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An open letter to the supervisors of Napa County:

Over the past six months or so, I have watched with great interest and concern the discussions, meetings, and decision-making processes used at the Planning Commission level in determining whether “solar farms” should or should not exist in Napa County—and where.

The final vote appeared to indicate that the feeling of three commissioners was that we could “start building commercial solar installations and figure it out as we go.”

I submit that there is another and better way to approach this issue in making final determinations for regulation of such projects in our agricultural areas.

There is no question that technological development has provided important benefits for health and the environment. While the understanding of the environment and health risks has advanced greatly, so too has the complexity of all the potential factors that can affect health as well as the environment. Thus great uncertainty remains about the health effects of many activities. Of concern to me as a medical scientist is the fact that a very important principle appears to have been missing in all of the Planning Commission discourse over this issue. This principle is known as the “Precautionary Principle.”

The Precautionary Principle originated as a tool to bridge the gap between uncertain scientific information and a political responsibility to act to prevent damage to human health and ecosystems. This principle assumes that for every action there are going to be reactions — and often those are unknown. Limitations in scientific tools and in the ability to identify or to quantify causal relationships are occasionally misinterpreted as evidence of safety.

The Precautionary Principle is the scientific prototype of risk management. If there is a plan in place that makes a change, what results might we see? And for those risk factors known, partially known, or unknown, what ameliorative means should we evaluate for risk management and how should we plan to recognize potential risks should they arise?

The World Health Organization in 2004 stated when it adopted this principle: “The Precautionary Principle is a tool for policy and decision-making designed to ensure that people or entities bear political responsibility for taking action to prevent damage to health and ecosystems in the face of uncertain scientific information about health and ecosystem risks.”

The statement goes on to say, "At the core of the Precautionary Principle lies the intuitively simple idea that decision-makers should act in advance of scientific certainty to protect the environment (and with it the well-being interests of future generations) from incurring harm.”

Failure to take precautionary action can have severe social and economic costs. There are many examples of this noted in such things as lead in paint, tobacco, asbestos and DDT—and their effect on humans and the environment. Early science and observations raised questions about these, but it was many years and considerable damage to the environment and humans, before any action was taken to mitigate what damage could then be contained.

Of note, the California Department of Toxic Substances Control, has labeled spent/used solar panels as “hazardous waste,” soon to be called “Universal Waste,” a category designated by the Environmental Protection Agency that is a subcategory of hazardous waste.

If these spent panels are already labeled as hazardous, then to the aforementioned point, the “Precautionary Principle” approach seems the judicious way to begin the examination of the requests for development of solar installations on large acreage of agricultural land in Napa. An examination of the environmental , and ecological, and biodiversity science of the effects of large solar installations that exists in the literature would seem the best place to begin.

While there is some conflicting information in some areas, there are pertinent discussions and needed scientific evaluations of the impact of such large expanses of solar panels. In those studies that are somewhat conflicting, questions are raised that the county would do well to incorporate into a plan that is clearly built around the Precautionary Principle.

I respectfully challenge you to embrace this model when deciding the issues of commercial solar projects in Napa, and what regulations should be.

Dr. Geni A. Bennetts

Napa

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