The 40-Acre Test: What SGMA Feels Like for a Small Farmer
- Jules Martella
- Jul 1
- 8 min read
I Am the Farmer People Say They Want to Protect
I am the kind of farmer people often say they want to protect. I farm 40 acres of walnuts.
That sentence sounds simple until you understand what lives underneath it.
Forty acres is not a corporate department. It is not a water team. It is not a compliance office. It is not a staff of consultants sitting around a conference table waiting for the next requirement to interpret. Forty acres is a kitchen table and a young man who leases the land. His first lease.
It is a stack of mail. A pump. A field. A crop. A family. A property tax bill. A water bill. A power bill. A broken line. A deadline. A notice that may or may not make sense the first time you read it.
I did not enter farming through a strategic business plan. I entered through loss. One day, the land was part of my life. Then suddenly, after the death of the farmer, it was my responsibility.
That is the part policy rarely understands. Laws are written for categories: Landowner. Grower. Stakeholder. Groundwater user. Domestic well owner. Small farmer. But real life does not arrive in categories.
It arrives all at once.
Forty Acres Is a Kitchen Table, Not a Compliance Department
When people talk about agriculture, they often talk in big numbers. Acres. Acre-feet. Allocations. Fees. Basins. Subbasins. Sustainability timelines. Reporting deadlines. Those numbers matter. I know they matter.
But behind every number is a person trying to make the math work.
On a 40-acre farm, there is not much distance between the policy conversation and the kitchen table. A decision made in a meeting shows up later as a letter, a fee, a form, a deadline, or a new question I have to figure out how to answer.
Sometimes it is not one big thing that breaks people. Sometimes it is one more thing.
One more bill.
One more report.
One more repair.
One more requirement.
One more system to learn.
One more meeting to attend.
One more acronym to understand.
One more place where you wonder if you are already behind and no one told you.
That is the reality of small farming. It is not romantic or simple. It is a 40 acre test of SGMA and the small farmer.
It is paperwork, risk, weather, labor, repair bills, market prices, power bills, compliance deadlines, and the constant pressure of trying to keep something alive that does not take a season off because you are tired.
Farming Already Comes With a Bill at Every Step
Before SGMA ever enters the conversation, I am already paying to farm.
I pay for pruning.
I pay for spraying.
I pay for fungicides, mite sprays, herbicides, and pesticides.
I pay for fertilizer.
I pay for labor.
I pay for harvest.
I pay for repairs.
I pay when a water line breaks.
I pay when the well needs attention.
I pay when equipment fails.
I pay electrical bills that can take your breath away, and I pay standby charges for the privilege of having power available when I need it.
I also have another part-time job worth of reporting to do: nitrogen management reporting. water reporting. compliance reporting. Forms, deadlines, records, and requirements that do not prune a tree, fix a pump, harvest a walnut, or pay the next bill.
That is what people outside farming often miss. The cost of farming is not one cost.
It is a thousand cuts, and a prayer that at the end of the year the harvest will cover the costs.
Every step has a bill attached to it. Every decision has risk. Every repair comes at the wrong time. Every crop year carries uncertainty before the first new regulation ever lands in the mailbox.
And then SGMA arrives as one more thing.
Then SGMA Arrives as One More Thing for a Small Farmer
SGMA, the Sustainable Groundwater Management Act, was created for an important reason.
Groundwater has to be managed. Anyone paying attention in the Central Valley knows that. We have seen the signs. We have seen wells struggle. We have seen land sink. We know the old way cannot simply continue forever without consequence.
I am not arguing against groundwater sustainability.
I am not arguing against planning.
I am not arguing against responsibility.
I believe domestic wells matter. I believe subsidence matters. I believe long-term water planning matters. I believe the future of California agriculture depends on whether we can figure this out.
But I also believe we have to be honest about what implementation feels like on the ground.
Because SGMA does not arrive on an empty desk with extra money waiting for it.
It arrives after the spray bill.
After the power bill.
After the broken line.
After the fertilizer.
After the labor.
After the well repair.
After the nitrogen management reporting.
After the crop price disappoints you.
After the bank still expects to be paid.
After the farm has already asked everything it can ask from the person trying to hold it together.
And then there is one more requirement.
One more deadline.
One more meeting.
One more portal.
One more notice.
One more cost.
That is the 40-acre test. Not whether I care about sustainability.
I do.
The test is whether a farm like mine can survive the cost of farming and the cost of compliance at the same time.
I Am Not Against Groundwater Sustainability
I want to be very clear about this.
This is not an anti-SGMA argument.
This is not an anti-agency argument.
This is not an anti-large-farmer argument.
This is a witness statement from a 40-acre walnut farmer who is living close enough to the ground to feel how these policies land.
There is a difference.
From far away, implementation can look like process. From the ground, it feels like capacity. Consisder the following questions:
Who has the staff to track every deadline?
Who has the money to hire the consultant?
Who has the time to attend every meeting?
Who understands which agency is asking for what?
Who knows which form matters?
Who can absorb another fee?
Who can make a mistake and survive it?
Those are not abstract questions. Those are survival questions.
And they matter because the system may be neutral on paper, but it is not neutral in practice.
The System May Be Neutral on Paper, But It Is Not Neutral in Practice
When the same requirement lands on two very different farms, it does not create the same burden.
For one operation, a new report may mean forwarding an email to the office manager.
For another, it may mean sitting at the kitchen table after dinner, trying to figure out what the notice means while the rest of the bills are still waiting.
For one operation, a consultant is part of the annual budget.
For another, a consultant may be the money that was supposed to pay for repairs, fertilizer, labor, or the next spray.
For one operation, a new fee may be frustrating.
For another, it may be the thing that tips the fragile math sideways.
None of this is a character issue.
It's scale. And scale matters.
A larger, better-resourced operation may have people who can interpret the rules, attend meetings, track changing requirements, apply for grants, analyze options, and plan years ahead.
A smaller farm may have one person doing everything.
That does not make the smaller farmer less responsible.
It makes the burden different.
When we pretend the burden is the same because the rule is the same, we miss the reality of how implementation actually works.
The 40-Acre Test Is About Capacity
The 40-acre test is about capacity. Not just land capacity. Human capacity. Financial capacity. Administrative capacity. Emotional capacity. There are five questions that need to be answered.
Can a small farm absorb another layer of regulation without losing the ability to function?
Can the farmer understand what is being asked without hiring someone every time a new letter arrives?
Can the farm pay for compliance without sacrificing repairs, labor, crop health, or basic operating needs?
Can the person responsible for the land keep up with the pace of change while still actually farming?
Can small farms survive a transition that requires time, money, technical support, and administrative muscle many of them simply do not have?
These are the questions we should be asking before small farms fall behind. Not after.
Because once a small farmer is confused, behind, discouraged, or financially underwater, the damage has already begun.
Local Control Only Works If Local People Can Participate
I still believe local control matters. In fact, I believe it more now than ever; however, local control only works if local people can actually participate.
It has to mean people understand the process before they are expected to comply with it.
It has to mean notices are written in plain language.
It has to mean meetings are understandable.
It has to mean phone calls are answered.
It has to mean office hours, real outreach, patient explanations, and enough repetition that people who are busy, overwhelmed, grieving, aging, farming, working, or caring for families still have a chance to catch up.
Communication is not decoration. Communication is infrastructure. If people do not understand what is happening, they cannot participate in local control. They can only react to it.
And reaction is not the same as trust.
Small Farms Cannot Be Talking Points
If California says small farms matter, then small farms cannot only matter in speeches, grant language, outreach materials, and public meetings.
They have to matter in implementation.
They have to matter in timelines.
They have to matter in fee structures.
They have to matter in how notices are written.
They have to matter in how reporting systems are designed.
They have to matter in how agencies communicate.
They have to matter in how much support is available before a farmer is already behind.
A small farm does not have unlimited administrative muscle. It does not have unlimited cash flow. It does not have unlimited time.
Sometimes it has one person trying to hold the whole thing together. That does not mean groundwater management is wrong. It means implementation has to be honest about who is carrying the weight.
Are We Protecting Small Farms, or Filtering Them Out?
These are the questions I cannot stop asking: are we protecting small farms? Or are we quietly filtering them out? Are we keeping track of how many small farms go under in the name of protection?
If the only farms that can survive sustainability are the farms with enough money, staff, infrastructure, and technical support to absorb the process, then we have to be brave enough to name what is happening.
We may not be saving small farms. We may be designing a future only the best-resourced farms can survive.
I do not believe that is the stated goal and I do not believe most people working on groundwater policy want that outcome, but outcomes are not measured by intentions.
They are measured by what happens on the ground, and on the ground, the pressure is real.
The Future Has to Have Room for Farms Like Mine
I am not asking to be excused from the future. I am asking whether the future has room for farms like mine.
I am asking whether a 40-acre walnut farmer can comply, adapt, understand, participate, and survive without being buried under costs and complexity.
I am asking whether small farms will be part of California’s groundwater future, or whether we will praise them in public while making it nearly impossible for them to remain.
I believe groundwater has to be managed.
I believe local control matters.
I believe domestic wells matter.
I believe agriculture has to change.
I also believe the people closest to the land need to be part of shaping what comes next.
Not as an afterthought.
Not as a checkbox.
Not as a category in a report.
As real people with real bills, real fields, real responsibilities, and real limits.
That is the 40-acre test.
And I am living it.
Comments