The original February 26, 1990 application and February 27, 1990 permit list 44135 Perryman Lane, APN 571-030-037 as the well location. An amended version of the same application — bearing the same permit number CK#397/16245 — substitutes 44100 Ginger Circle and APN 571-040-001. Both versions carry the same permit number. They cannot both be the original, valid permit for the same well. Additionally, the amended application shows APN 571-040-001 — still not Reed's APN of 571-040-002.
Best Best & Krieger's Exhibit C, submitted June 22, 2016 as the permit for the subject well, shows APN 541-040-002. Reed's actual APN is 571-040-002. "541" and "571" cannot both be the correct APN for the same parcel. The Lynch invoice submitted as Exhibit D also shows APN 541-040-002-0.
The Lynch Well invoice (BB&K Exhibit D, April 23, 1990) specifies drilling to 400 feet with a 7-inch diameter bore. The State DWR Well Drillers Report under Permit 16245 shows the well completed to 600 feet. A well cannot be simultaneously 400 feet and 600 feet deep. One document is incorrect, or they describe different wells.
Ordinance 682 voids a permit if work is not completed within 6 months of issuance. Permit 16245 was issued February 27, 1990. The Well Drillers Report shows work started approximately April 1990 and was completed December 5, 1990 — approximately 9 months and 6 days after issuance. Work was still ongoing at the 6-month mark (approximately August 27, 1990). Under Ordinance 682's own terms, the permit became void before the well was complete. DEH inspections from 2011 onward treat a permit derived from this sequence as valid authority for the water system. Both cannot be correct.
Ordinance 682 Section 3 requires a permit before well commencement. Drilling at 44100 Benton Rd. commenced May 1, 1990. The 1990 Original Well Permit Application is dated after that date. The permit-first requirement and the after-commencement application sequence cannot both comply with Ordinance 682.
DEH inspection reports for State ID #1790 from 2011–2024 record the inspected address as 44135 Perryman Lane, APN 571-040-004. The subject property is 44100 Ginger Circle, APN 571-040-002. Two different parcels cannot simultaneously be the correct address for the same permitted water system. Ryan Olney confirmed the error in writing on December 20, 2023.
The 2024 DEH final inspection references "Permit #29371." The County permit number on file is #16245. WP0029371 in the state system cross-references to EH16245 — so these likely refer to the same underlying permit under different numbering systems. However, this cross-reference was not previously documented and the 2024 inspection report does not explain it.
The May 24, 1990 Campbell Grant of Easement (Document #191167) names specific individual grantees — not "Weber Valley Heights Water Association." BB&K's June 22, 2016 letter claims the easement runs in favor of the Association and that "the Association is the owner of the well." An easement cannot simultaneously name only individual grantees while also running in favor of an association not mentioned in the instrument.
The November 19, 1990 mechanics lien claims January 1990 as the date of service. Well drilling did not commence until May 1, 1990. A service date of January 1990 for work on a well not yet started is contradicted by the commencement record.
The California Secretary of State (July 2014) has no record of WVHWA as any entity. The Riverside County Clerk (August 2016) found no FBN filing for WVHWA from 1972 to 2016. Yet State ID #1790 is an active operating permit. A water system permit cannot be validly held by an entity that has no verifiable legal existence in either state or county records.