary to protect Project operations for the benefit <br />of all allottees. <br /> <br />Also, the use of interruptible supply contracts should be viewed in the larger <br />context pertaining in the District. There is an active market of long standing in both <br />permanent transfers and annual leasing of C-BT units. These transactions are negotiated <br />by the parties without District involvement; the District's policy is not to interfere with <br />private decisions regarding the use or rental of C-BT water as long as such use or rental <br />complies with applicable law, contracts, and the District's rules, regulations and policies. <br />In the case of an annual rental, the parties simply notify the District of the lease so it can <br />be entered into the District's records. Even permanent transfers entail a relatively low <br />level of District review, which examines transferability, justification of need for the <br />purchase, and general compliance with the District's rules, regulations and policies. <br />Impacts on non-parties to the contract are not considered by the District in connection <br />with those types of transfer; there appear to be no grounds for subjecting the parties to <br />an interruptible supply agreement to limitations connected with third-party impacts that <br />are not imposed on parties to other transfers. <br /> <br />Another point to keep in mind is that some Windy Gap participants own C-BT <br />units which they can use as back-up supply to support in-lieu deliveries. These units may <br />be leased out through the annual rental market in most years. If they were called in to <br />repay an in-lieu debt, the water would be withdrawn from the rental market for that year, <br />just as would be the case if the units were called in pursuant to an interruptible contract. <br />The fact that the units would be transferred pursuant to an interruptible arrangement <br />does not appear to call for any additional restriction on the change. <br /> <br />Continuing public involvement efforts <br /> <br />Although the formal public involvement phase that was part of this study has <br />ended, the District should consider ongoing public information efforts in connection with <br />the use of interruptible supply contracts. As noted earlier in this report, there continues <br />to be misunderstanding and lack of knowledge as to the use and operation of these <br />agreements. Continuing educational efforts to clarify the nature of interruptible <br />arrangements will help to increase the level of acceptance of using such arrangements as <br />one of the water supply options in the region. In addition, it is crucial to the successful <br />implementation of any new concept that people feel that they are being kept informed <br />about what's going on and that there is no attempt on the part of the District to docsomething without their knowledge and consent. <br /> <br />25 <br />