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A recent appeal submitted to the California Coastal Commission following County approval of a Coastal Development Use Permit Modification and finding a Final Subsequent Mitigated Negative Declaration with Addendum adequate for a Mendocino Unified School District “Water Supply and Storage Project” shows how deeply concerned a growing number of residents are of the project’s impacts upon their health, welfare, property, water supply, and greater coastal resources.
Given the hot mess of a public hearing held by the Mendocino County Planning Commission on December 19th, an appeal was likely. Procedural deficiencies, inaccuracies, omissions, violations, and errors have plagued the project throughout the environmental review process and ramped up after it joined with the Mendocino City Community Services District in combining grant funding for a vastly different project. Public activism, California Coastal Commission intervention, and bid delays have kept the two districts and their mutual project manager at GHD Engineering in constant reaction to increasing public concern. By all appearances, it’s doubtful they ever saw it coming.
On its face, the project’s analyses and reports appear detailed and thorough enough, but in-depth, they are without whole or convincing evidence with numbers that sometimes don’t add up. Between the lines, there’s a lack of some evidence and studies, with conclusions based on unsupported assumptions and data which, combined with a general lack of transparency, are receiving more and more public scrutiny.
Concerns have run the gamut, from lack of proper notifications and other procedural errors encountered during the environmental review and public hearing processes to substantive issues including noncompliance with Mendocino County Code regulations, local coastal groundwater development guidelines and water rights, questions about the revelancy for school districts to sell and distribute state water resources, a loose Memo of Understanding signed between MUSD and MCCSD (the fourth, since 2022) and still no legally-binding operating agreement with terms to spell out critical allocation, prioritization, distribution, and cost criteria, the consideration of the project for consolidation into a community or even regionalized water system, the depletion of a local aquifer in an area designated as a Critical Groundwater Area, the aridification of a local soils, hillsides, and the wildfire risks associated with it, adverse impacts to sensitive wetlands and headwaters in an “Environmentally Sensitive Habitat Area” of protected species formed by Slaughterhouse Creek, viewshed obstructions, noncompliance with county height limits, and conflict-of-interest issues with a member of the MCCSD Board of Directors who is contracted not only with MUSD but other customers in the watershed to operate and manage their respective water systems.
It may be that remaining supporters have not studied the environmental review documents, studies, or public comment well enough or attended meetings to hear presentations and public testimony. It’s understandable. Constantly-evolving plans have created a project record which is lengthy, tedious, and complicated – in large part because a full Environmental Impact Report was not pursued which would have more fully addressed the mounting questions and concerns that have been cited along the way. Instead, a truncated version of an EIR in the form of a Subsequent Mitigated Negative Declaration was prepared and adopted by MUSD (as Lead Agency), an Addendum added and approved by the County (as Responsible Agency), and a Coastal Development Use Permit applied for, halted, then reapplied for in modified form just two weeks before the whole matter was hastily and confusingly conditioned and then approved by resolution of the Mendocino County Planning Commission.
Originally conceived as as a straightfoward project by MUSD nearly ten years ago to resolve the school district’s drinking water deficiencies, the project was reconceived in late 2021 as a combined, co managed emergency water supply and storage project “for the benefit of the village of Mendocino” and
the single-square mile MCCSD. Since then it has morphed into a project wholly controlled by MUSD and their 420-square mile district, rebranded and emphasized as a fire suppression project, and rebranded again as a well testing project. Having ballooned into a $11.1 million endeavor, the project manager’s current narrative focuses on test well drilling and not the production wells and storage tanks the project is intended to become. Betting on past actions, however, even these plans could change. But as it currently stands, an amendment to the CDP demonstrating adequate proof of water by way of further hydrological study will be required before project construction can begin.
As late as the December 19 public hearing, new details continued to be discovered and disclosed, some posted as late as the morning prior to the 10:00 a.m. public hearing. Before then, potentially embarrassing comment was removed from the record, other public comment took as long as several days or over a week to be posted, while others were were buried in succeeding postings or incorrectly attributed. The rush to approve was on, and despite public objection due to the insufficient time to review, consider, and prepare comment, the project was approved.
One of the more salient points resulting from the hearing was pressed out of the project manager who admitted that only 200,000-300,000 gallons of stored water was needed instead of the 630,000 proposed. Another was raised by a planning commissioner who reported that groundwater dye testing performed at the site years ago reappeared in wells “all over” the Town of Mendocino west of Highway 1. Curiously, Public Records Act requests submitted to MCCSD, the County of Mendocino, and Department of Water Resources have not produced the test results. Yet another detail disclosed in hearing comments was that the closest domestic well is estimated to be just thirty feet away from the wellfield: all are points which remain unaddressed in the environmental review for the project.
Make no mistake: whatever what the community is being told and sold about an emergency water supply, GHD’s project manager acknowledged in a October 21, 2024 communication to County staff, “MUSD may elect to provide water to members of the community who are in need during periods of declared drought emergency when water is not available from other water suppliers in the area, however, they have no obligation or requirement to do so”. He and the former MCCSD president are on record as describing members of the public challenging the project as conspiracy theorists. Regardless of the name-calling, which is rarely prudent conduct on behalf of elected officials or their consultants, most reasonable people would likely agree with adjacent and down-gradient property owners, many of which have experienced well depletion problems, who question the project. Imagine you’re a homeowner with a well near the new wellfield with up to nine actively-producing wells or within sight of two enormous stainless steel storage tanks four stories tall. For folks in town, an even greater challenge exists: establishing the burden of proof required that a wellfield located a mile or so uphill at the school district’s headquarters on Little Lake Road has adversely impacted your water supply downtown. Still supportive?
As an elected member of the MCCSD who originally approved the project in January 2022, I must admit that this is the sloppiest governing, the sloppiest project, I’ve ever witnessed. Any vain attempt to chronicle its crooked, complex path would require a tome and mental files of tungsten steel. The fact that two of five MCCSD directors who originally voted to support the project are now challenging it should speak volumes. Conspiracy theorists, both?
As one of those two directors, there’s much (at least some of us) weren’t informed at the time of proposal:
- that the wellfield would draw from the headwaters and wetlands of Slaughterhouse Creek (“gulch”);
- in a location the County has designated as a “Critical Groundwater Area” and a basin the State has designated as “Critically Overdrafted”;
- that the water supply would not be developed and co-managed to benefit the community of Mendocino as we understood it would be, but the 420 square-mile MUSD;
- that the project would not comply with the MCCSD groundwater extraction ordinance; – that MUSD would become the project’s Lead Agency under CEQA, oversee environmental review, and utilize an existing Initial Study/MND designed for drinking water upgrades; – that it was planned in an “Environmentally Sensitive Habitat Area” of protected species; – adjacent a residential neighborhood with a history of private, domestic well depletion problems rather than the “good well production” area described to us;
- with the closest private domestic well as little as 30 feet away;
- that property values may be negatively affected;
- that a pair of four-story tall, stainless steel storage tanks would be contructed in exceedance of the County’s mandatory height limit of 35’ within the Highly Scenic Area of Little Lake Road Trail; – that the tanks that would be continuously filled or “topped-off” throughout the year and not simply during the rainy season if/when precipitation totals allowed;
- that the treated, potable water would be used to irrigate school playing fields; – that former dye tests determined the project site’s groundwater flowed west of Highway 1 and throughout the town of Mendocino;
- that the project would be considered for consolidation as part of a public water system; – that meetings were being quietly held to discuss and decide the project and its funding; – that personal requests for a physical tour of the project area would be ignored; – and that critical allocation and distribution criteria requested in 2021 would not be developed for another three years – and counting.
With the Coastal Commission considering a new appeal by ten and more appellants on the heels of an original one filed by a solo appellant in April, 2024, it’s critical that residents and political leaders recognize the narrative being spun by those with special interests in it prior to passing judgement. Before buying into the anticipated narrative or rumor that will with little doubt, portray appellants as conspiracy theorists or boondogglers (as one MCCSD director has described it), consider what you would do if you were personally impacted by a grand total of three huge new water tanks within your home’s or business’s viewshed (two storing potable water, a third with recycled water) and up to nine wells in a dense, geographically-compressed wellfield. With your viewshed obstructed, your water supply in jeopardy, your property values diminished, and sensitive coastal resources impacted, how would you react? If residing in the village, consider how you will possibly afford to establish the burden of proof required of you that the new wellfield has depleted your family’s water supply. Anyone able to sympathize should not be supportive but rather, protective of our mutual resources and voice objection.
The rush to construct has made a profound mess of things, and it didn’t have to be this way. A better project is possible, one that is far more logical, sustainable, equitable, inclusionary, consistent with statutes, regulations, ordinances, and county codes, developed with far more transparency, and this time – one that is well within the People’s earshot.
Christina Aranguren
Former Director, MCCSD
Current Chair/Appellant, MendoMatters.org
Good grief. This project exemplifies everything wrong with CA these days. First, there is the dependency on government grants that not only slow the process down but come with strings attached. And I detest the fact that you have to curry favor with an elected official to get the money. Secondly, there is a regulation for everything that moves or doesn’t move. Satisfying all of these requirements is a nearly impossible task. Next, the competing needs of the parties that never seem to seek compromise. A project that should have been accomplished in 12 months is now 10 years and running with no end in sight.
Another example is the Bullet Train whose costs and delays are beyond imagination with no meaningful results. That is what we are looking at here.
No, it’s not. Its people like this that prevent will prevent another Potter Valley/pg and e/lake Pillsbury situation. Thank you and let’s be responsible for our actions.
Back to using wine to flush the toilets, poor greenies , they can afford it.The Headlands used to be where the Chinese population lived before it was burned down.
And how is it relevant that Chinese immigrant laborers once lived in the Headlands?