"Mendocino's 2017 Wastewater CEQA: Why It Won't Meet 2030 California Standards"

David KIng

12/19/202517 min read

Why I Don't Like to Come to Town: Mendocino's Water and the Paradigm Shift

Life in Comptche: The Relationship of Ions

In Comptche, my work begins at the foundation of all life: the soil. Soil is a living system defined by the relationship of ions—calcium and magnesium balancing structure, sodium and potassium interacting with organic acids, and trace minerals coordinating with microbial metabolites. These ionic relationships build aggregation, porosity, and resilience, which in turn regulate water movement, nutrient availability, and microbial diversity. When I pay attention to ions, I see a coherent, measurable world where chemistry predicts biology, and biology confirms chemistry.

Sometimes I'm contracted to go to town. That's when the distance between what soil teaches and what institutions assume becomes stark. I observe, listen, and try to understand. But I keep returning to a simple truth: soil chemistry does not respond to narratives. It responds to ions, water, and measurable forces.

A Shocking Discovery in Mendocino: Reclaimed Water on the Bluff

While speaking to the Mendocino Unified School Board about child safety concerns, I learned reclaimed wastewater is slated for irrigation on sports fields above and within the town of Mendocino. Mendocino's households rely on shallow coastal wells in sandy bluff soils—an aquifer that is fast, exposed, and vulnerable. Large volumes of reclaimed water can disrupt ionic balances (particularly sodium displacing calcium), degrade soil structure, increase leaching of nitrate and other solutes, and accelerate transport of contaminants to the shallow aquifer.

Ionic displacement risk: Sodium-rich water disperses soil particles by replacing divalent cations (calcium/magnesium) on exchange sites, collapsing structure and increasing runoff, infiltration variability, and turbidity. This doesn't just impact water movement; it fundamentally degrades the soil's ability to support a healthy microbial community and cycle nutrients, leading to long-term ecological consequences that compound over years and decades.

Rapid leaching in sandy soils: High hydraulic conductivity moves nitrate, dissolved organic carbon (DOC), pathogens, and contaminants of emerging concern (CECs) quickly toward wells—especially under hydraulic mounding conditions.

Capture zone overlap: Irrigation above or near domestic wells raises the potential for direct capture of percolate into drinking water cones of depression.

Narrative assurances ("no significant impact expected") cannot manage these mechanisms. Only measurement, thresholds, and enforceable response protocols can.

Mendocino's CEQA: A Document Frozen in Time

In 2017, Mendocino's CEQA Environmental Report for wastewater expansion satisfied the standards of its day. It discussed construction impacts, biological resources, and conventional water quality concerns like nitrate, salinity, and pathogens. But the science—and the law—have since advanced. Against today's expectations, the record is incomplete.

Missing CECs assessment: No evaluation of pharmaceuticals, PFAS (per- and polyfluoroalkyl substances, known for their persistence and health concerns even at low levels), endocrine disruptors, microplastics, or advanced microbial indicators common in recycled water contexts.

No ionic/sodicity management plan: Absent analysis of sodium adsorption ratio (SAR), exchangeable sodium percentage (ESP), or measures to protect aggregation and permeability in sandy terrains.

Limited hydraulic analysis: No quantitative modeling of hydraulic mounding, residence times, capture zones, or transport pathways from irrigated fields to shallow domestic wells.

Monitoring gaps: Reliance on broad assurances rather than specific monitoring commitments, analyte lists, sampling frequencies, public reporting, and corrective-action triggers tied to thresholds.

Evolving precedent: Recent decisions and guidance increasingly reject vague "end-result" claims and favor measurable, enforceable monitoring and mitigation. CEQA practice now emphasizes substantial evidence built on specific, transparent data.

Bottom line: CEQA 2017 is a valid baseline, but it's not proficient against today's standards. Mendocino needs an addendum or supplemental review that reflects current science, risk pathways, and accountability.

What Reclaimed Water Often Contains—and Why It Matters Here

Reclaimed water quality varies with treatment train and source inputs. While Mendocino may be considering this option due to water scarcity or cost considerations, it's crucial to understand that the level of treatment (e.g., primary, secondary, tertiary, or advanced) dictates what contaminants remain. Even with advanced treatment, several classes of concern recur, and Mendocino's geology magnifies their risk.

Nutrients: Nitrate/Nitrite can exceed safe thresholds in shallow aquifers; rapid transport in sand increases exposure.

Salts and sodicity: Sodium and bicarbonate elevate SAR/ESP, dispersing structure and impairing infiltration; chloride can accumulate and affect plant/soil health.

Organic load: Dissolved organic carbon (DOC) modifies redox and can mobilize metals; it also affects disinfection by-products formation.

Pathogens: Even with advanced treatment, indicator organisms and viruses require rigorous monitoring, particularly where irrigation occurs above drinking water sources.

CECs: Pharmaceuticals, PFAS, endocrine disruptors, microplastics are persistent or poorly removed by conventional treatment; sandy soils and short travel times amplify risk to wells. These contaminants are concerning because they can have long-term health impacts even at very low concentrations.

In short: the bluff's shallow aquifer is a high-consequence receptor. If we choose irrigation above it, we must choose measurement worthy of the risk. The potential economic burden on residents, should their wells become contaminated, could be substantial, involving costly remediation or the need for alternative water sources, not to mention impacts on property values.

Quantitative Safeguards: What a Modern Protection Plan Should Require

A need for a credible science-based framework replaces narrative assurances, with measurable accountability. Here's what that looks like for Mendocino.

Advanced treatment verification: Proof of performance for PFAS, pharmaceuticals, viruses, and microplastics via method-appropriate lab analyses; document removal efficiencies and residuals.

Hydrogeologic modeling: Mounding and capture-zone analysis for irrigated areas relative to domestic wells; simulate seasonal irrigation volumes, storm events, and worst-case scenarios.

Soil chemistry protection: SAR/ESP tracking, calcium amendments where needed, and permeability/aggregation monitoring; avoid sodicity rise and structural collapse.

Sentinel monitoring wells: Nested wells upgradient/downgradient of sports fields with screened intervals aligned to shallow aquifer; define analyte panels, frequency (e.g., monthly, seasonal), and QA/QC.

Public reporting and transparency: Open data dashboards with methods, detection limits, raw data, and interpretation; publish trend analyses and trigger exceedances promptly.

Thresholds and corrective actions: Predefined action levels (e.g., nitrate, PFAS, pathogens, SAR) linked to immediate response: reduce irrigation, modify treatment, apply soil amendments, suspend use pending remediation.

Operating protocols: Irrigation timing/volume controls, storm bypass plans, backflow protections, and maintenance logs; integrate adaptive management tied to monitoring feedback.

If Mendocino can't commit to these safeguards, it shouldn't commit its drinking water source to reclaimed irrigation narratives.

The Paradigm Shift: From Narrative Compliance to Measurable Outcomes

We are living through a fundamental transformation in how environmental safety and agricultural quality are defined, verified, and regulated. For decades, the dominant paradigm relied on narrative compliance—following prescribed methods and trusting that outcomes would be acceptable. This model worked when industrial chemistry was simpler, when contaminant loads were lower, and when regulatory science had not yet revealed the full scope of risks we now understand.

The Old Paradigm: When Narratives Were Enough

In the past, certification systems like "Organic" represented the gold standard. If you followed the methods—avoided synthetic pesticides, used approved inputs, maintained buffer zones—you earned the label. The narrative was: follow these practices, and your product will be safe, nutritious, and environmentally sound. There was an implicit assumption that method compliance guaranteed outcome quality.

Similarly, wastewater treatment followed narrative pathways. If effluent met conventional parameters for BOD, TSS, and fecal coliform, it was deemed safe for discharge or reuse. The narrative was: tertiary treatment produces water suitable for irrigation. Monitoring focused on a narrow suite of parameters, and environmental reviews relied on generalized impact assessments.

This paradigm sufficed in an era when:

  • Contaminant chemistry was less complex

  • Detection limits were higher (parts per million rather than parts per billion or trillion)

  • Regulatory frameworks were still developing

  • The cumulative effects of persistent pollutants were not yet understood

  • Agricultural and municipal inputs had not yet introduced the vast array of synthetic compounds we see today

Why Narratives Are No Longer Sufficient

Today, we face a different reality. Advanced analytical chemistry can detect contaminants at parts per trillion. We now understand that PFAS persists in the environment for generations. We know that endocrine disruptors can affect biological systems at concentrations once thought irrelevant. We have documented pharmaceutical residues in groundwater beneath irrigated fields. We understand that microplastics accumulate in soils and organisms.

The narrative approach cannot address these realities because:

Detection has outpaced regulation: We can now measure contaminants that were invisible when our regulatory frameworks were designed. Many of these substances have no established safe thresholds, yet they are ubiquitous in reclaimed water and biosolids.

Method compliance does not guarantee outcome quality: A farm can be certified organic yet produce food with lower nutrient density than conventional operations. Wastewater can meet tertiary treatment standards yet contain pharmaceuticals, PFAS, and antibiotic-resistant bacteria.

Cumulative and synergistic effects are not captured by single-parameter compliance: Narrative frameworks evaluate contaminants in isolation. Real-world exposure involves mixtures, transformations, and interactions that cannot be predicted from individual compliance points.

Persistence and bioaccumulation were underestimated: Substances like PFAS, once promoted as safe, are now recognized as virtually indestructible in the environment. By the time harm is documented, contamination is widespread and irreversible.

The New Paradigm: Measurable Accountability

The shift we are living through—in agriculture, water management, and environmental regulation—moves from what you do to what you achieve. This is not merely a technical adjustment. It represents a philosophical realignment: from trust-based systems to evidence-based verification.

In agriculture: Regenerative certification now requires measurable improvements in soil organic matter, water infiltration, and nutrient density. Carbon credits demand verified sequestration with third-party monitoring. Climate-smart agriculture ties funding to documented reductions in greenhouse gas emissions and demonstrated increases in soil health metrics.

In water management: Aquifer recharge projects now require contaminant panels that include CECs, pathogen monitoring with molecular methods, and real-time public reporting. Permit conditions specify measurable limits rather than narrative assurances. Enforcement is tied to continuous data streams, not periodic inspections.

In environmental review: CEQA analysis increasingly requires quantitative modeling, transparent data sources, and enforceable mitigation tied to measurable thresholds. Vague claims of "no significant impact" are giving way to detailed analyses with statistical confidence intervals and uncertainty quantification.

California 2030: The Regulatory Inflection Point

California's agricultural and environmental landscape is approaching a transformative deadline. By 2030, the state will implement a suite of regulations that compress three decades of European climate-smart agriculture standards into less than a decade of adaptation time for California farmers and land managers.

The Governor's Executive Order and Its Implications

California has committed to achieving carbon neutrality by 2045, with aggressive interim targets for 2030. This commitment is not rhetorical—it is being translated into enforceable regulations that will fundamentally reshape how land is managed, how water is used, and how agricultural operations are verified.

Key regulatory pathways include:

Soil health verification: Farms participating in state programs must document baseline soil organic carbon, track changes over time, and demonstrate net sequestration or maintenance. This requires chemical analysis, not self-reporting.

Greenhouse gas accounting: Operations above certain thresholds must account for emissions from fertilizer use, tillage, livestock, and irrigation energy. Offset claims require third-party verification using standardized protocols.

Water use efficiency and quality protection: Agricultural water use will be tied to demonstrated efficiency improvements, with groundwater recharge and quality protection requirements that go beyond current Sustainable Groundwater Management Act (SGMA) baselines.

Nitrogen management: Building on existing frameworks, 2030 regulations will tighten nitrogen application limits, require real-time monitoring, and link compliance to demonstrated reductions in nitrate leaching to groundwater. I have clients with excess nitrogen in their soil from mismanagement of cover crops—no synthetic nitrogen was ever added. The narrative was: plant cover crops for soil health. The reality: without proper termination timing, species selection, and carbon-to-nitrogen ratio management, cover crops can create nitrate loading that exceeds what synthetic fertilizer would have contributed. When those cover crops decompose at the wrong time or in the wrong proportions, the nitrogen pulse leaches directly to groundwater. Method compliance (planting cover crops) does not guarantee outcome quality (groundwater protection). This is the paradigm problem in microcosm.

Biodiversity and ecosystem services: Habitat restoration, pollinator support, and riparian protection will shift from voluntary to required components of farm management plans for operations seeking state support or certification.

Why Small Farms Are on the Brink

These regulations represent a necessary evolution—climate change and environmental degradation demand accountability. But the transition timeline is brutally compressed for small operations that have been operating under the old narrative paradigm.

Most small farmers:

  • Lack capital for monitoring infrastructure

  • Do not have staff trained in soil chemistry, hydrogeology, or greenhouse gas accounting

  • Have been told for decades that "organic" or "sustainable" labels were sufficient

  • Are discovering that their soils, after years of inputs promoted as safe, are contaminated or depleted

  • Cannot afford third-party verification or the data systems required for compliance

The result is a pending extinction event. Farms that cannot adapt—financially, technically, or operationally—will not survive 2030. Land that fails to meet new standards will be taken out of production. Farmers who followed state-approved practices for decades will find themselves liable for contamination they did not cause and could not have detected without advanced testing.

Federal Alignment: The Inflation Reduction Act and Beyond

The federal government is reinforcing California's trajectory. The Inflation Reduction Act (IRA) and related legislation direct unprecedented funding toward climate-smart agriculture, but access to these funds is conditioned on measurable outcomes:

Climate-Smart Commodities: Producers must document greenhouse gas reductions, carbon sequestration, or water quality improvements using approved protocols and third-party verification.

Conservation program payments: USDA's Environmental Quality Incentives Program (EQIP) and Conservation Stewardship Program (CSP) are shifting from practice-based payments to outcome-based incentives. Farmers must demonstrate results, not just implement methods.

Renewable energy and carbon markets: Participation in voluntary carbon markets requires verified credits using standardized methodologies. Claims of sequestration without quantitative proof are increasingly subject to fraud liability.

This federal-state alignment creates a regulatory vise: farmers cannot escape outcome-based verification by crossing state lines or appealing to federal preemption. The paradigm shift is national, and it is irreversible.

The Timing Trap: Implementing Old Standards Into a New Regulatory Reality

Mendocino's reclaimed water project is scheduled to begin operations in approximately 18 months—realistically 2026 or early 2027 when accounting for typical delays. This timeline places the project in an extraordinarily vulnerable position: infrastructure designed and approved under 2017 narrative standards will go online just 3-4 years before California's 2030 regulatory framework takes full effect.

This is not a theoretical problem. Mendocino will begin irrigation based on the old paradigm and find itself immediately unprepared for the new one.

What This Means in Practice

Year 1 (2026-2027): Operation begins

  • System operates under 2017 CEQA assumptions

  • Monitoring focuses on conventional parameters (nitrate, salinity, basic pathogens)

  • No CEC panels, no parts-per-trillion sensitivity, no real-time public dashboards

  • Soil chemistry tracking likely absent or minimal

  • Narrative compliance: "tertiary treatment is sufficient"

Years 2-3 (2027-2029): Regulatory framework shifts

  • California tightens SGMA requirements with explicit groundwater quality components

  • Federal and state funding increasingly tied to measurable outcomes

  • PFAS regulations begin phasing in with actionable limits

  • Advanced monitoring becomes standard practice in water reuse projects statewide

  • Liability frameworks evolve as contamination cases (like Maine) reshape legal precedent

Year 4 (2030): Full compliance required

  • Climate-smart agriculture regulations in force

  • Greenhouse gas accounting mandatory for operations above thresholds

  • Water quality verification requires CEC monitoring and public reporting

  • Soil health metrics tied to state program participation

  • Narrative compliance no longer acceptable for environmental reviews or permits

The Infrastructure Mismatch

Here's the core problem: infrastructure built to 2017 standards cannot easily be retrofitted to meet 2030 requirements.

Treatment systems designed for conventional tertiary parameters do not necessarily remove PFAS, pharmaceuticals, or microplastics effectively. Adding advanced treatment (reverse osmosis, advanced oxidation, granular activated carbon with appropriate regeneration) after construction is exponentially more expensive than designing for it initially.

Monitoring well networks require strategic placement based on capture zone modeling and hydrogeologic analysis. Installing sentinel wells after irrigation begins means playing catch-up—trying to detect contamination that may already be moving toward domestic wells rather than preventing it from the start.

Soil amendments and calcium management to prevent sodicity-driven structural collapse need to be part of the initial operations plan. Addressing sodium displacement after soil structure has degraded requires years of remediation and may never fully restore the original calcium/magnesium balance that stabilizes Mendocino's sandy bluff soils.

The Financial Burden

Mendocino will face a cruel choice around 2028-2030:

Option 1: Retrofit the system to meet new standards

  • Add advanced treatment components: $500K - $2M+

  • Install comprehensive monitoring network: $100K - $300K

  • Implement real-time data systems and public dashboards: $50K - $100K

  • Conduct hydrogeologic modeling and capture zone analysis: $75K - $150K

  • Ongoing operational costs increase 30-50%

Option 2: Suspend operations until compliance can be achieved

  • Fields revert to non-reclaimed water sources (if available)

  • Stranded infrastructure investment

  • Community relations crisis

  • Potential regulatory enforcement

Option 3: Continue operations under inadequate safeguards

  • Groundwater contamination risk to shallow wells

  • Legal liability as new standards clarify what "reasonable care" requires

  • Potential health impacts to residents

  • Eventual forced shutdown with contamination already present

None of these options are good. All of them are expensive. All of them were avoidable.

The Comparison to Agriculture

Small farms face an identical trap. Many invested in "organic" certification and infrastructure based on 2010s standards. They followed approved practices, used permitted inputs, and trusted the narrative framework. Now, as 2030 approaches, they discover:

  • Their organic label does not exempt them from outcome-based verification

  • Inputs they used for years (like Maine's biosolids) are now recognized as contaminated

  • They lack the capital to retrofit operations for measurable accountability

  • They cannot access climate-smart funding because they cannot document outcomes

  • They face an extinction event not because they did anything wrong, but because they built their operations in the wrong paradigm

Mendocino is replicating this pattern. The town is investing in infrastructure under 2017 assumptions that will be obsolete by 2030. The timing virtually guarantees a crisis.

The Window for Correction: Closing Fast

There is still time—barely—to avoid this collision. If Mendocino acts now:

Require a CEQA addendum before construction proceeds. Update the environmental review to reflect 2030 regulatory expectations, not 2017 assumptions. Model the system against the standards it will actually face, not the standards it was approved under.

Design for 2030 requirements from the start. Include advanced treatment verification, comprehensive monitoring networks, soil protection protocols, and real-time public reporting in the initial construction. The marginal cost of doing this correctly now is a fraction of retrofit costs later.

Establish enforceable thresholds and corrective actions. Don't wait for regulations to force compliance. Adopt protective standards voluntarily, with clear triggers that pause irrigation if contamination is detected. This protects the aquifer and demonstrates due diligence that will matter when liability questions arise.

Engage the community in transparent oversight. Public reporting and community involvement create accountability that protects everyone—residents get early warning of problems, and project operators have documented evidence of responsible management.

Budget for the real operational costs. A system designed to protect Mendocino's shallow aquifer in the 2030 regulatory environment costs more to operate than one designed for 2017 narrative compliance. Budget honestly for what it takes to do this safely, or acknowledge the project is not financially viable under modern standards.

The Alternative: Repeating Maine's Mistake

If Mendocino proceeds on the current timeline with 2017 infrastructure and assumptions, the sequence is predictable:

  1. 2026-2027: System begins operations. No immediate problems detected with conventional monitoring.

  2. 2028-2029: Regulatory expectations shift. Advanced testing (not previously required) reveals elevated CECs in monitoring wells—if monitoring wells exist. Sodium levels in soil show structural degradation. Nitrate trends upward in downgradient domestic wells.

  3. 2030: New regulations in force. Mendocino's system does not comply. Retrofit costs are prohibitive for a small community. Operations continue while "studying the issue."

  4. 2032-2035: Domestic wells show contamination. PFAS detected at levels of concern. Community faces safe drinking water crisis with no municipal system backup. Property values decline. Health concerns mount.

  5. 2035+: Litigation, remediation attempts, and a contaminated aquifer that will take decades—if ever—to recover.

This is not hypothetical. This is Maine's pattern, now playing out in Mendocino's future unless the paradigm shift happens before implementation, not after.

The Core Question

The question is not whether Mendocino's reclaimed water project will face 2030 regulatory standards. It will. The question is whether the infrastructure will be designed to meet those standards, or whether the community will spend the 2030s trying to retrofit a system that was obsolete before it finished construction.

Mendocino is scheduled to implement old-paradigm infrastructure into a new-paradigm regulatory reality. Without immediate course correction, the project is designed to fail.

Agriculture and Water: Parallel Crises and One Lesson

The crisis facing small farmers is not separate from Mendocino's water dilemma—they are expressions of the same systemic failure. Both agriculture and water management are discovering that narrative compliance, which sustained operations for decades, can no longer protect public health or environmental integrity.

Maine's Cautionary Tale

For decades, farmers in Maine followed practices approved and promoted by the state. The state itself delivered biosolids and other materials under assurances of safety. These inputs were certified, tested under the standards of the time, and presented as beneficial soil amendments that would improve fertility and support sustainable agriculture.

Years later, testing with advanced methods revealed PFAS contamination so severe that lands once used for food production are no longer considered suitable. More than 300 farms are now dealing with contamination that renders their products unsalable, their land unusable, and their livelihoods destroyed. The state is paying for medical monitoring and treatment to reduce toxin levels in farmers themselves—people who trusted the system and followed every rule.

The lesson is systemic: when institutions promote inputs or practices without quantifiable proof of safety, rural communities bear the consequences. The farmers did nothing wrong. The state followed its own protocols. But the protocols were built on narratives, not measurements. By the time the measurements were possible, the contamination was irreversible.

The Same Dynamic in Mendocino

Mendocino faces an identical paradigm trap. The 2017 CEQA approval was legitimate under the standards of its day. The wastewater treatment plan likely meets conventional regulatory requirements. Institutions are following established protocols. But those protocols are narrative-based: if you follow these treatment steps, the water will be safe.

The question Mendocino must ask is: do we wait for the measurements, or do we require them first?

If Mendocino irrigates above its shallow aquifer based on narrative assurances, and contamination is later detected, the community will face the same irreversible harm that Maine's farmers now endure. There is no municipal water system to fall back on. There is no alternative aquifer. Once the bluff's shallow wells are compromised, the town's drinking water security is gone.

The choice is whether to learn from Maine's experience—or repeat it.

Training for the New Paradigm: ORCA

To meet this reality, I helped start a nonprofit dedicated to educating farmers and land managers for the world of measurable accountability. One flagship project is ORCA—Organic Regenerative Certified Apprenticeship, certified at both federal and California state levels.

ORCA exists because the extinction event facing small farms is not inevitable—it is a consequence of unpreparedness. Farmers trained in narrative compliance cannot suddenly pivot to outcome-based verification without new skills, new tools, and new ways of thinking about their land.

Focus areas:

  • Ionic relationships: Apprentices learn how calcium/magnesium balance, sodium hazards, and trace mineral interactions drive soil structure, water infiltration, and microbial diversity. This is not abstract chemistry—it is the foundation of soil resilience under climate stress.

  • Soil biology: Training includes microscope-based assessment of bacterial and fungal populations, protozoa, and nematodes. Apprentices learn to read soil as a living system, not an inert medium.

  • Contamination pathways: Understanding how contaminants move through soil profiles, how ionic displacement accelerates leaching, and how to design monitoring systems that detect problems before they become crises.

  • Nutrient density measurement: Moving beyond NPK to measure plant tissue for micronutrients, secondary metabolites, and Brix levels that correlate with nutritional quality and pest resistance.

  • Greenhouse gas accounting: Practical training in carbon sequestration measurement, methane flux monitoring, and nitrous oxide mitigation strategies.

  • Hydrogeologic basics: How to read capture zones, understand residence times, model infiltration rates, and protect groundwater in agricultural contexts.

Tools and methods:

  • Chemical analysis protocols for soil, water, and plant tissue

  • Microscopy for biological assessment

  • Data management systems for continuous monitoring

  • Third-party verification procedures

  • Adaptive management frameworks tied to measurable feedback

Objective: Prepare apprentices to operate in a world where funding, certification, and public trust depend on data, not narratives. Where regulatory compliance requires continuous proof. Where survival depends on the ability to measure, interpret, and adapt.

This is not about branding or marketing. ORCA is a response to structural change. The 2030 regulations are coming whether farms are ready or not. The federal funding is available, but only for those who can document outcomes. The carbon markets are real, but fraudulent claims carry criminal liability. The next generation of farmers must be equipped for this reality—or they will not farm at all.

Direct Call to Action for Mendocino

  1. Require a CEQA addendum or supplemental EIR focused on CECs, ionic soil dynamics, hydraulic mounding, and enforceable monitoring/mitigation.

  2. Install sentinel wells and publish the data—methods, results, thresholds, and actions—on a public dashboard.

  3. Adopt soil protection standards (SAR/ESP limits, Ca amendments, infiltration/permeability checks) tied to irrigation management.

  4. Commit to corrective triggers that pause or modify irrigation when thresholds are exceeded.

  5. Engage independent review by hydrogeologists and soil chemists to validate models, monitoring designs, and operating protocols.

Community members should actively engage with local decision-makers by attending school board meetings, contacting officials, and forming groups to advocate for these essential safeguards.

If the plan can't stand up to measurement, it shouldn't stand over our water.

Closing Reflection

I don't like to come to town because the contradictions are so plain. In Comptche, the relationship of ions shows me a world that's measurable, tangible, and accountable. In town, I see institutions clinging to narratives that no longer protect us. We're living through a paradigm shift: from promises to proof, from labels to outcomes, from stories to ions. Mendocino's future depends on making that shift—before irrigation begins, not after wells are compromised.

References

California Environmental Quality Act (CEQA): Statute and Guidelines (California Public Resources Code §§21000–21189; CEQA Guidelines, Title 14, CCR).

California Governor's Executive Orders: Climate change and carbon neutrality targets; 2030 interim goals and agricultural implications.

California Air Resources Board: Scoping Plan for achieving carbon neutrality; agricultural sector requirements and verification protocols.

State Water Resources Control Board: Recycled Water Policy and Amendments; permitting and monitoring guidance for water reuse projects.

US EPA: Water reuse frameworks, PFAS guidance documents, pathogen control and risk assessment resources for reclaimed water and aquifer recharge.

USGS: Groundwater mounding and capture zone analyses; modeling approaches for shallow aquifers in permeable soils.

USDA Natural Resources Conservation Service (NRCS): Climate-smart agriculture and forestry strategy; conservation program outcome-based payment structures.

Inflation Reduction Act (IRA): Climate-smart commodities program; verification and monitoring requirements for federal funding.

FAO / USDA: Soil sodicity and salinity management; SAR/ESP concepts, field diagnostics, and amendment strategies (calcium-based remediation, infiltration protection).

WHO: Guidelines for safe use of wastewater and excreta in agriculture; microbial risk management and public health considerations.

Peer-reviewed literature on CECs: Reviews documenting pharmaceuticals, PFAS, endocrine disruptors, and microplastics in recycled water and groundwater beneath irrigation sites.

Maine Department of Environmental Protection: PFAS contamination reports; biosolids program investigation; farm assistance and remediation programs.

California Supreme Court (2022): Rulings on local groundwater well permits and CEQA review requirements.

U.S. Supreme Court (2025): Decision on EPA's use of "end-result" permit conditions under the Clean Water Act.

European Union Common Agricultural Policy (CAP): Climate-smart agriculture frameworks; three decades of outcome-based regulation informing California's 2030 timeline.