Ferguson

I concur, but in doing so I wish to point out that the water project was in a preliminary stage of development when the 1965-1966 assessment was made on the basis of a single district and no property was directly benefited during that period. Evidence before the board that the intangible benefits derived from the fact the project was under construction inured to the entire district is sufficient to support the creation of a single zone for tax purposes. In future years this may not be true and, since the creation of “zones of benefit” occurs annually, there is nothing to preclude a distinction in the future between various areas of the district according to the benefits as defined in the act.

The authorities cited in the opinion to support the conclusion that the term “zone” as used in the act means “geographical area” seem to be conclusive on this point. It is true, as appellants point out, that if the criteria for determining benefits as delineated- by the statute are applied geographically, an injustice results to some property owners. For example, in an agricultural area the owner of farm property would probably benefit under all of the criteria, while an owner of oil and gas…

Kern County Water Agency was established by an act of the Legislature in 1961 (Stats. 1961, ch. 1003, p. 2651; West’s Ann. Water Code App. 1959 Supp., 1966 Cum. Pocket Part, p. 89 [Deering’s Wat. Code, Uncodified Acts, Act 9098.]); by its terms the Agency in extent covered the entire area of the county.

The Agency was created to enable it to acquire a supplemental water supply for its member units; the act prescribed the powers and duties of the Agency, and provided in detail for its organization, operation and management; authorized the acquisition of property to carry out the purposes of the Agency; authorized the incurrence of indebtedness; pro *910 vided for the issuance of bonds and for the levy and collection of taxes and the payment of any indebtedness contracted by it, including general agency expenses, as well as cooperating in satisfying contracts with any other entity. By vote of the electors within the area of the Agency its formation was approved.

After its creation, the Agency contracted with the State Department of Water Resources for the purchase of Feather River water to be delivered by means of the California Aqueduct now under construction. In connection with…