July 18, 2019

Dear Napa County Board of Supervisors and Director Morrison,

Re: Proposed Small Winery Protection and Use Permit Streamlining Ordinance.

We are very concerned about this proposed ordinance and see it as further erosion to the Agricultural Preserve, a shortcut to more urbanizing influences that degrade our environment and bring more traffic and events irreversibly into agricultural lands. It is unthinkable to take on such an open-door policy for more expansion, across potentially hundreds of wineries, without both individual and cumulative environmental impact analysis.

Specifically, we have the following questions and comments:

Why is the county acting to expand “small” wineries? Is there a compelling need to assist nearly half the wineries in the county to become larger with no appropriate environmental analysis?

Please clarify the number of “small wineries” that could avail themselves of this ordinance. How many plans and applications for additional small wineries are in process with the county? What is the potential total impact? What is the potential cumulative impact of the possible “no impact” expansions?

There is a distinct conflict in the wording of item #2 in the proposed ordinance. How is it possible that each small winery “has no new significant environmental impacts, and does not increase the severity of existing significant environmental impacts” when it is stated that small wineries have “ limited impact.” This ordinance (and the county) needs clear and consistent definitions of the words “limited” as well as “significant.”

In light of the direction and needs of the Climate Action Plan, we must have a cumulative impact analysis on our carbon budget before this can be considered. On the surface, it is highly contraindicated for GHG and ongoing climate considerations.

The word “employee” must be defined. Many people who work at wineries are not employees of the winery; they are often hired through temp agencies or work for catering companies, vineyard management companies or other vendors. An increase of 10 or 10%, whichever is greater, in actual employees of a winery would lead to large impacts of more traffic, more emissions, more water usage, and wastewater concerns. The result could be far larger than acknowledged based on official employees. This could result in at least 2,000 more workers driving to and from work (10 x 200 small wineries). Again, a need for a cumulative impact CEQA analysis.

With gridlock on Silverado Trail and Highway 29: Traffic must be analyzed as part of the cumulative impact of this expansion.

What does “change in hours of operation” mean? Music until 10 pm every weekend? Early dinners and late-night dancing? Expanded weddings and auctions? With the change in direct to consumer marketing, we need clarification on what hours and how this will interface with our already impacted residents and restaurants operating within the urban centers.

Marketing events could jump to a staggering 260% increase in from 10 to 26 events annually. For a neighbor, this is an event, and all its attendant traffic and noise, every other weekend of the year. Multiply this by 200 or more wineries. This is not a negligible impact.

On gallonage: when the overall increases are counted, this could amount to a 50% increase in production (20k – 30k gallons) Is that correct?

This proposed small winery protection may be “streamlining” for a large number of wineries. For the environment, our air quality, traffic and the quiet, rural quality of life we treasure, it’s a whopper of a “steamroller”.

Charlotte Williams
President, Napa Vision 2050