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I would like to respond to Ms. Chris Malan’s letter, published on Sept. 2, 2018, where she recommends that water be the focus of the county’s Strategic Plan (“Impose moratorium on new slope vineyards”).

Ms. Malan’s comments are welcome, and water is likely to play a prominent role in the plan, but the letter contains incorrect information. My intent is not to be argumentative, but it is critical for the success of the Strategic Plan that community decisions be based on factual evidence.

The Strategic Plan will define county priorities through 2022, and the actions needed to achieve those goals. While debate often centers around land use, the county has nearly 20 departments and over 1,350 employees, who deal with issues including law enforcement, fire, healthcare, libraries, support services, parks, and roads. The Strategic Plan will encompass all of the county’s many responsibilities and public concerns.

I would like to respond to several specific issues raised by Ms. Malan.

Algae blooms are a health concern throughout California. They are caused by increased water temperature, high nutrient concentrations, and low water flows. In 2014, the San Francisco Bay Regional Water Quality Control Board (RWQCB) approved a proposal to take the Napa River off the list of impaired water bodies for nutrients resulting in excessive algae growth. The State Water Quality Control Board (SWQCB) will consider the delisting in the summer of 2020.

County staff have worked with the RWQCB to ensure that the new vineyard Waste Discharge Requirements are compatible with our erosion control plan process. As a result of these requirements, other jurisdictions in the Bay Area will be following the model that Napa County established more than 25 years ago to protect watersheds and the quality of our streams.

Forests are not being eliminated within Napa County. Nearly 42 percent of the county (or 213,000 acres) consists of oak woodlands, riparian forest, or conifer forest. In comparison, only 13 percent of the county is used for farmland, and 6 percent is developed with urban uses. Trees cover more than twice as much land in Napa as agriculture and cities combined.

Since 1991, the county has approved an average of eight new wineries annually. There have never been 50 new wineries approved in one year. In fact, there haven’t been 50 new wineries approved over the past eight years combined. The highest number of new wineries approved in any one year was 17 in 2006.

Most vineyards are not planted on steep slopes. There are currently 53,451 acres of vineyards in Napa County. More than 57 percent of the vineyards are on lands that have slopes of less than 5 percent. More than 85 percent of vineyards are on slopes of less than 15 percent.

The Conservation Regulations already require stream buffers and tree retention. Setbacks of 35 to 150 feet are mandated for vineyards, depending on the surrounding slopes. Setbacks may also be applied to vineyard replanting and previously disturbed areas may be required to be revegetated. A minimum 60 percent of all tree canopy must be retained on any parcel where a vineyard is proposed. When biological studies are also applied, 90 percent of on-site trees are protected.

Extensive monitoring of wells around the Napa Valley shows that ground water levels remain steady. There is no evidence of subsidence, water quality impacts, salt water intrusion, or streams being affected by overdrafting. The county has prepared a Groundwater Sustainability Plan (Basin Analysis Report), as required under state law. The plan is currently under review by the California Department of Water Resources. In addition, the county has joined with the city of Napa to voluntarily study water quality in the watersheds of the municipal reservoirs.

The Napa River is proposed for listing as an impaired water body for chlordane, DDT, dieldrin, mercury, and PCBs. No action by the SWQCB has yet been taken. However, the pesticides referenced have been banned for over 30 years. Mercury is a mineral that naturally occurs throughout the region and has not been mined locally more than 50 years.

The county administers 29 permits that allow the use of hold and haul to process high strength wastewater. Six facilities are located within city limits and another five are within the airport industrial area (serviced by the Napa Sanitation District). Only 18 of over 500 wineries (less than 4 percent) have hold and haul permits. Note that on-site wastewater systems also need to have their tanks regularly pumped.

Public policy should be based on goals that we can all agree upon, relying on fact-based analysis. I appreciate and share Ms. Malan’s interest in protecting our natural resources and welcome the ongoing dialogue. The best way that we can ensure a comprehensive and balanced approach to protecting our natural resources is for the public, business leaders, and local government to work together in developing a sustainable vision for all of Napa County.

David Morrison, Director

Napa County Planning, Building, and Environmental Services Department

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